Wealthyx LLC

Item 5 - Fees and Compensation
Overview
WealthyX charges an advisory fee for the investment advisory services provided through its
Internet Adviser platform. This section describes WealthyX's advisory fee, how it is calculated and
collected, and other costs Clients may incur in connection with their 529 plan accounts. Clients
should read this section carefully and review the applicable Program Description provided by their
assigned program manager at account opening to fully understand all costs associated with their
account.

WealthyX Advisory Fee
WealthyX charges an advisory fee of up to 10 basis points (0.10%) annually on assets under
management. WealthyX's advisory fee is consistent across all program managers available
through the WealthyX platform - Clients are charged the same advisory fee regardless of which
program manager they are assigned to.

Fee Calculation
WealthyX's advisory fee is calculated based on the average daily balance of the Client's 529 plan
account during each calendar month. The monthly fee is calculated by applying an annual rate of
up to 10 basis points to the average daily balance and dividing by twelve to arrive at the applicable
monthly fee amount. For illustrative purposes, a Client with an average daily balance of $10,000
during a given month would incur a monthly advisory fee of approximately $0.83, representing
one twelfth of the annual 10 basis point fee.

Fee Collection
WealthyX's advisory fee is deducted directly from the Client's 529 plan account on a monthly
basis. Clients should be aware that direct deduction of the advisory fee from their account will
reduce the overall value of their account over time, which may affect the total amount available
for the Beneficiary's educational expenses.

Fee Billing and Timing
WealthyX's advisory fee is charged monthly in arrears, based on the average daily balance of the
Client's account during the preceding calendar month. Clients will be able to review their advisory
fee charges through their account statements provided by their assigned program manager on at
least a quarterly basis.

Termination and Refund Policy
Clients may terminate their Investment Advisory Agreement with WealthyX at any time by
providing written notice through the WealthyX platform. In the event of termination, WealthyX will
provide a pro-rated refund of any advisory fees charged for the portion of the month following the
effective date of termination. Because WealthyX's advisory fee is charged monthly in arrears
based on the average daily balance, the pro-rated refund will reflect only those days in the final
month during which the Client's account was no longer under the advisory relationship. Refunds

WealthyX LLC | Form ADV Part 2A Brochure

will be credited to the Client's account within a reasonable time following the effective date of
termination.

Third Party Fees and Costs
In addition to WealthyX's advisory fee, Clients will incur fees and costs charged by their assigned
program manager that are separate from and in addition to WealthyX's advisory fee. These third-
party costs are not charged by WealthyX and WealthyX does not receive any portion of these
fees. Third party costs may include program management fees charged by the applicable program
manager for administration of the state 529 plan, underlying fund expense ratios charged by the
target date funds within the Client's selected portfolio, and any other fees or costs disclosed in
the applicable Program Description provided to the Client at account opening.
These third party costs vary across program managers and across individual target date fund
portfolios within each program. WealthyX's program manager assignment process takes total
costs to the Client into account — including both WealthyX's advisory fee and applicable third-
party costs — as part of its fiduciary obligation to act in each Client's best interest. Clients are
strongly encouraged to review their applicable Program Description carefully for a complete and
detailed breakdown of all costs associated with their specific program and portfolio selection.

Total Cost Illustration
To assist Clients in understanding the total cost of their investment, the following illustrates how
WealthyX's advisory fee combines with third party program costs. For example, if a Client's
assigned program charges a total program and fund expense ratio of 0.25% annually, and
WealthyX's advisory fee is 0.10% annually, the Client's total annual cost would be approximately
0.35% of assets under management. Actual costs will vary depending on the program manager
assigned and the specific target date fund portfolio selected. Clients should refer to their
applicable Program Description for specific cost information applicable to their account.

Platform Services Fee
Clients should also be aware that WealthyX pays a platform services fee to Fates Financial, LLC
equal to 90% of WealthyX's gross advisory revenues in exchange for website hosting, technology
infrastructure, and client acquisition services. This fee is paid by WealthyX from its advisory
revenues and does not represent an additional cost to the Client — the advisory fee of up to 10
basis points on assets under management is the total amount charged to the Client by WealthyX
regardless of the platform services fee arrangement. The platform services fee arrangement and
associated conflicts of interest are described in detail in Items 10 and 14 of this Brochure.

Fee Negotiations
WealthyX's advisory fee of up to 10 basis points is the standard fee applicable to all Clients.
WealthyX does not currently negotiate individualized fee arrangements with Clients.

Anticipated Expansion — Retirement Planning Products
When WealthyX establishes its anticipated affiliated broker-dealer relationship and expands its
platform to include retirement planning products, the fees applicable to those products may differ
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Item 7 — Account Requirements and Types of Clients
Overview
WealthyX currently provides investment advisory services to individual retail investors, trusts, and
custodial accounts who open 529 college savings plan accounts through the WealthyX Internet
Adviser platform. WealthyX anticipates expanding its client base in the near future to include
individuals, trusts, and custodial accounts seeking retirement planning products and investment
opportunities through its anticipated affiliated broker-dealer relationship. When that expansion

WealthyX LLC | Form ADV Part 2A Brochure

occurs, this section will be updated by amendment to reflect the full scope of WealthyX's
expanded client relationships.

Current Client Base — 529 College Savings Plan Program
WealthyX's current Clients are individual retail investors — typically parents, grandparents,
trustees, or custodians — who open 529 college savings plan accounts for the benefit of a
prospective student (the "Beneficiary"). WealthyX currently serves the following types of clients:
Individual Account Holders — typically a parent or grandparent opening a 529 account in their
own name for the benefit of a Beneficiary. The individual account holder is the Client for purposes
of the advisory relationship with WealthyX.
Trusts — WealthyX accepts accounts opened by trustees on behalf of a trust where the trust is
the account holder for the benefit of a Beneficiary. The trustee acts as the Client representative
for purposes of the advisory relationship, and WealthyX's recommendations are made to the
trustee in their capacity as account holder. Trustees opening accounts on behalf of a trust should
ensure that the trust document permits investment in 529 college savings plan accounts and
should consult with a qualified legal adviser regarding any applicable trust restrictions before
opening an account.
Custodial Accounts — WealthyX accepts custodial accounts opened under the Uniform Transfers
to Minors Act ("UTMA") or the Uniform Gifts to Minors Act ("UGMA") where a custodian opens
and manages a 529 account on behalf of a minor Beneficiary. The custodian acts as the Client
representative for purposes of the advisory relationship with WealthyX. Custodians should be
aware that UTMA and UGMA custodial accounts are subject to specific legal requirements
regarding the management of assets on behalf of minors, and should consult with a qualified legal
adviser regarding their obligations as custodian before opening an account.
In all cases, the Beneficiary is the individual for whose educational benefit the account is
established and is not a party to the advisory relationship with WealthyX regardless of the account
type.
WealthyX does not currently provide advisory services to the following types of clients:
   •   Institutional investors
   •   Corporations or business entities
   •   Pension or profit sharing plans
   •   Foundations or endowments
   •   Non-United States residents

Eligibility Requirements
To open an account with WealthyX, prospective Clients must meet the following eligibility
requirements: Clients must be United States residents with the legal capacity to enter into an
Investment Advisory Agreement with WealthyX. In the case of trustees and custodians, Clients
must have the legal authority and appropriate documentation to open and manage a 529 college
savings plan account on behalf of the trust or minor Beneficiary. Clients must have access to the
internet and a valid email address, as WealthyX operates exclusively as an internet-based adviser
and all account opening, questionnaire completion, portfolio selection, and ongoing account
communications are conducted through the WealthyX platform.
State residency is a relevant consideration in the account opening process but is not a restrictive
eligibility requirement. WealthyX works with multiple program managers each operating under a
separate state's 529 plan, and no program manager imposes a strict state residency requirement
— Clients may be assigned to any available program regardless of their state of residency.

WealthyX LLC | Form ADV Part 2A Brochure

However, many states offer income tax deductions or credits to residents who invest in their home
state's 529 plan. WealthyX evaluates state residency as part of its fiduciary program manager
assignment process, taking into account the potential tax benefits of a Client's home state plan
alongside total program costs in determining the most appropriate program manager for each
Client. Clients who are assigned to an out-of-state plan should be aware that they may forgo state
income tax benefits available for contributions to their home state's plan. Clients are encouraged
to consult with a qualified tax adviser regarding the state tax implications of their program manager
assignment before making a final portfolio selection.

Account Opening Process
To open an account with WealthyX, prospective Clients must complete the following steps through
the WealthyX Internet Adviser platform:
    • Complete the online questionnaire providing information regarding the Beneficiary's age
       and anticipated undergraduate college enrollment date and the Client's state of
       residency
    • Review the program manager assignment and portfolio recommendation presented by
       WealthyX based on the questionnaire responses
    • Select a target date fund portfolio from those available through the WealthyX platform
       under their assigned program manager
    • Execute the WealthyX Investment Advisory Agreement
    • Review and acknowledge receipt of WealthyX's Form ADV Part 2A Brochure, Form ADV
       Part 2B Brochure Supplement, and Form CRS
    • Review and acknowledge receipt of the applicable Program Description provided by the
       assigned program manager
    • Provide any additional information required by the assigned program manager in
       connection with account opening under the applicable state 529 plan
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