Who We Are SBA is a Registered Investment Advisor (RIA) with its primary place of business in Seattle, Washington. We are organized as a limited liability company under the laws of the State of Delaware. Our principal owner, Stuart Robertson, has led ShareBuilder 401k since 2007. ShareBuilder 401k is a fully owned subsidiary of ShareBuilder Inc. SBA’s mission is to lead Americans to save by helping lower costs in 401(k) plans, making simple-to-buy plans available digitally, and providing advisory services for employers, including certain fiduciary responsibilities and oversight of Model Portfolios and an Investment Roster. ShareBuilder Advisors, LLC provides investment advice to plan sponsors under the names “ShareBuilder 401k” and “ShareBuilder Advisors.” Services to Plan Sponsors The Firm provides consulting services and information to Plan Sponsors (or “Employers”) regarding establishing defined contribution plans (“Plan”) for their Participants (or “Employees”)1. Through our website, we ask the Employer a series of questions and then recommend a particular Plan based on the Employer’s identified needs. We then provide an automated process to assist the Employer in selecting and purchasing a Plan and then choosing investment options, as described below. Our Plan recommendations are based on several factors, including but not limited to, size of employee base, demographics, and existing benefits. Key to meeting our goal of making 401(k) plans simpler is offering limited investment choices. To this end, we offer exchange-traded funds (ETFs) on our platform, certain Commodity ETFs, and a Money Market Fund. We also provide Model Portfolios. We do not offer advice on any other types of investments. Investments outside this defined roster may not be held in any SBA account. We provide QDIA

appropriate options for selection by plan sponsors and vote fund proxies for your plan. Participants may choose to invest in a Model Portfolio created by SBA, or they may build a custom portfolio utilizing a selection of the ETFs and the Money Market Fund. Model Portfolios are constructed to meet a range of Plan and Participant risk profiles. In no event does SBA construct a profile outside of these portfolios, nor does SBA offer or furnish personalized advice to Plan Participants. Because SBA’s Investment Committee chooses the investment options available, as well as the composition of the Model Portfolios, we serve as an ERISA 3(38) advisor for each 401(k) Plan, unless otherwise arranged or designated. The Investment Committee also manages proxy voting for plan sponsors in most cases. We do not provide other investment advisory services beyond these to our 401(k) Program Clients. 1 Plan Sponsors and Participants shall have the same meaning as defined in ERISA. SBA’s ERISA 3(38) status distributes some of the fiduciary risks and duties Employers would otherwise have in offering a Plan by managing the investments made available in the Plan. The Plan Sponsor and other Employer personnel involved with the Plan retain all other fiduciary duties, including the selection of other Plan providers. SBA also offers the Solo 401(k) Saver program to small businesses with only the Plan Sponsor as a participant. This limited plan may be efficient for certain small businesses. SBA offers no tax advice to Plans, Plan Sponsors or Plan Participants. SBA does not have custody of assets, nor does it provide advice to participants. Employee Plan SBA provides a 401(k) plan for its employees, which, in accordance with ERISA requirements includes no asset charges. This is a difference from our stated fee chart in Item 5.