Investing Online LLC

ITEM 5. FEES AND COMPENSATION

Investing Online charges clients a monthly fee. For clients with $1,200 or less in assets in their
Client Accounts, the Firm charges a fixed fee of $1 per month, which is assessed on the last day of
each month. For clients with more than $1,200 in their Client Accounts, the Firm charges an annual
asset-based fee of one percent (1%), which is prorated and charged based on the average daily
balance of their Client Accounts. In the event of termination, clients with $1,200 or less in their
Client Accounts are charged the fixed fee set forth above for the current month of service. Clients
with $1,200 or more are charged a prorated asset-based fee, calculated as of the date of termination.
The Firm may offer or negotiate to charge certain clients a lesser fee or exclude certain assets or
asset classes from the fee at its sole discretion. The Firm’s agreements and the client’s separate
agreement with the Custodian generally authorize the Firm to debit Client Accounts for the amount
of the fee and to directly remit the fee to the Firm.

Clients will incur brokerage and other transaction costs in addition to the fees they pay to Investing
Online. Investing Online does not charge these to clients and does not benefit directly or indirectly
from any such charges. These types of charges include, but are not limited to, wire transfer fees,
paper statement fees, and bounced check fees. The issuer of some of the securities purchased for
clients, such as mutual funds and ETFs, may charge product fees and expenses that affect clients.
For example, an ETF typically includes embedded expenses that may reduce the fund’s net asset
value, and therefore directly affect the fund’s performance and indirectly affect a client’s portfolio
performance or an index benchmark comparison. For additional information about the Firm’s
recommendation of broker-dealers for Client Accounts, see Item 12 of this brochure.

Clients may withdraw assets from Client Accounts at any time, subject to the usual and customary
securities settlement procedures. However, the withdrawal of assets may impair the achievement of
a client’s investment objectives. Clients are advised that when cash is withdrawn, they may be
subject to transaction fees, and/or tax ramifications. In the event of a withdrawal by the client, the
Firm may retain sufficient assets in the Client Account to cover the anticipated fee for the current
billing period.

ITEM 7. TYPES OF CLIENTS

The Firm generally provides investment advice to the following types of clients: individuals,
high-net worth individuals, and entities (such as corporations and limited liability companies).

The Firm does not impose requirements for opening or maintaining a Client Account, such as a
minimum account size.

ITEM 8. METHOD OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS

Investment Strategies and Methods of Analysis

As set forth above, Investing Online employs the Algorithm to recommend portfolios containing
treasuries, fixed income (debt) securities, certificates of deposits, and mutual funds and ETFs that
invest in the foregoing based on the information provided by clients in their Client Profiles.

Investing Online currently offers one or more models that seek to optimize yield and liquidity by
allocating among the above-mentioned securities. The strategies employed by the models are not
generally meant to be long-term in nature, and are aimed at achieving short-term and
medium-term client objectives on risk-adjusted returns.

Risk of Loss

Investing in securities involves risk of loss that clients should be prepared to bear. Investing
Online cannot guarantee any level of performance or that clients will not incur a loss of capital.

Securities portfolios recommended by the Firm will not be fully diversified. As such, securities
portfolios recommended by the Firm may not follow general movements in the market. The Firm
does not provide comprehensive financial or tax planning or legal advice, and clients are advised
and afforded the opportunity to seek the advice and counsel of the client’s own tax, financial, and
legal advisers. The Firm’s Services are not a complete investment program and clients should not
use them as the sole component of their investment plan. Clients must understand that investments
made via the Platform involve substantial risk and are subject to various market, currency,
economic, political, and business risks, and that those investment decisions and actions will not
always be profitable. Clients may lose some or all of the amount invested.

The following risks are not meant to be all inclusive, but should be considered prior to engaging
Investing Online for its advisory services.

Market Risk

The price of a security, mutual fund, exchange-traded fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, macroeconomic environment,
unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates,
regulatory changes, and domestic or foreign political, demographic, or social events. If a client has
a high allocation in a particular asset/class, it may negatively affect overall performance to the extent
that the asset/class underperforms relative to other market assets. Conversely, a low allocation to a
particular asset class that outperforms other asset/classes in a particular period may cause that
client’s portfolio to underperform relative to the overall market.

Investment Risk

There is no guarantee that Investing Online’s judgment or investment decisions about particular
securities and asset classes will necessarily produce the intended results. Such judgment may

prove to be incorrect, and a client might not achieve its investment objectives. In addition, it is
possible that clients or Investing Online itself may experience computer equipment failure, loss of
internet access, viruses, or other events that may impair access to Investing Online’s software based
financial service.

Volatility and Correlation Risk

Clients should be aware that the Firm’s asset selection process may be based in part on a careful
evaluation of past price performance and volatility to evaluate future probabilities. However, it is
possible that different or unrelated asset/classes may exhibit similar price changes in similar
directions which may adversely affect a client and may become more acute in times of market
upheaval or high volatility. Past performance is no guarantee of future results, and any historical
returns, expected returns, or probability projections may not reflect actual future performance.

Mutual Fund and ETF Risks

An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund
and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of
the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-
level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the
event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual
funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker
acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees,
redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day,
although the actual NAV fluctuates with intraday changes to the market value of the fund’s
holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during
periods of market volatility, which may, among other factors, lead to the mutual fund’s shares
trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and
transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their
most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and
more frequently for actively-managed ETFs. However, certain inefficiencies may cause the shares
to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active
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