Zoe Financial, Inc. (“Zoe”) is not a client of any Advisor it recommends. Advisors pay Zoe if you hire them. That payment is a conflict of interest: Zoe has a financial incentive to recommend the Advisors in its network, and because the fee varies by Advisor, an incentive to recommend some Advisors over others. Some Advisors also own equity in Zoe or pay Zoe fees to use its platform, which give Zoe additional incentives to recommend them.

What Zoe does

Zoe matches users with independent investment advisors that participate in the Zoe Advisor Network (each, an “Advisor”). Each Advisor has a profile page describing its services, fees, and disclosures; review it before hiring an Advisor. Each recommendation of an Advisor is an endorsement for which Zoe is compensated by that Advisor.

How Zoe is paid

Zoe has a written agreement with each Advisor. If you become an Advisor’s client, the Advisor pays Zoe a referral fee. Depending on Zoe’s agreement with that Advisor, the fee may be:

(1)a percentage of the advisory fees you pay the Advisor (or of the Advisor’s revenue from your relationship), up to 35%, for as long as you remain the Advisor’s client, where the Advisor charges an asset-based fee;

(2) an annual fee of up to 0.35% of your household’s assets managed by the Advisor, on a tiered schedule under which the rate declines as assets increase, for as long as you remain the Advisor’s client;

(3) a percentage of fixed or hourly planning fees, up to 35%, during an initial period of up to five years; or

(4) a fixed, one-time referral fee.

The referral fee structure and rate that apply to your Advisor are set in Zoe's agreement with that Advisor and are available from that Advisor on request. Certain Advisors also pay Zoe a fee to participate in the Zoe Advisor Network. If an Advisor undergoes a change of control, or has paid referral fees to Zoe for ten or more years, the Advisor may end its future payments by paying Zoe a lump sum equal to three times its average annual payments over the prior three fiscal years (annualized where a full three-year history does not exist).

No part of the referral fee is charged to you, and Zoe’s agreements require that Advisors not charge referred clients more than their standard fees for similar services.

Zoe’s conflicts of interest

• Zoe earns a referral fee only if you hire an Advisor from the Zoe Advisor Network, so Zoe has an incentive to recommend Network Advisors.

• Referral fees vary by Advisor, so Zoe has an incentive to recommend Advisors that would pay Zoe more.

• Certain Advisors, directly or through affiliates, hold equity interests in Zoe totaling less than 5% in the aggregate, so Zoe has an incentive to refer clients to those Advisors.

• Advisors pay Zoe platform, sub-advisory, and model marketplace fees, depending on the services they use, for accounts held on the Zoe Wealth Platform, and brokerage for certain platform accounts is provided by Zoe Securities, LLC, a broker-dealer under common ownership with Zoe that receives compensation related to those accounts. Zoe therefore has an incentive to recommend Advisors that use the platform and for your accounts to be held there. Platform and sub-advisory fees are waived for referred clients while a referral fee is payable; model marketplace fees are not.
  
  

For additional information, please refer to Item 14 of Zoe’s Form ADV Part 2A, available at adviserinfo.sec.gov/firm/brochure/285158. Questions: support@zoefin.com.