Wing: investment adviser

WFI will consider the following aspects of a Member’s situation: assets and liabilities, financial goals, lifestyle preferences, applicable time horizons, income-based scenarios, investment risk preferences, and personality traits. Proposed financial planning guides – which are furnished by WFI’s proprietary algorithm – will provide personalized guidance that adheres to a fiduciary standard, including guidance for savings, money management, asset allocation, and funding. Each planning guide provided by WFI is based solely upon information provided by the Member. As a result, the planning guide relies on accuracy and completeness of the information provided by the Member. Member Content In addition to tailored planning guides for each activated “experience”, members will occasionally receive Insights that are based on activated experiences. Insights are delivered in the Home feed and within the Experience module. Additionally, subscribers (Members) can receive creative content, such as video interviews or updates, within their in-app Home feed. Portfolio Management Through Partner Firms. Members are referred to Wing by participating investment advisers (“Partner Firms”) that have entered into agreements with Wing. Each Partner Firm creates and maintains its own model portfolios (currently a set of ETF-based portfolios at five risk levels) and supplies them to Wing. A Member referred by a Partner Firm may open a separate Managed Account within the Wing App and invest in one of that Partner Firm’s model portfolios. After a Member completes the risk questionnaire, the Wing App maps the Member’s risk profile and time horizon to one of the Partner Firm’s model portfolios and recommends it; the Member confirms the selection in the App. Wing then implements the model portfolio in the Managed Account and rebalances it as described in Item 8. Wing does not select investment advisers for Members. The model portfolios available to a Member are limited to those of the Member’s Partner Firm. A Member may not select a model portfolio offered by a different Partner Firm; doing so would require closing the Managed Account and being referred to Wing by that other Partner Firm. Wing does not evaluate Partner Firms against one another on behalf of Members and does not replace a Member’s Partner Firm. If Wing’s relationship with a Partner Firm

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ended, Members referred by that Partner Firm would need to transfer or liquidate their Managed Accounts or, with their consent, transition to another arrangement; Wing would notify affected Members in advance. As of the date of this brochure, all Members with Managed Accounts (other than accounts of Wing’s related persons) were referred by, and are invested in the model portfolios of, SignatureFD, LLC. Artificial Intelligence in Planning Guidance. Since July 2026, the written financial planning guidance displayed in the Wing App (financial assessments, advice items, and briefs) is drafted by third-party large language models from figures computed by Wing’s deterministic planning engine and is reviewed by automated verification steps before it is published. Artificial intelligence does not compute any financial figure shown to Members, select investments, determine allocations, or execute transactions. AIgenerated guidance is non-discretionary, may contain errors, and depends on the information Members maintain in the App. Wing remains responsible for the guidance it provides. Retirement Accounts Wing provides investment advisory services with respect to taxable accounts, traditional IRAs and Roth IRAs. Wing does not manage employer sponsored retirement plans and does not recommend that clients roll assets from employer sponsored retirement plans into IRAs. As part of its financial planning services, Wing may recommend that a client consider converting assets from a traditional IRA to a Roth IRA. Wing does not provide tax advice, and clients should consult their tax professional regarding the tax consequences of a Roth conversion.

C. Client Tailored Services and Client Imposed Restrictions WFI will provide an in-app planning guide for each individual Member. A set minimum number of questions for each experience must be answered in order to generate a planning guide. WFI may use model allocations together with a specific set of guidance for each Member based on their personal restrictions, needs, and targets. Members may not impose restrictions on guidance or types of guidance in accordance with their values or beliefs.

D. Wrap Fee Programs The Firm acts as a sponsor and/or portfolio manager for certain wrap fee programs. Under these programs:

The Firm provides portfolio management services. Members pay a single comprehensive fee (the "wrap fee") for advisory services, brokerage transactions, and custody costs. Wrap fee programs may offer certain benefits, including simplified fee structures and minimized transaction costs for active traders. Members should be aware that the wrap fee may be higher than the combined cost of purchasing the services separately.

Potential Conflicts of Interest

Limited Services: Wrap fee programs may restrict the universe of investments available to Members, potentially excluding certain securities or strategies that could otherwise be suitable for their portfolios. Additional Information More details about the Firm’s wrap fee programs, including their costs, services provided, and any potential conflicts of interest, can be found in the Wrap Fee

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Program Brochure (Appendix 1 to this document). Members considering a wrap fee program should carefully review this document before participating.

E. Assets Under Management WFI currently has the following assets under management: Discretionary Amounts

Non-discretionary Amounts

Date Calculated

$127,775

$0

March 2026

The Advisory Fee for the model portfolios currently offered through the Wing App is 1.00% per year; Advisory Fees for other Partner Firms’ model portfolios may range from 0.85% to 1.50% per year, as stated in the Member’s Fee Schedule. Of the Advisory Fee, a share set by agreement with the Partner Firm — currently as much as 85% of the Advisory Fee — is paid by Wing to the Partner Firm for its model portfolio and referral, and the balance is retained by Wing. The Advisory Fee is computed daily at the annual rate on the average daily net asset value of Eligible AUM and deducted monthly in arrears from the Managed Account by the custodian under Wing’s billing instructions. The Wrap Program fees consist of the Advisory Fee. The Wrap Program fee does not include the Membership Fee or Other Fees (defined below) that you may be charged as applicable and described below. The Wrap Program fee is deducted monthly, in arrears, by the custodian under Wing’s billing instructions. For the first billing period of our advisory relationship, the Wrap Program fee is calculated on a pro rata basis. In the event the Agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding portion of the fee is charged to the Member. Membership Fees The Membership Fee, as described above, is three hundred and ninety-nine dollars per year ($399/year). The Membership Fee is generally paid directly to Wing by the Member’s Partner Firm annually in advance, and the cost is not passed back to the Member. However, if a Member does not ultimately invest any assets in a Partner Firm model portfolio through Wing, the Membership Fee may be assessed by Wing to the Member annually in advance. Wing Membership gives you access to Wing’s automated

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financial planning and personal finance tools, including cash flow, budgeting, and debt reduction tools, financial education, and access to the Member’s Partner Firm model portfolios through the Wing App. Other Fees You understand that, in addition to equity securities of individual companies, Wing may invest in shares of money market funds, ETFs, and/or invest ETFs (or other securities used for hedging), for your Managed Account(s) in accordance with your Portfolio Plan. As a shareholder in these ETFs (and in any money market funds), you will bear a share of the management and other expenses of such ETFs as disclosed in each ETF’s prospectus. These expenses are charged by the ETF’s managers and service providers in the normal course of business and are reflected in the share value of the ETFs. The foregoing ETF expenses are separate and apart from your Wrap Program Fee. You will receive from us a notification when ETFs (or money market funds) are purchased for your Managed Account(s). You agree that it is your responsibility to read the applicable prospectuses in connection with your decision to invest. Additionally, you may incur certain other charges imposed by third party financial institutions. These additional costs may include but are not limited to custody fees, paper statement fees, bounced check fees, transfer taxes, wire transfer, electronic fund fees, and any fees or expenses charges by our participating Partners. All other fees referred to this Section are “Other Fees.” Wing does not receive any portion, either directly or indirectly, of these Other Fees.

D. Prepayment of Fees WFI collects Membership Fees in advance. Refunds on fees paid in advance but not yet earned will be refunded on a prorated basis.

E. Outside Compensation For the Sale of Securities to Clients Neither WFI nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds.

All guidance considers 1) Member stated and linked information, including life goals, 2) risk vs. return characteristics, interest rates, inflation, and other economic factors. Members must understand that diversification does not ensure profit or protect against a loss in a declining market. There is no guarantee that any particular asset allocation guidance or mix of funds will meet their investment objectives or provide a given level of income or return. WFI provides projections of investment outcomes in its planning guidance. Projections are estimates only and are based on certain economic factors, such as interest rates, inflation, a Member’s finances, and other pertinent financial factors. As estimates, they are imprecise and hypothetical in nature, do not reflect actual investment results, and are not guarantees of future results. They are subject to change over time with updates to our algorithms and underlying assumptions and may be materially impacted by a Member’s failure to update their personal and financial information. WFI does not recommend investment strategies for individual securities. As a financial planning platform, WFI provides strategies related to asset allocation, risk tolerance and diversification across all asset classes. How Managed Accounts are managed and monitored. Managed Accounts are invested in the Partner Firm’s model portfolio through an automated rebalancing tool made available by Wing’s custodian. Wing sets the rebalancing parameters — including drift tolerances, minimum trade sizes, rebalancing frequency, tax-aware settings for taxable accounts, and any tax-loss-harvesting settings — under a written rebalancing policy, and documents any change to those parameters. The rebalancing tool evaluates each account every business day and generates trades when an account’s drift exceeds a tolerance, when cash flows occur, or when a model changes, and Wing rebalances each account in any event at least quarterly. Each month Wing’s Chief Compliance Officer reviews every Managed Account against its assigned model portfolio and the Member’s current risk profile and reviews trading activity. No individual at Wing reviews Members’ planning guides or Managed Accounts on a personalized basis beyond these systematic reviews. Investing in securities involves the risk of loss that Members should be prepared to bear. While WFI provides recommendations based on analysis of Member needs, the performance of Managed Accounts depends on the model portfolios created by the Member’s Partner Firm and on Wing’s implementation of them. There is no guarantee that the Partner Firm’s model portfolios will achieve their objectives or expected returns. Additionally, our reliance on client-provided data and automated tools may result in recommendations that are not fully aligned with client needs if the data is incomplete or inaccurate.

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Limitations of algorithmic advice. Wing’s advice is generated by software from the information Members provide and authorize Wing to aggregate. The software applies fixed rules and models that cannot account for circumstances Members have not entered, may be affected by errors in data or in the software, and does not exercise individual judgment. Wing tests its risk questionnaire, its mapping of profiles to model portfolios, and its rebalancing configuration, and maintains change-management and client-impact procedures for defects; but Members should review their guidance, keep their information current, and contact Wing with questions.

Wing’s relationship with each Partner Firm is governed by written agreements under which the Partner Firm supplies its model portfolios, is paid a share of the Advisory Fee charged to Members it referred (see Item 5 and Item 14), and pays Wing subscription fees for its clients’ Wing memberships. Before entering into an agreement with a Partner Firm, Wing confirms that the Partner Firm is an investment adviser registered with the SEC or a state, reviews its Form ADV and disciplinary history, and obtains its model portfolios, target allocations, and rebalancing instructions in writing. Wing does not evaluate Partner Firms’ investment performance against one another or against benchmarks on behalf of Members, does not monitor Partner Firms on Members’ behalf other than to confirm receipt and accurate implementation of model portfolio changes, and does not replace a Member’s Partner Firm. If Wing terminated its relationship with a Partner Firm (for example, for regulatory or contractual reasons), Members referred by that Partner Firm would be notified in advance and would need to transfer or liquidate their Managed Accounts or, with their consent, transition to another arrangement. Conflicts of interest. Partner Firms are compensated for referring Members to Wing through the feesharing described in Item 14, which gives each Partner Firm an incentive to refer clients to Wing. The Chief Executive Officer of SignatureFD, LLC — a Partner Firm that has referred Members to Wing — holds an investment in Wing through a Simple Agreement for Future Equity (SAFE), which gives SignatureFD’s principal a financial interest in Wing’s growth. Because each Member’s investment options are limited to one Partner Firm’s model portfolios, Wing does not mitigate these conflicts by

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selecting among managers; Wing addresses them by disclosing them in this brochure, in Form CRS, in the Referral Disclosure Statement delivered to each referred prospect with the membership-code invitation at the time of referral and again in the onboarding disclosures the Member accepts in the Wing App, and by fixing the fee-sharing terms by written agreement.

B. Recommendations Involving Material Financial Interests WFI does not recommend that Members buy or sell any security in which a related person to WFI or WFI has a material financial interest.

C. Investing Personal Money in the Same Securities as Clients Wing’s related persons — its officers, certain contractors, and their family members — maintain accounts on the Wing platform. Those accounts are managed to the same Partner Firm model portfolios as Member accounts, except for a small number of legacy accounts invested in a model that is closed to new investors. All platform accounts, including related-person accounts, are traded through the same automated process in the same aggregated orders at the same prices, so related persons receive no execution advantage over Members. Supervised persons may also buy or sell securities, including the ETFs used in the model portfolios, in personal accounts outside the platform. Those transactions are subject to Wing’s Code of Ethics, which requires reporting of personal holdings and transactions, preclearance of initial public offerings and private placements, and review by the Chief Compliance Officer of personal trading against Member trading.

D. Trading Securities At/Around the Same Time as Clients’ Securities Related-person accounts on the platform are included in the same aggregated orders as Member accounts and receive the same average price; no account is traded ahead of another. Personal trades by supervised persons outside the platform are reported and reviewed under the Code of Ethics to detect trading ahead of, or against, Member accounts. The securities used in the model portfolios are broadly traded exchange-traded funds, and Wing’s orders are not of a size that would affect their prices.

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B. Aggregation of Orders Wing’s rebalancing system aggregates the orders generated for all accounts in a given security on a given day into a single block order, which is executed through Apex and allocated to the participating accounts pro rata at the average execution price, including fractional shares. Aggregation applies to all accounts on the platform, including accounts of Wing’s related persons. Because the platform enforces its minimum trade size on the block order, an individual account’s allocation may be smaller than that minimum.

B. Factors That Will Trigger a Non-Periodic Review of Client Accounts A non-periodic review of a Managed Account occurs when the monthly review identifies a deviation from the model or a mismatch between the assigned model and the Member’s profile, when a Partner Firm changes a model portfolio, when a Member records a material profile change, or when a defect in the software affecting advice is identified.

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C. Content and Frequency of Regular Reports Provided to Clients The planning guides generated by the tech enabled financial planning platform are dynamic, meaning they are constantly up to date and change pursuant to changes in the user’s lifestyle or financial situation. In addition to financial planning guides, the user will receive insights (similar to tips) that can help educate them on various financial options.

Partner Firms also pay Wing annual subscription fees for their clients’ Wing memberships. These arrangements create conflicts of interest: each Partner Firm has a financial incentive to refer its clients to Wing rather than to another adviser or platform, and, as described in Item 10.B, the principal of one Partner Firm holds an investment in Wing and so has a financial interest in Wing’s growth. A Partner Firm’s referral is a compensated endorsement under SEC Rule 206(4)-1 and is not based on an independent evaluation of Wing’s services. Wing addresses these conflicts through disclosure: each referred prospect receives a Referral Disclosure Statement at the time of the referral, with the invitation that carries the membership code, stating that the Partner Firm is not a client of Wing, that it is compensated for the referral, the material terms of that compensation, and the conflicts described above; the same statement is repeated in the onboarding disclosures the Member must accept in the Wing App before a Managed Account is opened.