Disclosures

Entity Information and Registrations

Zoe Financial, Inc. ("Zoe Financial") is an investment adviser registered with the U.S. Securities and Exchange Commission ("SEC") under the Investment Advisers Act of 1940. SEC registration does not imply a certain level of skill or training. Zoe Financial's Form ADV Part 2A (the "Brochure") and Part 2B (the "Brochure Supplement") contain important information about Zoe Financial's business practices, fees, conflicts of interest, and disciplinary history, if any. Clients and prospective clients are encouraged to read the Brochure and Brochure Supplement before engaging Zoe Financial's services. These documents are available free of charge at adviserinfo.sec.gov or upon request from Zoe Financial. Zoe Financial's CRD number is 285158.

Zoe Securities, LLC ("Zoe Securities") is a broker-dealer registered with the SEC and is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). Zoe Securities' CRD number is 326979. You may check the background of Zoe Securities and its registered representatives on FINRA's BrokerCheck at brokercheck.finra.org.

Affiliation. Zoe Financial and Zoe Securities are affiliated entities under common ownership and control. Brokerage services, including the Zoe High-Yield Cash Account, are offered through Zoe Securities. Investment advisory services are offered through Zoe Financial. This affiliation creates a conflict of interest because Zoe Financial has a financial incentive to recommend or utilize brokerage services provided by its affiliate, Zoe Securities. Clients should be aware of this relationship when evaluating the services and products described on this page.

Clearing and Custody. Zoe Securities introduces client accounts to Apex Clearing Corporation ("Apex"), a registered broker-dealer, member of FINRA and SIPC, which serves as the clearing firm and custodian for client brokerage accounts. Apex is not affiliated with Zoe Financial or Zoe Securities.

High-Yield Cash Account Disclosures

The Zoe High-Yield Cash Account ("Cash Account") requires a brokerage account opened through Zoe Securities and carried by Apex. Neither Zoe Financial, Zoe Securities, nor Apex is a bank. Uninvested cash in your brokerage account may be swept into interest-bearing deposit accounts at participating Program Banks through Apex's FDIC-Insured Bank Sweep Program.

Swept balances are eligible for FDIC insurance up to $250,000 per depositor, per Program Bank, per ownership category, aggregated with any other deposits you hold at the same bank. Apex may place funds across multiple Program Banks; however, you are responsible for monitoring your total deposits at each bank to manage coverage. FDIC insurance applies only while funds are on deposit at a Program Bank (not to securities or funds held in the brokerage account).

Cash held in your Apex brokerage account or in transit to/from Program Banks is protected by SIPC up to $500,000 (including $250,000 for cash); SIPC does not protect against a decline in market value. Apex also maintains excess SIPC-type insurance subject to limits.

APY is variable and may change at any time without notice. Interest is accrued daily at Program Banks and credited to your account; rates are set by Program Banks and may be lower than alternatives. Any promotional or boosted APY (if offered) is time-limited and contingent on stated eligibility requirements; when the promotional period ends, the rate reverts to the then-current standard APY.

Deposits and withdrawals are made through your Zoe Securities/Apex brokerage account, not directly with Program Banks. Under federal regulation, a Program Bank may require up to seven (7) days' prior notice before permitting a sweep out; access to funds may be delayed in the event of a Program Bank failure.

The current Program Bank list is maintained by Apex and may change. You may opt out of specific banks via Zoe; if too few banks remain to place all cash within FDIC limits, some cash may remain unswept (and thus not FDIC-insured) or be deposited above FDIC limits.

Participation does not guarantee that some or all of your excess cash will be swept at all times. Apex does not monitor your non-Program deposits for FDIC aggregation; you must track your total deposits at each bank.

Compensation, Fees, and Conflicts of Interest

Apex receives fees from Program Banks tied to balances placed; higher fees to Apex can reduce the rate you receive. Program Banks earn a spread on your deposits and have discretion to set deposit rates.

Zoe Financial and/or Zoe Securities may receive a portion of the fees that Apex earns from participating Program Banks in connection with the FDIC-Insured Sweep Program. This creates a financial incentive for Zoe to recommend the Cash Account and the sweep program over other available cash alternatives that may offer higher yields or different features. Clients should consider this conflict when evaluating whether the Cash Account is appropriate for their needs.

Zoe Financial charges advisory fees as described in its Form ADV Part 2A. Cash held in the Cash Account may or may not be included in the assets on which advisory fees are calculated, depending on your advisory agreement. Please consult your advisory agreement or speak with your financial advisor for details.

The fees and compensation arrangements described herein are in addition to any advisory fees, brokerage commissions, or other charges that may apply to your account. For a complete description of fees, compensation, and conflicts of interest, please refer to Zoe Financial's Form ADV Part 2A and Zoe Securities' account documentation.

Investment Risks and Limitations

The Cash Account is designed to hold uninvested cash and is not intended as a long-term investment strategy. Cash held in the sweep program is not invested in securities and will not participate in equity or fixed-income market returns. Over time, the yield on cash may not keep pace with inflation, which would reduce the purchasing power of your holdings.

Dollar-cost averaging, as referenced in this material, is an investment strategy and does not guarantee a profit or protect against a loss in declining markets. Investors should consider their willingness and ability to continue investing through periods of market volatility.

Past performance of the Cash Account's APY is not indicative of future results. The rate you receive may be higher or lower than historical rates and may be higher or lower than rates available through other cash products, including money market funds, certificates of deposit, or high-yield savings accounts offered by banks.

Regulatory and Legal

Your account is subject to the Apex Customer Account Agreement, including the pre-dispute arbitration clause and governing law provisions. In any inconsistency between this page and the Apex Sweep Program Terms, the Apex Sweep Program Terms control.

This material is provided for informational purposes only and does not constitute an offer to sell, a solicitation of an offer to buy, or a recommendation with respect to any security or investment strategy in any jurisdiction where such offer, solicitation, or recommendation would be unlawful. Nothing on this page constitutes legal, tax, or accounting advice. Clients should consult their own legal, tax, and accounting advisors before making investment decisions.

This disclosure set is intended to be read alongside the full Apex Sweep Program Terms, Zoe Financial's Form ADV Part 2A, and Zoe Securities' account documentation.