Wallace: investment adviser

We do this by assisting you in purchasing groups of fractional shares of the publicly-traded companies, as well as holding cash in your brokerage account if you opt-in to do so. Wallace allows users to modify stock indexes and ETF holdings, or create their own custom index through modified direct indexing (the modified groups of stocks are called "strategies"). Users can choose to create their own strategy by picking multiple stocks and setting weights for each. These stocks are packaged together and treated as a single investment. Once the user confirms the strategy and initiates the trade, the Platform allocates and executes the order flow. Users can rebalance or modify strategies at any time. Users can also choose a number of common indexes to modify, including top S&P, top NASDAQ, and sector/industry indexes. Wallace also has an AI tool built in to help facilitate modified direct indexing, although the tool does not provide any advice. Users can use our tool to research holdings of ETFs, sectors/industries, market indexes, or general market themes based on parameters. Users can use this information to create their strategies. We also have a tool to automatically weight the holdings of a strategy by fundamental data, such as market capitalization or P/E ratio. Users are not asked to complete a risk profile to use the Platform. Use of the Platform is selfdirected; thus, users may make their own choices regarding risk tolerance, diversification, time horizons, and investment focus. Wallace provides an AI tool to help facilitate investment personalization and to research investment structures that best align with the users’ individual goals. This AI tool does not provide financial advice. The Platform also provides basic information such as fundamental and market data about individual stocks and ETFs which users can reference while making investment decisions. We have established a relationship with Alpaca Securities LLC (“Alpaca”), a FINRA registered broker-dealer (the “Broker”). You must open a brokerage account with the Broker to use the Platform. Wallace does not have discretionary trading authority and does not trade user accounts. Our platform provides investment structuring and provides the ability for the user to initiate trades for their chosen securities. The Broker will provide custody, clearing, and settlement services for your account. All account opening functionalities, including identity verification and approval, are handled digitally by Broker. The Broker provides all brokerage services to you; therefore, you must agree to the terms of the Broker’s “Customer Account Agreement” to establish an account.

Alpaca offers other brokerage services, including margin lending, securities lending, and cash sweep services. See Item 12, Brokerage Practices, for a discussion on how we have selected Alpaca as the Broker. The securities available are a limited universe of publicly-traded stocks, as defined by the Broker, which is subject to change. The Platform provides access to this stock universe. All users have access to the same universe of securities. You can purchase, sell, or restructure a group of securities on a daily basis. Other than facilitating and structuring investments, we do not tailor our services to your individual financial circumstances. Users have the ability to impose restrictions on the strategies they choose or build. We provide investment advice regarding structuring groups of securities, but only in the form of algorithmic outputs based on market data. We do not trade accounts for clients. We provide recommendations for investment strategy construction and rebalancing based on our algorithms, and if the user chooses to accept the recommendations, the user initiates the trade through our mobile application to their account at the Broker. Only individuals will be permitted to establish accounts with the Broker, which shall be in their own name; accounts for legal entities are not supported in the Wallace Platform at this time. You will be required to complete all applicable Broker forms and agreements, and authorize the Broker to deduct our fees from your accounts pursuant to your agreements with us. The Broker reserves the right to reject any account application for any reason whatsoever. The Broker has the sole discretion to determine the universe of available securities, and to add or remove any security from the universe at any time. If a security is removed from the universe, the Broker will limit transactions in that particular security to the liquidation of positions only. Wallace does not provide portfolio management services to wrap fee programs. Wallace does not provide “continuous and regular supervisory or management services” to user accounts and therefore does not have regulatory assets under management to report.”

Client is responsible for all custodial and securities execution fees charged by the Broker. The Advisor’s fee is separate and distinct from the custodian and execution fees.

Neither Wallace nor its supervised persons accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.

Technical analysis is a method of evaluating securities by relying on the assumption that market data, such as charts of price, volume and open interest can help predict future (usually short-term) market trends. Technical analysis assumes that market psychology influences trading in a way that enables predicting when a stock will rise or fall. Sentiment analysis involves evaluating public and private sentiment around stocks, sectors, and industries. Sentiment analysis may include analyst scoring, thematic comparison, third-party ratings, and additional public data. The objective of sentiment analysis is to aid the user in structuring investments alongside additional types of analysis. Sentiment analysis relies on market actions and reactions, and aims to capitalize on perceived stock values. Cyclical analysis of economic cycles is used to determine how these cycles affect the returns of an investment, an asset class or an individual company’s profits. Cyclical risks exist because the broad economy has been shown to move in cycles, from periods of peak performance followed by a downturn, then a trough of low activity. Between the peak and trough of a business or other economic cycle, investments may fall in value to reflect the uncertainty surrounding future returns as compared with the recent past.

Users need to be aware that investing in securities involves risk of loss that clients need to be prepared to bear. The methods of analysis and investment strategies followed by the Advisor are utilized across the Platform and available to all users. Users have discretion to utilize differing methods of analysis as they see fit to structure and pursue their investing goals. One method of analysis or investment strategy is not more significant than the other and users may utilize different types of analysis methods. Investing includes the risk that the value of an investment can be negatively affected by factors specifically related to the investment (e.g., capability of management, competition, new inventions by other companies, lawsuits against the company, labor issues, patent expiration, etc.), or to factors related to investing and the markets in general (e.g., the economy, wars, civil unrest or terrorism around the world, concern about oil prices or unemployment, etc.). Risks of all types of analysis may include risks that market actions, natural disasters, government actions, world political events or other events not directly related to the price or valuation of a specific company’s fundamental analysis can adversely impact the stock price of a company causing an investment structure containing that security to lose value. Risks may also include that the historical data and projections on which the analysis is performed may not continue to be relevant to the operations of a company going forward, or that management changes or the business direction of management of the company may not permit the company to continue to produce metrics that are consistent with the prior company data utilized in the fundamental analysis, which may negatively affect the estimated valuation of the company. The primary risks in technical analysis are that the factors used to analyze the price, trends and volatility of a security may not be replicated, or the outcomes of such analysis will not be the same as in past periods where similar combinations existed. Because of the reliance on trends, technical analysis can signal buying at market peaks and selling at market troughs. Sentiment analysis carries inherent risk of third-party bias as it incorporates analyst recommendations, outside analysis, discussion volume, market irrationality, and “hype” regarding a company, sector, industry, or general market movements. Sentiment analysis is theoretical regarding retail and institutional investments and resulting market movements. Thus, this type of analysis is not directly controlled by fundamental or other types of analysis. This type of analysis may be aimed at thematic or trend predictions. The difficulty of sentiment analysis is quantifying subjective intent into actionable investment strategies and structures. This type of analysis should not be relied upon for actions such as price targeting or company valuation. In cyclical analysis, economic or business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. Also, the lengths of the economic cycles may be difficult to predict with accuracy. Therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends.

All investments involve some degree of risk. In finance, risk refers to the degree of uncertainty and/or potential financial loss inherent in an investment decision. In general, as investment risks rise, investors seek higher returns to compensate themselves for taking such risks. Every saving and investment product have different risks and returns. Differences include how readily investors can get their money when they need it, how fast their money will grow, and how safe their money will be. The Wallace Platform primarily recommends that clients invest in exchange-listed equity securities and market index funds comprised of exchange-listed equities. The material risks of equities and index funds are: Risks of Investing in Index Funds: Investing in index funds is often viewed as a simple and low-cost way to gain broad market exposure, but it carries several important risks. The most fundamental is market risk: because index funds track the overall market, they rise and fall with it. During market downturns or crashes, index investors experience the full impact of losses, as these funds offer no built-in protection or ability to shift into safer assets. Another key risk is the inability to outperform the market. Index investing is designed to deliver average market returns, not above-average ones. While this approach avoids the risk of poor stock selection, it also means investors will not benefit disproportionately from exceptional companies until those firms become large enough to significantly influence the index. Over time, this limits upside relative to skilled active strategies, where such skill exists. Although indexes appear diversified, many are highly concentrated. Large-cap indexes are often dominated by a small number of companies or sectors, such as technology. This concentration can expose investors to sector-specific downturns, even when holding hundreds of stocks. Similarly, country-specific or thematic indexes may rely heavily on a narrow portion of the economy, increasing vulnerability to structural changes. Valuation risk is another concern, as index funds buy stocks regardless of whether they are cheap or expensive. When markets are overvalued, investors may face long periods of low or even negative returns. Historical examples show that buying into an index at peak valuations can require many years just to recover nominal losses, let alone inflation-adjusted ones. There is also growing concern about passive investing itself contributing to distortions in the market. As more capital flows into index funds, the largest companies receive the greatest inflows simply because of their size, not necessarily their fundamentals. This dynamic can push prices higher and potentially create bubbles, while smaller companies receive less attention and capital. Costs, though typically low, are not zero. Expense ratios, tracking errors, and taxes can all reduce returns over time, especially in taxable accounts. Even small differences in cost can compound significantly over long investment horizons. In addition, index funds lack flexibility; they cannot move to cash, reduce exposure to risky sectors, or adapt to changing economic conditions, leaving investors fully exposed at all times.

Indexes are also sensitive to inflation and interest rate changes. Rising rates can compress stock valuations, particularly in growth-heavy indexes, while high inflation can erode real returns. Finally, behavioral risk plays a major role. Index investing requires discipline, and many investors struggle to stay invested during market downturns or avoid buying after extended bull markets. Poor timing driven by emotion can undermine the long-term benefits of indexing. In summary, while index investing is efficient, diversified, and well-suited for long-term investors, it is not risk-free. Understanding these risks is essential to using index funds effectively and aligning them with appropriate time horizons, risk tolerance, and financial goals. Risks of Investing in Stocks: All investments involve some degree of risk. In finance, risk refers to the degree of uncertainty and/or potential financial loss inherent in an investment decision. In general, as investment risks rise, investors seek higher returns to compensate themselves for taking such risks. Every saving and investment product has different risks and returns. Differences include how readily investors can get their money when they need it, how fast their money will grow, and how safe their money will be. Business Risk With a stock, you are purchasing a piece of ownership in a company. With a bond, you are loaning money to a company. Returns from both of these investments require that the company stays in business. If a company goes bankrupt and its assets are liquidated, common stockholders are the last in line to share in the proceeds. If there are assets, the company’s bondholders will be paid first, then holders of preferred stock. If you are a common stockholder, you get whatever is left, which may be nothing. Volatility Risk Even when companies aren’t in danger of failing, their stock price may fluctuate up or down. Large company stocks as a group, for example, have lost money on average about one out of every three years. Market fluctuations can be unnerving to some investors. A stock’s price can be affected by factors inside the company, such as a faulty product, or by events the company has no control over, such as political or market events. Liquidity Risk This refers to the risk that investors won’t find a market for their securities, potentially preventing them from buying or selling when they want. This can be the case with the more complicated investment products. Risks that apply to Equity Strategies, including ETFs: • Management Risk: Due to its passive and defensive management, a strategy could underperform other strategies with similar investment objectives and/or focusses. •

Allocation Risk: A strategy may use an asset allocation strategy in pursuit of its investment objective. There is a risk that a strategy’s allocation among asset classes or investments will cause a strategy to lose value or cause it to underperform other strategies with a similar

investment objective and/or strategy, or that the investments themselves will not produce the returns expected. •

Sector/Industry Risk: The risk that the strategy’s concentration in equities in a specific sector or industry will cause the strategy to be more exposed to the price movements in and developments affecting that sector.

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Market and Timing Risk: Prices of securities may become more volatile due to general market conditions that are not specifically related to a particular company, such as adverse economic conditions or outlooks, adverse investor sentiment, changes in the outlook for corporate earnings, or changes in interest rates.

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Event Risk: The possibility that an unforeseen event will negatively affect a company or industry, and thus, increase the volatility of the security.

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Liquidity Risk: The risk that exists when a security’s limited marketability prevents it from being bought or sold quickly enough to avoid or minimize a loss.

Reliance on Algorithms: We use proprietary algorithms to help you analyze and structure your investment strategies. We cannot guarantee that the algorithms used will indeed function as intended. The Wallace Platform has inherent limitations, including the possibility of human error in the design, data input or implementation process. The risk of errors, malfunctions, and anomalies is inherent in each component of the programming process, how those components function together, and how the program absorbs data points provided by you and interpreted by the Wallace Platform.

investment trust, private investment company or “hedge fund” and offshore fund), other investment advisor or financial planner, futures commission merchant, commodity pool operator, or commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer or sponsor of syndicator of limited partnerships.

Although there is no affiliation with a broker-dealer, as disclosed in Item 5, Wallace has a business relationship with Alpaca Securities, a FINRA registered broker-dealer, where users of the Wallace Platform will open accounts and conduct trading at Alpaca. Item 12 discusses the evaluation of Alpaca concerning best execution. Wallace does not recommend or select other investment advisors for clients.

Wallace will provide a copy of the Code of Ethics to any user or prospective user upon request. Wallace does not recommend to Platform users securities in which the firm or a related person has a material financial interest. Wallace and/or its investment advisor representatives may from time to time purchase or sell products that they may recommend to users. This practice creates conflicts of interest in that personnel of Wallace can take advantage of the advance knowledge of firm securities trading and trade their personal accounts ahead of the user trades or recommend trades in user accounts that may affect the price of the securities owned by the Investment Advisor Representatives. To mitigate these conflicts, Wallace has adopted a Code of Ethics as noted above. Wallace’s Code of Ethics is available upon request. Finally, supervised persons of registered investment advisors are fiduciaries by law and are required to put the client’s interest before those of the firm and themselves. Wallace requires that its investment advisor representatives follow its basic policies and ethical standards as set forth in its Code of Ethics. Investment Advisor Representatives of Wallace may trade for their own accounts securities that are being traded by users of the Platform at or about the same time. To mitigate the conflict of interest in such circumstances, Wallace’s policy is to provide recommendations on specific securities to Platform users prior to the trading of their own accounts. The Chief Compliance Officer examines personal trading activities of Wallace’s personnel to verify compliance with this policy.

The firm seeks to obtain the most favorable net results for clients’ price, execution quality, services and commissions. Although the firm seeks competitive commission rates, it may pay commissions on behalf of clients which may be higher than those available from other brokers in order to receive other services. The firm may enter into such transactions so long as it determines in good faith that the amount of commission paid was reasonable in relation to the value of the brokerage and research services provided by the broker. The services that may be considered in this determination of reasonableness may include (1) advice, either directly or through publications or writing, as to the value of securities, the advisability of investing in, purchasing or selling securities, and the availability of securities or purchasers or sellers of securities; (2) analysis and reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy, and the performance of accounts; or (3) effecting securities transactions and performing functions incidental thereto. Such research furnished by broker-dealers may be used to service any or all of Wallace’s users and may be used in connection with accounts other than those that pay commissions to the broker-dealers providing the research. In particular, third-party research provided by broker-dealers may be used to benefit all of the firm’s users. This creates a conflict of interest in that the firm has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the users’ interest in receiving most favorable execution. Benefits received may be used as soft dollars provided that: • The service is primarily for the benefit of Wallace’s clients • The commission rates are competitive with rates charged by comparable broker-dealers; and • Wallace does not guarantee a minimum amount of commissions to any broker-dealer. Wallace does not receive client referrals from any broker-dealer or third party as a result of the firm selecting or recommending that broker-dealer to clients. Wallace requires that all users use a particular broker-dealer for execution and/or custodial services. The broker-dealer is recommended based on criteria such as, but not limited to, reasonableness of commissions charged to the user, tools and services made available to the user and the Advisor, and convenience of access to the account trading and reporting. Wallace does not trade user accounts.

As an investment advisory firm, Wallace has a fiduciary duty to seek best execution for user transactions. While best execution is difficult to define and challenging to measure, there is some consensus that it does not solely mean the achievement of the best price on a given transaction. Rather, it appears to be a collective consideration of factors concerning the trade in question. Such factors include the security being traded, the price of the trade, the speed of the execution, apparent conditions in the market, and the specific needs of the user. Although Wallace does not place orders for user accounts, it recognizes the primary objective of the users for the purchase and sale of securities is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. Wallace’s users may not necessarily pay the lowest commission or commission equivalent as specific transactions may involve specialized services on the part of the broker. Wallace does not permit clients to direct brokerage. Wallace does not aggregate trades because it does not place trades for the users of the Platform. Each user initiates their own trades.