Conversation Starters

1. Given my financial situation, should I choose an investment advisory service? Why or why not?

You should consider an investment advisory service like Spendvest if you are looking for a lowcost, automated way to invest without managing your own portfolio. We build and manage portfolios for you based on information you provide, including your financial situation, risk tolerance, and spending patterns. This may be appropriate if you are comfortable using a technologydriven service and do not need ongoing personalized advice from a financial professional.

Spendvest may not be appropriate if you want customized financial planning, frequent interaction with a human advisor, or the ability to tailor individual investments, because our service is automated and standardized across clients.

2. How will you choose investments to recommend to me?

We use an automated algorithm to select and manage your investments. The algorithm considers information you provide, including your financial goals, risk tolerance, and certain behavioral data, such as spending patterns. Based on this information, we construct a diversified portfolio, primarily using equity securities or an exchangetraded funds (ETF).

Our system monitors and adjusts your portfolio over time to maintain your target allocation. While we oversee and maintain the system, investment decisions are made by the algorithm, not by a human advisor on an individualized basis.

3. What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean?

Spendvest is an SEC registered investment adviser, which means we are regulated under the Investment Advisers Act of 1940 and must act as a fiduciary, placing your interests ahead of our own.

The individuals responsible for overseeing our investment process and operations have licenses, certifications, and professional designations described in their Form ADV Part 2B brochure supplements. These credentials generally indicate that an individual has completed certain education, passed exams, and met ongoing professional standards in areas such as investment management or financial planning.

4. Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

Spendvest charges a subscription fee (monthly or annual), rather than a percentage of assets under management. Because our fee is not based on the size of your account, the cost as a percentage of your investment will be higher for smaller account balances and lower for larger balances.

For example, if you invest $10,000, the full $10,000 will generally be invested in your account. However, you will separately pay the subscription fee. If your annual fee is $89.99 that represents approximately .9% of a $10,000 account. In addition, you will incur indirect costs, such as ETF expense ratios.

Over time, these fees and costs will reduce your investment returns, particularly if your account balance is relatively small.

5. How might your conflicts of interest affect me, and how will you address them?

We have conflicts of interest because we are compensated in ways that could influence our recommendations or services. For example:

• We charge a subscription fee, which creates an incentive for us to encourage you to maintain an account, regardless of size.
• We require you to use a specific custodian, which limits your ability to compare alternatives.
• We receive a portion of the interest earned on cash balances, which creates an incentive for us to include or maintain cash in your account.

We address these conflicts by fully disclosing them, applying fiduciary standards, and designing our program to treat clients consistently, rather than making individualized recommendations that could be influenced by compensation.

6. How does your firm benefit from my cash being held in my account, and are there other options that could pay me more interest?

When you hold uninvested cash in your account, the custodian pays interest on those balances. You receive a portion of that interest, and Spendvest receives a portion as well.

Because we receive part of the interest, we have a financial incentive for you to maintain cash in your account or use this custodian’s cash program, rather than alternatives that could pay you more interest.

Yes, there may be other custodians, sweep programs, or cash management options that pay higher interest rates, but those options may not be available through our platform.

7. As a financial professional, do you have any disciplinary history? For what type of conduct?

We do not have disciplinary history to report.

8. Who is my primary contact person? Is he or she a representative of an investment adviser or a brokerdealer? Who can I talk to if I have concerns about how this person is treating me?

Because Spendvest provides automated investment advisory services, you will not have a dedicated financial advisor assigned to your account. Instead, you may contact our customer support team, which assists with account and service questions but does not provide personalized investment advice.

Spendvest is an investment adviser, not a brokerdealer. If you have concerns about your account or how you are being treated, you may contact us directly using the contact information on our website or by emailing us at support@spendvest.com. You may also contact the SEC or visit Investor.gov for additional information about your rights as an investor.