Libretto LLC (“Libretto” or the “Firm”) is a software as a service (“SAAS”) company focused on delivering digital advice systems and resources to aid other third-party advisors (each an “Advisor,” and collectively, “Advisors”) in managing complex wealth. Libretto does not provide services directly to retail clients. Rather, it provides a suite of services including planning, investment advice and wealth management, among other services, directly to Advisors, who in turn utilize Libretto’s platform to service their clients. Libretto provides its investment advice exclusively through its proprietary interactive website. Libretto is currently registered with the U.S. Securities and Exchange Commission as an internet investment adviser with its principal place of business located in Los Angeles, California. Libretto began conducting its business in 2015 and became a registered investment advisor in 2018. Libretto is controlled by its majority owner and Chief Executive Officer, Jeffery Coyle. Trevor Coyle serves as Chief Compliance Officer of the firm. Financial Strategy System Libretto system Libretto provides advice tools via its website. The scope of these software tools includes financial planning, portfolio construction and wealth management. Financial Planning The Libretto Financial Planning system employs a priorities-driven planning methodology that informs both portfolio construction and wealth management directives. Given a set of client priorities (annual spending, travel budget, second home, college funding for children, etc.) and financial resources (social security & pensions, liquid assets, semi- liquid assets, illiquid assets, etc.), the Financial Planning system provides illustrative calculations comparing estimated needs with resources. On this basis, the Financial Planning system provides context to the Advisor that can be used to evaluate the sufficiency of financial resources in meeting stated client priorities and objectives. The financial plans are presented by the Advisors to their end clients. Financial Planning recommendations from Libretto’s Financial Planning system are not limited to any specific product or service offered by a registered investment adviser, broker-dealer or insurance company. Portfolio Construction Libretto’s portfolio construction process is comprised of a household-level Asset Allocation system and account-level Trading tools. Libretto – Disclosure Brochure dated March 05, 2024 5 The Libretto Asset Allocation system is a liabilities-driven methodology that maps priorities to asset allocation targets. Advisors may customize asset allocation targets to tailor recommendations to clients. The Libretto Trading system provides Advisors with tools that enable them to set account- level asset allocation targets, which ultimately may be used to inform potential trades. The Libretto Trading system does not offer any recommendations with respect to the buying and selling of specific financial products; rather, it provides tools that allow Advisors to fully customize targets to reflect the needs of their clients. As detailed in Item 5 Fees and Compensation, the Trading system is available under certain packages but not others. Wealth Management Libretto’s Financial Planning system establishes an initial draft set of wealth management directives that may be suitable to enhance the client’s overall financial strategy. These directives may include estate, tax, insurance and other non-financial products or services such as health care advocacy or trustee services. The directives serve as an initial draft to enable Advisors to tailor a final set of wealth management products and services to the unique needs and circumstances of each end client. Complementary systems Certain technology solutions are outside of the scope of Libretto’s tools but relate to the ultimate implementation of Libretto solutions. Systems that provide such services are complementary to Libretto’s delivery. They include, but are not limited to, data aggregation, portfolio accounting and portfolio rebalancing. Data Aggregation and Portfolio Accounting Advisor firms manage client data within their respective systems and may input data into the Libretto system manually or through established feeds with third party providers. Libretto’s system imports client-level portfolio data from Advisors’ data systems and/or custodial feeds. Advisors are responsible for the integrity and reconciliation of client data. This data is captured and organized within Libretto’s system to inform planning, portfolio construction, reporting and support trading. Portfolio Rebalancing Advisor firms may choose to use systems that assist in performing portfolio monitoring, rebalancing and trade execution. While Libretto does not provide portfolio rebalancing services, Libretto’s portfolio construction outputs may be used to inform solutions that are ultimately implemented in external portfolio rebalancing systems. Advisors are responsible for operating and maintaining their respective portfolio rebalancing systems. Libretto – Disclosure Brochure dated March 05, 2024 6 Delivery Augmentation In addition to software tools, Libretto provides delivery augmentation services that are intended to enhance Advisors’ client deliveries. Libretto’s delivery augmentation includes webinar series, white label materials and other value-add

resources, such as templates and diagnostics. These materials cover topics related to financial structure, portfolio methods and wealth management. The depth of materials available will differ across the various delivery packages referenced under Item 5 Fees and Compensation. Professional Development To streamline adoption, Libretto provides professional training resources intended to expand the sophistication of a firm’s full advisory team. These resources include: Training sessions – Libretto hosts training sessions on core Libretto methodology and system use. These sessions are delivered periodically, and they accelerate the learning process for new users while refreshing knowledge for more experienced users. Online training resources – Libretto delivers online training resources to promote ongoing learning and enable quick access to detailed answers on methodology and system implementation. These resources include videos, an on-demand encyclopedia and intuitive guides, among others. Implementation Support To complement its software delivery, Libretto provides system implementation support. During a new firm’s onboarding process, Libretto helps refine Libretto-related data management processes, which typically includes instruction on configuring an integration or defining best practices for uploads. Libretto also assists a new firm’s advisory team in creating a few initial client case studies. Libretto’s client service team is available on an ongoing basis to answer questions related to Libretto’s software tools. Change Management Consulting Libretto may be engaged, as part of existing SAAS agreement or on a standalone basis, to provide consulting on business processes, wealth strategy design and implementation of Libretto’s methodology and software platform. This service is designed to help Advisors ensure a smooth implementation process, and it includes business planning, discovery and research. We work together with the client to outline an implementation plan that covers all business and client delivery goals. Libretto – Disclosure Brochure dated March 05, 2024 7 These change management consulting services extend beyond Libretto’s standard Delivery Augmentation, Implementation Support and Professional Development deliverables in that they are tailored to a firm’s specific needs. Consulting areas may include: Firm augmentation – Sessions and materials delivered to a firm’s leaders focused on enhancing business value. CIO augmentation – Sessions and materials delivered to a firm’s CIO and investment team focused on enhancing the firm’s investment delivery. Team augmentation – Training sessions tailored to the needs of a firm’s advisory team. Operational Projects – Projects related to a firm’s technology, data management and operational workflows. Additional System Perspectives Libretto does not provide regular and continuous management of assets, and all advice is generated using software-based models or applications on a non-discretionary basis. Portfolios are based on the inputs of the Advisors in the application of planning, asset allocation, asset location, product fulfillment and investment policy. Libretto’s systems will assist Advisors in managing portfolios based on the end client’s individual objectives, time horizons, risk tolerance and liquidity needs. As appropriate, Advisors may also review and discuss their client’s prior investment history, as well as family composition and background. Libretto enables management of the Advisor’s advisory accounts on a non-discretionary basis. Account supervision is guided by the client's stated objectives and liquidity needs, as well as tax considerations. Advisors may impose reasonable restrictions on investing in certain securities, types of securities or industry sectors through the Libretto system. Once the Advisor’s client's portfolios have been established, the Advisor may conduct periodic portfolio and financial plan reviews with the client and rebalance the portfolio as conditions warrant based on the client's individual needs. Libretto will make initial illustrative investment suggestions which are not limited to any specific product or service offered by an asset manager, broker-dealer or insurance company. However, the Advisor may override or select its own investment recommendations. All investments involve some risk, and some types of investments involve certain additional degrees of risk. Implementation of recommendations generated by Libretto’s system should only be implemented by Advisors when consistent with the Advisor’s end Libretto – Disclosure Brochure dated March 05, 2024 8 client's stated investment objectives, tolerance for risk, liquidity and suitability, all as determined by the Advisor. Libretto’s system supports Advisors’ efforts to continuously iterate the financial plan and portfolio to reflect changes in their end clients’ objectives, assets, suitability and preferences. The system enhances the ability of Advisors to successfully communicate with their own clients and reflect their wishes in their strategy. Wrap Fee Programs Libretto does not sponsor or participate in any wrap fee programs. Assets Under Management Libretto does not manage client assets directly, but rather supports the efforts of Advisors. Therefore, it has no regulatory assets under management.