Kraken Adviser LLC

Item 5:    Fees and Compensation
The Adviser does not charge an advisory fee in connection with its services. Notwithstanding
the foregoing, the Adviser receives an indirect economic benefit for providing advisory services
based on its affiliates’ receipt of compensation from Clients as described below.
When Clients invest in a Bundle, Clients will incur certain costs in relation to the transaction,
including costs payable to Kraken Securities and Alpaca in connection with securities
transactions. Additional fees may apply depending on the method of funding the Bundle
investment. Kraken Securities will also earn revenue from the equity securities traded and held,
such as payment for order flow and fully paid stock lending. The Adviser indirectly benefits from
its affiliates’ receipt of these revenues.
Clients will also incur certain costs payable to third parties unaffiliated with the Adviser, such as
Alpaca. The Adviser does not charge these to Clients and does not benefit directly from any
such charges of such third parties. These 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 ETFs, may charge product fees and expenses that affect Clients.
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.

Clients may invest in Bundles using USD. Upon a Client’s election to invest in a Bundle, the
Adviser instructs Kraken Securities to effect the security purchase. After their initial deposit,
Clients may make additional investments in a Bundle or in portfolios recommended or
constructed by the Portfolio Agent through recurring or ad hoc contributions, subject to the
Adviser’s right to terminate its services.
Clients cannot hold excess funds in their Investment Account. Rather, the Investment Account is
composed of the securities purchased as part of a Bundle or pursuant to the Portfolio Agent.
The Adviser andKraken Securitiesmay offer discounted rates to Clients in connection with their
services with respect to Clients’ Investment Accounts at their sole discretion. For example,
Kraken+ subscribers may receive discounted fees for buying and selling Bundles and for
transactions effected through the Portfolio Agent.

Item 7:    Types of Clients
The Adviser generally provides investment advice to individuals who are eligible to open a
Crypto Account with Payward Interactive and a Brokerage Account with Kraken Securities, and
who opt to invest in a Bundle or to use the Portfolio Agent through the Platform. This includes
individuals, including high-net-worth individuals, but not corporations.
The Adviser does not maintain requirements for opening or maintaining an Investment Account,
such as a minimum account size. However, when investing in a Bundle or in a portfolio
managed through the Portfolio Agent, the Client must invest an amount sufficient to satisfy the
minimum purchase size of each constituent security ($1 notional).