COMPOUND PLANNING, INC.

Item 1: Cover Page ____________________________________________________________________________________________________ Compound Planning, Inc. Form ADV Part 2A - Disclosure Brochure CRD # 171787 / SEC # 801-126007 115 Broadway, 5th Floor New York, NY 10006 Telephone: (888) 533-9364 www.compoundplanning.com September 29, 2025 This brochure provides information about the qualifications and business practices of Compound Planning, Inc., an investment adviser registered with the United States Securities and Exchange Commission. If you have any questions about the contents of this brochure, please contact us at (888) 533-9364 or compliance@compoundplanning.com. Nothing in this document is to be construed as a recommendation or an endorsement by the United States Securities and Exchange Commission (“SEC”) or any state securities authority or an offer of securities; please refer to the actual investment offering and related legal documentation for complete disclosures. Registration as an investment adviser does not imply a certain level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide you with information to determine whether to retain their services. This brochure is on file with the appropriate regulatory authorities as required by federal and state regulations. Additional information about Compound Planning, Inc. or any of its affiliated persons who are registered or required to be registered as Investment Advisor Representatives of the firm is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in "Compound Planning" or CRD # 171787. Results will provide you with all firm disclosure brochures.) 1  Item 2: Material Changes ____________________________________________________________________________________________________ Compound Planning, Inc. ("Compound," "the Adviser" or "firm") reviews its Form ADV Part 2A brochure at least annually to confirm it remains current. In this item, we are required to summarize only those material changes made to our brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 31, 2025, we have the following material changes to report: Item 4: Advisory Business Firm Description & Principal Owners - Leadership Transition Effective August 2025, Alexander M. Farman-Farmaian assumed the role of Chief Executive Officer (formerly Co-CEO) of Compound Planning, Inc., succeeding Christian G. Haigh, also formerly Co-CEO, who now serves as President and Executive Chairman of Alternativ, Inc., Compound's parent company. Strategic Investment by FT FinTech Holdings, LLC In the third quarter of 2025, Compound Planning, Inc. received a minority investment from FT FinTech Holdings, LLC ("FTFH", "Investor"), a Delaware limited liability company and Qualified Purchaser. FTFH made a convertible synthetic equity minority investment in the firm that includes a preferred strategic relationship with an affiliate of the Investor. Subject to its fiduciary duty to clients, Compound has designated the Investor's affiliated direct indexing platform ("Canvas") as its preferred provider of direct and custom indexing solutions for its advisors. The agreement also provides the Investor with certain information rights, including access to quarterly and annual financial statements, notice of material events, and inspection rights, subject to confidentiality limitations. Franklin Managed Options Strategies, LLC Effective September 2025, Compound Planning, Inc. entered into a sub-advisory agreement with Franklin Managed Options Strategies, LLC ("Franklin Managed"). This SEC-registered investment adviser is under common ownership with FT FinTech Holdings, LLC ("FTFH"), a strategic investor in Compound. This relationship is important for clients to know because Franklin Managed and FTFH are affiliated entities, and Compound may recommend Franklin Managed as a sub-advisor for Franklin Managed Options Strategies. While Compound also offers other options strategy providers and does not receive any incentive or compensation to select one provider over another, the affiliation with FTFH and Franklin Managed presents a potential conflict of interest. Compound mitigates this conflict by conducting ongoing due diligence on all providers, selecting options strategies based solely on the best fit for the client, and upholding its fiduciary duty at all times. SyntheticF Securities Backed Lending Program Effective September 2025, Compound entered into a sub-advisory agreement with SyntheticFi LLC ("SyntheticFi"), an SEC-registered investment adviser, to offer a securities-backed lending program to eligible clients. SyntheticFi facilitates the trading of synthetic loan contracts using option-based box spreads. Compound may allocate client assets to SyntheticFi Borrowing at its sole discretion, based on suitability and client objectives. Compound's discretion to allocate client assets to SyntheticFi can create a conflict of interest due to the revenue-sharing arrangement. Compound mitigates this conflict by conducting suitability reviews and disclosing the arrangement to clients in accordance with its Code of Ethics and fiduciary obligations. Assets Under Management Compound offers its advisory services on a discretionary and non-discretionary basis. As of August 31, 2025, our client assets under management total $4,301,591,496. The following represents assets under management by account type: Type of Account Discretionary Non-Discretionary Total Assets Under Management $ 4,301,591,496 $0 $4,301,591,496 2  Item 5: Fees & Compensation Effective September 8, 2025, Compound amended its Advisory Services Agreement ("Advisory Agreement" or "ASA") to clarify termination provisions and enhance transparency. The ASA and this brochure now include updated language regarding: ● ● ● termination timing, defined as 30 days following written notice ("Notification Date") from the client, fee proration for accounts billed in advance, based on the number of days remaining in the billing period, and refund calculations, where clients will receive a rebate for any prepaid, unearned fees beyond the Termination Date (30 days after the Notification Date). This section also includes new disclosures regarding reimbursement payments Compound may receive under its SyntheticFi Securities-Backed Lending Program. These payments are made for marketing, education, and support services related to the advisory service and are calculated as a percentage of the synthetic loan size. As a result of this arrangement, Compound has a financial incentive to recommend the SyntheticFi program. Compound mitigates this conflict by conducting suitability reviews and disclosing the arrangement to clients in accordance with its Code of Ethics and fiduciary obligations. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss We added new disclosures under this section to describe the investment methodology and risk considerations associated with our Direct Index Solutions Strategy and the SyntheticFi Securities-Backed Lending Program. These updates clarify Compound's sub-advisory relationship with SyntheticFi LLC and the nature of synthetic loan contracts structured using option-based box spreads. We also added disclosures with respect to our Franklin Managed Strategy. For full details, please refer to Item 8: Methods of Analysis, Investment Strategies & Risk of Loss. Item 10: Other Financial Industry Activities & Affiliations Compound has added disclosure regarding its sub-advisory relationship with FT and the availability of other options strategy providers. Item 20: Privacy Practices Compound added information to this section to disclose the Adviser's practices regarding recent Regulation S-P amendments and our Incident Response Program and notification practices in the event of a data breach, and to offer additional information on our use of Artificial Intelligence ("AI"). Enhancement to ADV Disclosures Other sections of this brochure were further amended to include additional disclosures, supplementary clarifying information on Compound's advisory practices, and aesthetic and formatting changes. While these changes may not necessarily be material, the enhancements are intended to clarify and better aid investors in understanding the firm's business model, procedures, and services. Full Brochure Availability We may amend this document at any time to reflect material changes in our business practices, policies, or procedures, as securities regulators require. Annually, within 120 days of the close of our fiscal year on December 31st, and as needed for any material changes, we will provide clients - either electronically or in hard copy - with a new brochure or a summary of material changes from the previously supplied document, along with an offer to deliver the full brochure upon request. Please retain this document for future reference, as it contains essential information about our advisory services and business. You may view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either by our firm name, Compound Planning, Inc. or CRD # 171787. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at (888) 533-9364 or by email at compliance@compoundplanning.com. 3  Item 3: Table of Contents ____________________________________________________________________________________________________ Item 1: Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 4 Item 4: Advisory Business 5 Item 5: Fees & Compensation 19 Item 6: Performance-Based Fees & Side-By-Side Management 29 Item 7: Types of Clients 30 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss 30 Item 9: Disciplinary Information 42 Item 10: Other Financial Industry Activities & Affiliations 43 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 48 Item 12: Brokerage Practices 49 Item 13: Review of Accounts 54 Item 14: Client Referrals & Other Compensation 55 Item 15: Custody 56 Item 16: Investment Discretion 57 Item 17: Voting Client Securities 59 Item 18: Financial Information 59 Item 19: Requirements for State Registered Advisers 59 Item 20: Additional Information 59 Business Continuity Plan 59 Information Security Program 61 Privacy Practices 61 4  Item 4: Advisory Business __________________________________________________________________________________________________________________________ Description of Firm Compound Planning, Inc. (“Compound” or “the Adviser”) is an investment adviser registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940, as amended (the "Advisers Act"). Originally founded in 2012, Compound Planning, Inc. was formed following the acquisition of Compound Financial, Inc. by Alternativ, Inc. on September 22, 2023. The firm is incorporated under the laws of Delaware and headquartered at 115 Broadway, 5th Floor, New York, NY. Effective March 21, 2025, the Adviser changed its name from Atomi Financial Group, Inc., dba Compound Planning (the name under which it previously operated) to Compound Planning, Inc. Principal Owners Alternativ, Inc. is the holding company and Managing Member of Compound Planning, Inc., with greater than 75% ownership. Effective August 2025, Alexander M. Farman-Farmaian assumed the role of sole Chief Executive Officer of Compound Planning, Inc., succeeding Christian G. Haigh, who now serves as President and Executive Chairman of the Board of Alternativ, Inc., Compound’s parent company. Christian G. Haigh and Alexander M. Farman-Farmaian are Co-Founders of Compound Planning, Inc. and continue to serve as Directors of Alternativ, Inc., with Mr. Haigh also holding an indirect ownership interest in Alternativ. Courtney L. Holt serves as Chief Compliance Officer of Compound Planning, Inc., overseeing the administration of the firm’s Compliance Program, regulatory obligations, and Code of Ethics. FT FinTech Holdings, LLC In the third quarter of 2025, Compound Planning, Inc. received a minority investment from FT FinTech Holdings, LLC (“FTFH”, “Investor”), a Delaware limited liability company and Qualified Purchaser. The investment is structured as a convertible, synthetic equity interest, which includes a preferred strategic relationship between Compound and an affiliate of the Investor. Subject to Compound’s fiduciary duty, Compound has designated Canvas as a preferred direct indexing and technology platform (“Canvas”), and has agreed that Canvas will serve as the exclusive provider of a direct and custom indexing solution as it relates to integration with Compound’s technology platform. The platform also provides execution and custodial services. The agreement also gives the investor certain information rights, including access to quarterly and annual financial statements, notice of material events, and inspection rights, subject to confidentiality limitations. While this strategic relationship presents conflicts of interest as it could influence the selection and integration of certain investment products and technologies, this relationship does not obligate the firm to utilize the affiliate’s services exclusively. Compound retains full discretion to engage other providers as necessary. To mitigate potential conflicts of interest, maintain the independence of investment-related decision-making, and ensure all decisions are made in accordance with the firm’s fiduciary duty, including its obligations of care and loyalty to clients, Compound conducts regular due diligence on all providers and platforms, ensures that client interests remain paramount at all times, and adheres strictly to its fiduciary obligations under applicable SEC and state regulatory frameworks. Advisory Business In this Brochure, the terms "we," "our," or "us" refer to Compound, and the terms "you," "your," and "client" refer to you as either a current or prospective client of our firm. The term "Associate" refers to Compound’s Supervised Persons, which include the firm’s Officers, Directors and Executive Officers ("Control Persons"), employees, and its investment professionals (“Investment Professionals”), the individual registered Investment Advisor Representatives ("IARs") who are licensed, supervised, and approved by Compound to provide investment advice or advisory services on behalf of the firm, as required for their roles and client base. Compound owes a fiduciary duty to its clients, as defined by applicable laws and regulations. As a fiduciary, the firm is committed to acting with loyalty, care, fairness, and good faith toward each client. This commitment includes mitigating any potential conflicts of interest that may arise in the course of providing services. In delivering investment advice, we endeavor to exercise the highest degree of care, skill, prudence, and diligence that a prudent person acting in a fiduciary capacity would apply under similar circumstances. Compound offers investment advisory services to financial intermediaries, including unaffiliated broker-dealers, unaffiliated 5  registered investment advisers, and affiliated IARs (collectively, “Financial Intermediaries” or “Intermediaries”), in the capacity of a sub-adviser to the Financial Intermediary. These advisory services may include assisting the Financial Intermediary with tasks such as investment policy statement determination, asset allocation, investment selection, portfolio management, billing, and client reporting. The investment advisory services provided by the Adviser are typically offered on a limited discretionary basis. In certain instances, we may also provide these services on a non-discretionary basis. For accounts in which we do not have discretionary authority, the Adviser will seek client approval prior to making any recommendations deemed appropriate for the client’s financial objectives. Applicable regulations require our registered Financial Intermediaries to obtain the necessary licenses and complete required training to recommend specific investment products and services. Clients should be aware that their Investment Professional’s ability to recommend certain services, investments, or strategies may depend on the specific licenses or training they have completed. Additionally, registered individuals can only transact business or respond to client inquiries in the states and locations where they are properly licensed. For additional information about the individuals providing advisory services on our behalf, clients should refer to their Investment Professional’s Form ADV 2B Brochure Supplement, a separate disclosure document provided alongside this Brochure, prior to or at the time the advisory relationship begins. (If the client did not receive this document, please contact Compound directly at (888) 533-9364 or compliance@compoundhq.com to obtain a copy.) Non-Exclusive Relationship Compound's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client's specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client can differ or conflict with that provided for the same security or investment for another. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Other Professional Service Provider Recommendations Compound may suggest the services of other professionals for implementation purposes, such as lawyers, accountants, insurance agents, and others. These professionals are engaged directly by the client on an as-needed basis. Unless otherwise stated, Compound does not receive referral fees for such recommendations, and clients are under no obligation to use any recommended services. If clients choose to engage these professionals, they will enter into a separate agreement directly with the selected individual(s). Except where specifically indicated, Compound is not involved in the transaction and does not have the authority to accept clients on behalf of any referred professional. Each referred professional has the right to decline any client or prospective client for any reason or without reason. In selecting a referred professional, the client is responsible for reviewing and understanding the referred provider's separate contract, including any associated charges. The client will be liable for these charges should they choose to engage the referred professional. The client retains full discretion over all such implementation decisions and is under no obligation to accept or follow any recommendation from Compound. If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Should any conflicts of interest arise concerning the recommendation of other professionals in the future, Compound will notify the client accordingly. (See Item 10: Other Financial Industry Activities & Affiliations for additional information.) Client Responsibilities Compound's advisory services rely on the information provided by clients. The Adviser cannot adequately fulfill its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, submits any requested data or documentation in a timely manner, provides updates promptly upon changes, and otherwise fulfills their responsibilities under the Advisory Agreement. Compound will rely on the accuracy of the information supplied by the client or on their behalf without further investigation; the Adviser is not obligated to verify information obtained from clients or other professional advisors, including accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify Compound in writing if any information material to the 6  advisory services provided changes, if previously provided information that might affect the management of their account occurs, or if any earlier provided data becomes inaccurate. The client or their successor shall also promptly notify Compound in writing of the client's dissolution, termination, merger, or bankruptcy if the client is not a natural person or of the occurrence of any other event that might affect the validity of their Advisory Agreement or our authority under the Agreement. Compound reserves the right to terminate any client engagement where the client has willfully concealed or failed to provide pertinent information material to the advisory services to be rendered or to their individual or financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Advisory Agreement Compound’s advisory services are designed to address the specific needs of each client, as outlined in the applicable written client contract – whether the Advisory Services Agreement (“Advisory Agreement” or “ASA”), Financial Planning Services Agreement, or Consulting Services Agreement (collectively, the “Agreement”) - depending on the advisory service selected. Each Agreement will outline the scope of services, contract terms, advisory fees, the formula for calculating such fees, and the type of investment management authority granted. Additionally, the Agreement will specify whether any written reports or electronic plans will be provided. The final advisory fee structure for the selected service will be clearly documented in the executed Agreement. Investment Professionals are limited to providing only the services specified in the respective Agreement and must adhere to the client's stated objectives, limitations, and restrictions, as applicable. To engage Compound's advisory services, clients must complete and execute the appropriate Agreement for the selected service. Clients may engage us for additional services at any time. Once established, an Agreement may not be assigned, as defined under the Advisers Act, without the client’s consent, as specified therein. Clients should consult with their IAR and the applicable Agreement and Fee Schedules for additional information regarding each service. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Advisers Act shall not be considered an assignment. For further information regarding advisory service fees and account management style, refer to Item 5: Fees & Compensation and Item 16: Investment Discretion.) Investor Profile & Client Suitability Compound is an investment advisory firm dedicated to client engagement and personalized financial guidance. We provide tailored investment advice, advisory services, and wealth management technology designed to meet the unique needs of each client. At the outset of the advisory relationship, the IAR will conduct a comprehensive assessment of the client’s financial situation. This evaluation involves personal discussions, diagnostic questionnaires, and other tools provided by the Adviser. Key factors such as investment goals, financial objectives, risk tolerance, liquidity, income needs, time horizon, and market expertise will be evaluated. Additionally, the client’s income, expenses, and existing investments will be reviewed to form a clear understanding of their overall financial landscape. Further pertinent information will be gathered, including detailed financial data such as assets, liabilities, and portfolio statements. This data will serve as the foundation for crafting customized investment plans and recommendations tailored to the client’s specific financial situation. Based on this comprehensive profile, the Investment Professional will recommend the most appropriate advisory services for the client. Depending on the selected advisory service, a strategic investment recommendation will be formulated, which includes the development of an asset allocation strategy. This strategy will take into account the client’s financial objectives, risk tolerance, and personal preferences. The goal is to establish realistic, measurable financial targets and create an investment strategy that supports both short-term and long-term financial objectives. The executed Agreement will clearly outline the specific advisory services to be provided, along with the agreed-upon fee structure, ensuring transparency and mutual understanding of the terms. Types of Advisory Services Compound delivers comprehensive financial and planning solutions through the following advisory services: 7  1. Turnkey Asset Management Program (“TAMP”) Services - Includes model portfolio delivery and centralized trading services for affiliated and third-party advisers. 2. Investment Management Services – Includes discretionary and non-discretionary portfolio management for individuals and institutions. In addition, offers customized portfolios managed by Compound’s Custom Wealth Solutions (“CWS”) Team and delivered via Separetely Managed Accounts (“SMAs”) via the Direct Index Solutions Strategy option. 3. Financial Planning & Consulting Services – Includes retirement, estate, tax, cash flow planning, and specialized consulting engagements. 4. Third-Party Adviser Management Referral Services – Includes model portfolio delivery and centralized trading services for affiliated and third-party advisers. 5. Institutional Advisory Services - Includes services to financial institutions, retirement plans, and other entities under the following selections: - ERISA, Retirement & Employee Plan Benefit Services - Sub-Advisory Services for Other Financial Institutions - Provides investment, operational, or marketing support to other financial institutions. Offers securities-backed loans to clients using option-based strategies via the SyntheticFi Securities Backed Lending Program and Franklin Managed Options Strategies Sub-Advisory Program. 6. Educational Seminars & Workshops Services Below is a detailed overview of the advisory service options available to clients: Turnkey Asset Management Program (“TAMP”) Services Through Compound’s Turnkey Asset Management Program (“TAMP”) Services investment platform, Financial Intermediaries gain access to a comprehensive range of investment options, tax-advantaged investments, and operational support services to offer to their clients. Prior to offering any investment, Compound conducts thorough due diligence to ensure the investment, along with its general partner, sponsor, or adviser, is properly registered, licensed, or notice-filed with the relevant regulatory authority. Additionally, we evaluate the investment's suitability to ensure compliance with applicable regulations. As the TAMP provider, Compound is responsible for the implementation, trading, and reconciliation of selected investments, as well as ensuring proper billing and reporting. Additionally, we may serve as a sub-adviser to other financial institutions, offering portfolio management, investment selection, or advisory services based on the institution’s needs. These services also include a variety of investment strategies, asset allocations, and management functions tailored to institutional clients, utilizing affiliated IARs as part of the service. Under the TAMP Agreement, Compound has the authority to manage and automatically rebalance client assets in line with the parameters of the selected investment model or strategy. For unaffiliated Financial Intermediaries, the ultimate discretion over the suitability of any investment program rests with the Intermediary and the client. In this arrangement, our responsibility with respect to the end client’s account is more limited. (Continued on next page.) The available investment strategies, portfolio options, and support services through this advisory selection are as follows: 8  Turnkey Asset Management Program (“TAMP”) Services Under Compound’s In-House Model, a variety of asset allocation models are offered, each tailored to meet specific investment objectives. The securities selected within each model may include both load and no-load mutual funds, exchange-traded funds (“ETFs”), and/or individual securities. In formulating its asset allocation strategies, Compound utilizes a range of analytical tools, considering factors such as the historical risk and return profiles of asset classes, correlations between asset classes, and relevant risk premiums. In-House Model Clients retain direct ownership of the securities purchased within each investment strategy. Each model is based on a strategic asset allocation; however, the Adviser may adjust the actual allocation in response to market conditions, including fundamental, technical, and macroeconomic analysis. In its limited discretionary capacity, the Adviser determines the timing of trades and executes them when deemed appropriate. (Note: Investment minimums may be waived at the Adviser’s discretion.) Compound provides a platform through which third-party managers offer investment strategies and models (“Models”), available for selection by Financial Intermediaries on behalf of their clients. Through their Advisers, Financial Intermediaries may select third-party managers in accordance with each client’s specific investment objectives, guidelines, risk profile, and other pertinent financial considerations. Each Third-Party Model is typically provided by a traditional asset manager, private fund manager, or index provider (“Sponsor”). Third-Party Models Sponsors may also provide supplementary content (“Sponsor Content”), which can include descriptions of investment strategies, market commentary, insights into underlying investments, and other relevant information about the Sponsor’s team and Models. Sponsor Content reflects the opinions of the Sponsor and should not be construed as personalized investment advice. Furthermore, Sponsor Content is subject to change without notice. It is important to note that the fees charged by third-party managers are typically in addition to Compound’s advisory fees, as well as any other applicable expenses associated with the client’s account with Compound. Under Compound’s Intermediary-Directed Model, Financial Intermediaries are afforded the ability to create and manage investment portfolios on behalf of their clients. In this model, Compound provides only administrative services and does not offer investment advisory services; therefore, it is not responsible for selecting specific investment vehicles. Intermediary - Directed Models For certain types of Intermediary-Directed Models, Compound may facilitate the execution of trade orders as directed by the Financial Intermediary. However, Compound does not assume discretionary authority over client accounts nor act as an investment adviser in these instances. Compound provides Financial Intermediaries with access to non-traditional, private, or unregistered investment strategies (collectively, "Alternative Investments") for use with their clients. These Alternative Investments may include, but are not limited to, private equity (e.g., Regulation D, Regulation A), public non- traded offerings (e.g., S-1 offerings, intrastate offerings, Business Development Companies (“BDCs”), non- traded mutual funds), non-traded Real Estate Investment Trusts (“REITs”), and non-traded oil and gas programs. Certain Alternative Investments may require clients to enter into a separate agreement, typically a subscription agreement, with the respective Alternative Investment manager. These agreements will include distinct fees, terms, conditions, and disclosures. Alternative Investments Compound has a fiduciary responsibility to conduct due diligence on all Alternative Investments utilized by affiliated Financial Intermediaries. However, as a provider of Turnkey Asset Management Program (“TAMP”) services, the Adviser’s role is limited to administrative functions, such as trade processing and reconciliation for billing and reporting purposes. Unaffiliated Financial Intermediaries, in contrast, are solely responsible for conducting their own due diligence and ensuring that any security or investment product recommended to their clients is suitable based on the client’s needs and objectives. Alternative Investments generally impose minimum investor suitability standards, which are disclosed within the relevant investment’s prospectus or offering circular. Additionally, more restrictive suitability or concentration standards may apply at the state or firm level. While certain Alternative Investments may offer periodic tender offers or other redemption features, they are 9  typically considered illiquid. Therefore, investors should understand that these investments do not have a secondary market, which limits the ability to convert the investment into cash. Anticipated holding periods for Alternative Investments may vary depending on the specific nature and strategy of each investment. The Adviser will communicate the expected holding period, as indicated in each investment’s prospectus or offering circular. However, there is no guarantee that a liquidity event will occur within the stated timeframe, if at all. All Alternative Investments should be considered speculative in nature and subject to a high degree of risk, including the potential loss of the entire investment. Furthermore, Alternative Investments are not endorsed or approved by FINRA, the SEC, or any other regulatory agency. Under this service model, Financial Intermediaries may choose to utilize the following back-office support services: Account Reconciliation Support Compound utilizes electronic data feeds from trading, clearing, and custodial firms to enhance the efficiency of the account reconciliation process. This may be accomplished either directly by Compound or through third-party vendors. Billing Services Compound automates various aspects of client billing on behalf of Financial Intermediaries, including invoicing, fee calculation, and fee collection, ensuring a streamlined and accurate process. Back-Office Support Reporting Services Compound provides data aggregation and reporting services, enabling Financial Intermediaries to monitor their clients' accounts effectively. Intermediaries can review client holdings, asset allocation, and portfolio performance. Performance reporting is calculated in accordance with industry standards and applied to individual accounts or a combination of related accounts within a household or family asset structure. Software Licensing & Consulting Support Compound offers its asset management software program, provided through a web-enabled platform (“Platform”), to other Financial Intermediaries, including investment advisers, broker-dealers, and financial services firms. The Platform is typically customized and private-labeled in the name of the respective institution. Financial Intermediaries may offer the Platform to their financial professionals, who use it to manage client accounts. The Platform enables Financial Intermediaries to provide separate account investment advisory programs, a variety of asset allocation strategies, and account reporting services. Compound also permits financial intermediaries to combine these services and programs to strive to best meet the needs of their clients. Additionally, Compound may provide consulting services related to its Software Licensing, including implementation support and ongoing maintenance services. To engage in this service, clients will execute a TAMP Advisory Agreement, which will define the scope of services to be provided and the agreed-upon fees according to our Standard Fee Schedule, as negotiated and specified in the executed services Agreement. Clients participating in this advisory service should be aware that Compound can receive compensation for referring clients under the TAMP, which creates a conflict of interest. Compound is committed to acting in the best interest of its clients and will fully disclose any material conflicts related to these referral arrangements. (See Item 5: Fees & Compensation, Item 10: Other Financial Industry Activities & Affiliations, and Item 14: Client Referrals & Other Compensation for additional information.) Investment Management Services Compound’s Investment Management Services generally include asset allocation advice, selection of investments, implementation of the investment plan, and ongoing investment portfolio monitoring. Under this service model, Compound serves as the corporate registered investment adviser to affiliated Investment Adviser Representatives registered with the Adviser and employed either as W2 employees or 1099 contractors, or to unaffiliated Financial Intermediaries via a TAMP relationship. Affiliated IARs have access to the same investment models and ancillary services offered to unaffiliated Financial Intermediaries through our Turnkey Asset Management Program (“TAMP”) Services. This includes In-House and Third-Party Models, as well as Alternative Investments. In certain cases, provided the affiliated IAR has the necessary knowledge and experience, they may also be permitted to manage Intermediary-Directed Models. All client onboarding, client profiles, suitability determinations, terms, conditions, and disclosures are consistent for both affiliated 10  IARs and unaffiliated Financial Intermediaries. Affiliated IARs will receive direct operational support and compliance oversight from Compound. However, the relationship between a client and Compound will differ when working through an affiliated IAR as opposed to an unaffiliated Financial Intermediary. Under the advisory service through an affiliated IAR option, Compound serves as a fiduciary and operates under a discretionary management model, holding the responsibility to assess the suitability of investment recommendations and allowing the Adviser to execute securities transactions on behalf of the client without prior consent for each trade. (Clients should note that the discretionary management authority under this advisory service is limited to the investments within the client’s managed account. See Item 16: Investment Discretion for further details.) Direct Index Solutions Strategy The Direct Index Solutions Strategy offered under this advisory option is structured to allow clients to retain direct ownership of the underlying securities within each investment strategy. Each model is built on a strategic asset allocation framework, which may be adjusted in response to market conditions, including fundamental, technical, and macroeconomic analysis. Compound operates in a limited discretionary capacity, determining the timing of trades and executing them when appropriate. Clients may access these strategies through: In-House Models – Managed directly by Compound, using mutual funds, ETFs, and/or individual securities selected based on historical risk/return data, asset class correlations, and risk premiums. Third-Party Models – Offered via a platform where traditional asset managers, private fund managers, or index providers (“Sponsors”) provide investment strategies and models. Financial Intermediaries select these in alignment with each client’s investment objectives, risk profile, and financial circumstances. Sponsors may also provide supplementary content such as market commentary and strategy insights, which reflect their own views and are not personalized investment advice. To engage in this service, clients must execute a Direct Index Solutions Advisory Agreement, which defines the scope of services to be provided, the applicable fees, and the investment management authority granted to Compound. The Agreement will also specify whether any written reports or electronic plans will be provided. The final advisory fee structure will be clearly documented in the executed Direct Index Solutions Advisory Agreement. Fees charged by third-party managers are in addition to Compound’s advisory fees and any other applicable account expenses. Investment minimums may be waived at the Adviser’s discretion. Financial Planning & Consulting Services Compound’s Financial Planning & Consulting Services provides highly personalized, goal-oriented planning and consulting designed to address the distinctive needs of entrepreneurs, professionals, retirees, families, and other clients. Clients will select from two service options, as follows: Financial Planning Services Under our Financial Planning Services option, Compound will utilize purpose-built modeling software - whether licensed or proprietary - to address comprehensive financial planning needs. These services range from comprehensive financial planning to personalized one-on-one advice on investment matters or other areas of guidance, as specified in the client’s contract. Our offerings may include, but are not limited to, the following areas of focus: Asset Allocation - Advising on the most effective distribution of client assets to support the optimization of returns while managing risk. Business Planning - Providing guidance for business owners on matters such as succession planning, tax strategies, and financial growth. Cash Flow Forecasting - Analyzing and forecasting a client’s expected future cash inflows and outflows to assist in better financial management. Charitable Giving - Offering advice on charitable contributions, tax-advantaged giving strategies, and philanthropic goals. Distribution Planning - Helping clients structure the distribution of assets to meet income and estate planning goals, minimizing taxes. 11  Educational Funding - Planning for educational expenses, including strategies for funding college or other related needs. Estate Planning - Developing strategies to manage and transfer assets efficiently, with the aim of minimizing taxes and legal costs upon death. Financial & Cash Management Issues - Providing advice on managing current financial obligations, budgeting, and savings. Insurance Needs Analysis - Assessing a client’s current insurance coverage to determine if it meets their needs, and recommending appropriate changes. Other Investment Consulting & Asset Allocation - Offering tailored investment advice based on the client’s risk tolerance, goals, and market conditions. Investment Goal Setting - Identifying the client's specific investment objectives, time horizon, and risk profile to guide their investment decisions. Retirement Planning & Analysis - Developing strategies designed to better protect financial security in retirement, including savings and investment strategies. Risk Management - Identifying and addressing risks to the client’s financial security, including disability, health care, and long-term care risks. Taxation Issues - Advising on tax efficiency, potential deductions, and strategies to minimize tax liabilities. To engage in this service, clients will execute a Financial Planning Services Agreement, which will define the scope of services to be provided and the agreed-upon fees, which may be offered on a fixed fee or hourly basis, depending on the complexity and scope of the planning process. The duration and cost will be specified in the executed services Agreement. The Agreement will also specify whether any written reports or electronic plans will be provided. Financial plans and recommendations are based on the client's financial situation as disclosed at the time of the execution of the agreement. The timeline for completing an initial financial plan may vary depending on the client’s responsiveness and the timely submission of all required information and supporting documents. Typically, the completion of an initial financial plan takes approximately three (3) to six (6) weeks once all client data has been collected. It is Compound’s policy that no initial financial plan will take more than six (6) months to complete from the date of execution of the Financial Planning Services Agreement. If the plan is not completed within this timeframe, any prepaid unearned fees will be prorated, with a deduction for bona fide financial planning services rendered to date. If the client receives a written financial plan, the plan will not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, it shall be the client's responsibility to obtain them from one or more third parties. As financial planning is inherently a discovery process, where new information may surface throughout the course of analysis, should discrepancies arise during this process and the client’s circumstances differ significantly from the initial disclosures, the client can be subject to a revised fee. In such cases, clients will be notified promptly of any necessary changes to the engagement's scope, and no additional work will be undertaken until they approve the revised fee structure. Clients may request updates or additional reviews, which may incur additional fees at the firm’s current hourly rate. (See Item 5: Fees & Compensation for further information.) Consulting Services Compound offers specialized Consulting Services that extend beyond the scope of traditional financial planning. These services are tailored to address unique or complex issues requiring expertise in areas not typically covered under standard advisory services. Examples of services provided under this model include, but are not limited to, the following: 12  Bill Pay & Family Office Services - Offering a suite of services designed to manage financial tasks for high-net-worth families, including paying bills and managing day-to-day financial operations. Business Growth Strategies - Offering advice on scaling, funding, and managing the financial aspects of business expansion. Charitable Giving & Philanthropy Strategies - Advising on charitable giving programs, including foundations, donor- advised funds, and tax-efficient gifting strategies. Estate Transfer or Probate Matters - Assisting with the complex legal and financial processes involved in transferring assets upon death. Insurance Planning & Risk Management - Providing comprehensive risk analysis and recommending appropriate insurance policies to safeguard the client’s assets. Researching & Recommending Tax Strategies - Analyzing a client’s tax situation and recommending strategies intended to optimize tax efficiency and minimize liabilities. Succession Planning - Helping business owners plan for the transfer of their business interests to successors to better protect financial stability and continuity. Before commencing a Consulting Services engagement, clients will execute a Consulting Services Agreement, which will outline the scope of services, the associated fee structure, and other relevant terms of engagement. Consulting services are available on either a one-time or retainer basis, depending on the client’s specific needs. Neither Compound nor its IARs will have discretionary investment authority when providing Financial Planning & Consulting Services. Additionally, these services do not include the management of client assets or the implementation of the financial plan’s recommendations. Financial planning or consulting services may be provided as the sole service to the client. By executing a Financial Planning Services Agreement or a Consulting Services Agreement, the client is under no obligation to utilize any investment advisory, insurance, or other services offered by Compound, nor any products or services provided by IARs affiliated with our firm as a result of their involvement in activities outside the scope of the advisory relationship. This service does not encompass the implementation or monitoring of any recommendations. Clients are under no obligation to act on any financial planning or consulting recommendations made and retain the discretion to implement any recommendations independently or through any brokerage or firm of their choosing. Third-Party Adviser Management Referral Services Compound offers Third-Party Adviser Management Referral Services, under which, following appropriate due diligence, we may recommend or refer clients to independent, separately registered investment advisers (“TPMs”). These TPMs are responsible for administering the client’s account under a separate advisory agreement. For this service, Compound and IARs act in a Promoter capacity, introducing clients to TPMs as potential investors. If a client elects to engage the service, they may enter into a separate advisory agreement directly with the TPM, open an account, and - if accepted - become a client of the referred manager. Compound does not have the authority to accept clients on behalf of any TPM, and TPMs are not obligated to accept any referred client. Each TPM retains full discretion to reject any prospective client for any reason. Compound’s role is limited to verifying that prospective clients meet the suitability criteria to become TPM clients, assessing whether they have investable assets, ensuring they possess a basic understanding of financial investing, and assisting clients in selecting appropriate managers and allocation models based on their unique needs. Compound may also support clients in completing their profile and suitability documentation, and in understanding the referred manager’s agreement. This process helps the TPM determine an appropriate allocation strategy for the client’s account. Written agreements between Compound and each TPM govern referral arrangements. These agreements define the scope of services, compensation structure, and any applicable referral fees. Clients will receive the following information at the time of referral: 13  1. A Solicitor Disclosure Statement, which includes the nature of the relationship between Compound and the TPM. 2. A description of any compensation received by Compound and/or its IARs. 3. Disclosure of any material conflicts of interest arising from the relationship or compensation arrangement. 4. Required disclosures such as the TPM’s Form ADV Part 2 and Privacy Policy. Clients should be aware that TPMs may charge higher fees when referral fees are paid to Compound. All disclosures are provided in accordance with SEC Rule 206(4)-3, the Marketing Rule, and applicable state regulations. Clients must acknowledge receipt of all required documentation prior to engagement. Compound will only refer clients to investment advisers appropriately registered with the SEC or applicable state(s), and only to those individuals or entities deemed suitable for the services. The TPM assumes full responsibility for portfolio management, trade execution, reporting, and custody-related functions for assets under its management. Client assets will be held by the TPM’s independent Qualified Custodian, who safeguards the portfolio and executes transactions per the TPM’s instructions. Unless otherwise directed, clients will enter into a separate agreement with the custodian to establish the custodial account. Compound does not maintain physical custody of client assets or income derived from the TPM custodial account. The client is responsible for any custodial fees and expenses. Compound is not liable for any actions or omissions of the TPM or custodian, nor for any fees, charges, or costs associated with the referred account, including brokerage or custodial fees. Clients are encouraged to review all disclosure documents carefully and to understand the terms of the TPM’s investment management agreement, including fees, account management, and termination provisions. The following externally managed service is also available under this advisory services option: Cash Management Program As part of its Third-Party Adviser Management Referral Services, Compound offers a Cash Management Program designed to enhance returns and provide increased Federal Deposit Insurance Corporation (“FDIC”) insurance protection on large cash balances. Under this program, and as appropriate, clients will be referred to a third-party provider for a cash management solution. The third-party provider is responsible for selecting program banks, allocating deposits across multiple banks to ensure client funds remain within FDIC insurance limits, and safeguarding the cash or funds up to the applicable insurance thresholds. Clients are federally insured up to $125 million in accounts, with next-day liquidity and no transaction fees or redemption gates. To engage in this service, clients will execute a Cash Management Referral Agreement, which outlines the scope of services, applicable terms, and any referral-related disclosures. The agreement will also specify the roles and responsibilities of the third- party provider, including custody, allocation, and reporting functions. Compound does not maintain custody of client assets under this program and is not responsible for the actions or omissions of the third-party provider or custodian. The minimum investment requirement for a third-party cash management portfolio is $250,000, although the referred adviser may waive this minimum at their discretion. Clients are encouraged to review all disclosure documents carefully, including the referred provider’s Form ADV Part 2, privacy policy, and any applicable Solicitor Disclosure Statement, which will detail the nature of the relationship, compensation arrangements, and any material conflicts of interest. Institutional Advisory Services Compound’s Institutional Advisory Services are specifically tailored to support the distinct needs and circumstances of institutional clients, including businesses and their pension and retirement plans. These services are typically delivered in collaboration with other professionals and encompass a broad range of offerings, including ERISA, Retirement & Employee Benefit Plan Services for the investment management of pension and profit-sharing plans, 401(k) plans, 403(b) plans, SEP IRAs, SIMPLE IRAs, non-qualified deferred compensation plans, asset protection strategies, executive salary continuation plans, cross-purchase and stock redemption agreements, and employee advisory services and Sub-Advisory Services For Other Financial Institutions. Similar to other advisory services, the scope of work, specific services to be provided, and terms of the engagement will be clearly outlined in the applicable written Advisory Agreement executed between the Institutional client and Adviser, which will also specify the final agreed-upon advisory fees, the formula for calculating such fees and any refunds (as applicable), and the 14  type of investment management authority granted. Periodic reviews of the advisory services will occur to confirm that they remain aligned with the evolving needs of the institutional client. ERISA, Retirement & Employee Benefit Plan Services Under this advisory service option, Compound offers specialized investment advisory services for trustees and other fiduciaries, including those defined as "fiduciaries" under the Employee Retirement Income Security Act of 1974 ("ERISA") or employee benefit plans subject to ERISA. These services may include the development and documentation of investment policy statements, investment due diligence, education, and ongoing advisory and management services, all in full compliance with ERISA. We provide tailored institutional ERISA, retirement, and employee benefit plan services for clients with employee benefit plans or other retirement accounts, such as individual retirement accounts ("IRAs"), for a fixed fee. Compound may recommend that clients withdraw the assets from their employer's retirement plan and roll them over to an IRA that we will manage on their behalf. If clients elect to roll the assets to an IRA subject to our management, Compound will charge an asset-based advisory fee as outlined in the client's Advisory Agreement with our firm. In this capacity, we are considered a fiduciary under ERISA and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards as defined by ERISA. In this role, and for purposes of complying with the Department of Labor’s Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), where applicable, clients should be aware of the following: When we provide investment advice to you regarding your retirement plan or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable laws governing retirement accounts. How we are compensated conflicts with your interests, so Compound operates under a special rule requiring us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: follow policies and procedures designed to ensure that we provide advice that is in your best interest, charge no more than is reasonable for our services, and ● meet a professional standard of care when making investment recommendations (give prudent advice), ● never put our financial interests ahead of yours when making recommendations (give loyal advice), ● avoid misleading statements about conflicts of interest, fees, and investments, ● ● ● give you basic information about conflicts of interest. Compound benefits financially from the rollover of a client’s assets from a retirement account to an account we manage or provide investment advice for because the assets increase our assets under management and, in turn, our Advisory Fees. Our policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to an IRA subject to our management, they will be charged an Advisory Fee as outlined in their executed ASA. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are not obligated to have their retirement assets managed by us. Finally, we will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer. When establishing ERISA accounts, Compound will have plan fiduciaries for discretionary accounts, provide evidence of their authority to retain our advisory services and appoint us as an "investment manager" within Section 3(38) of ERISA for those plan assets that comprise the client's account. They will confirm that the services described in our Agreement are consistent with plan documents and furnish accurate and complete copies of all records that establish and govern the plan. If an established plan account contains only partial plan assets, as ERISA requires, the client will acknowledge that Compound has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. If ERISA or other applicable law requires bonding for the account's assets, we will confirm that bonding is in place to satisfy the obligation to cover Compound and all Associates whose inclusion is expected by law. 15  Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. IRA Rollover Considerations When considering an IRA rollover, clients must understand the distinctions between account types to make an informed decision about whether a rollover is the most suitable option for their situation. Many employers allow former employees to retain their retirement assets in their company plans, and current employees may sometimes transfer assets from their company plan even before retirement or job changes. Financial Intermediaries will assess various factors before recommending a retirement plan rollover, including, but not limited to: (1) the investment options available within the current plan versus those offered through us, (2) comparative fees and expenses, (3) the quality and responsiveness of the plan's investment professionals versus our services, (4) required minimum distributions, (5) age-related considerations, and (6) any potential tax implications associated with employer stock, if applicable. To the extent the following options are available, clients should carefully consider the costs and benefits of the following: leaving the funds in the employer's/former employer's plan, ● ● moving the funds to a new employer's retirement plan, ● ● cashing out and taking a taxable distribution from the plan, and rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for management are encouraged to speak with their CPA or tax attorney before making a change. The following are additional points for consideration prior to taking action: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might wish to consider other investment types: - Employer retirement plans generally have a more limited investment menu than IRAs. - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Consider plan fees - your current plan may have lower fees than Compound’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. - Confirm you understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. 3. Our strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. - Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed anytime; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 9. 10. Your plan may allow you to hire Compound as the manager and keep the assets in the plan name. 16  Sub-Advisory Services For Other Financial Institutions Compound provides Sub-Advisory Services for Other Financial Institutions seeking specialized investment strategies, operational support, or portfolio management expertise. Depending on the option selected, clients receiving services under this model will engage with Compound directly or indirectly through the partnering institution. In most cases, the formal sub-advisory agreement is executed between Compound and the financial institution, and not with the end client. However, where Compound is designated as the direct adviser, clients will execute an Advisory Agreement with Compound, which outlines the scope of services, applicable fees, and required disclosures. All sub-advisory relationships are subject to Compound’s fiduciary standards, compliance oversight, and suitability review procedures in accordance with its Code of Ethics and regulatory obligations. SyntheticFi LLC Securities-Backed Lending Program Compound offers a Securities-Backed Lending Program through a sub-advisory relationship with SyntheticFi LLC (“SyntheticFi”), an SEC-registered investment adviser. This program is designed for eligible clients seeking access to liquidity through synthetic loan contracts, which are structured using option-based box spreads. To engage in this service, clients will execute a Securities-Backed Lending Referral Agreement, which outlines the scope of services, applicable terms, and disclosures. SyntheticFi is responsible for structuring and facilitating the synthetic loan transactions, including trade execution and reporting. Compound may allocate client assets to SyntheticFi Borrowing at its sole discretion, based on suitability and client objectives. Compound does not maintain custody of client assets under this program and is not responsible for the actions or omissions of SyntheticFi or any affiliated custodian. Clients are encouraged to review all disclosure documents carefully, including SyntheticFi’s Form ADV Part 2, privacy policy, and the executed Referral Agreement, which will specify the terms of the lending arrangement, applicable fees, and any limitations or risks associated with the strategy. Compound’s discretion to allocate assets to SyntheticFi creates a potential conflict of interest due to a revenue-sharing arrangement, as disclosed in Item 14: Client Referrals & Other Compensation of this brochure. Compound mitigates this conflict by conducting suitability reviews and disclosing the arrangement to clients in accordance with its Code of Ethics, which requires full disclosure of any material conflicts of interest that may reasonably be expected to impact the objectivity or impartiality of the advice provided. A copy of Compound’s Code of Ethics is available upon request at no charge. Franklin Managed Options Strategies Sub-Advisory Program Through its sub-advisory relationship with Franklin Managed Options Strategies, LLC (“Franklin Managed”), Compound offers clients access to the Franklin Managed Options Strategies Sub-Advisory Program. This service is designed for eligible clients seeking professionally managed options strategies, which may include covered and uncovered options, exchange-traded funds, and other instruments, as specified in the applicable strategy guidelines. Franklin Managed provides discretionary management of client accounts allocated to its strategies, with all investment decisions made in accordance with defined objectives and restrictions. To engage in this service, clients will execute an investment advisory agreement that outlines the scope of services, applicable terms, and disclosures. Franklin Managed is responsible for the discretionary management of client accounts allocated to its strategies, including trade execution and reporting. Compound may allocate client assets to Franklin Managed at its sole discretion, based on suitability and client objectives. Compound does not maintain custody of client assets under this program and is not responsible for the actions or omissions of Franklin Managed or any affiliated custodian. Clients are encouraged to review all disclosure documents carefully, including Franklin Managed’s Form ADV Part 2, privacy policy, and the executed advisory agreement, which will specify the terms of the options management arrangement, applicable fees, and any limitations or risks associated with the strategy. Compound’s discretion to allocate assets to Franklin Managed creates a potential conflict of interest due to the affiliation between Franklin Managed and FTFH, a strategic investor in Compound. While Compound offers other options strategy providers, and does not receive any incentive or compensation to select one provider over another, the affiliation presents a material conflict. Compound mitigates this conflict by conducting ongoing due diligence on all providers, selecting options strategies based solely on the best fit for the client, and upholding its fiduciary duty at all times. All material conflicts of interest are disclosed to clients 17  in accordance with Compound’s Code of Ethics, which is available upon request at no charge. Educational Seminars & Workshop Services Compound hosts complimentary Educational Seminars & Workshop Services for various audiences, including clients and prospects, and is sometimes asked to provide speakers for financial educational speaking engagements, community events, and conferences on various investment topics on an "as-announced" basis for groups seeking general instruction on investments and other personal finance areas. Content will vary depending upon the attendees' needs, is intended to be purely educational, and will not involve selling any investment products. The information presented will not be based on any individual’s needs. Compound will not provide personalized investment advice to attendees during such events. The Adviser will only provide such investment advice if engaged independently and only where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes and will not offer specific accounting, investment, legal, tax, or professional advice. Further, attendees have no obligation to schedule a consultation, purchase services from Compound, or become clients. (See Item 5: Fees & Compensation for additional details.) Types of Investments Compound provides investment and portfolio management advice across a broad range of asset classes, including equities, corporate debt, exchange-traded funds (“ETFs”), U.S. government securities, mutual funds, insurance products, and alternative investments. While these are the primary instruments used, Compound reserves the right to advise on other suitable investments based on each client’s specific goals, financial circumstances, and risk tolerance. Advice may include recommendations on existing holdings and portfolio diversification strategies. Compound does not engage in market timing but may increase cash allocations when deemed appropriate based on market conditions or client needs. In addition to traditional investment vehicles, Compound may offer access to specialized strategies and programs designed to address specific client objectives, such as customization, liquidity, or tax efficiency. These strategies are subject to eligibility requirements and may involve unique risks, which are disclosed in the relevant sections of this brochure and accompanying agreements. Tailored Advisory Services Compound offers a comprehensive suite of services to all clients, though some may require only limited services based on the nature of their investments. In such cases, limited services are offered at our discretion, as outlined in the client's written Agreement, which will contain applicable terms and Fee Schedules. Compound reserves the right to advise on any investment product deemed suitable for a client’s individual circumstances, needs, and objectives, which may include advising on those already held in a client’s portfolio at the outset of the advisory relationship. Additionally, when appropriate, we may recommend other securities to help diversify a portfolio. (For further information, see Item 5: Fees & Compensation and Item 8: Methods of Analysis, Investment Strategies & Risk of Loss.) Client Imposed Restrictions Clients have the right to impose restrictions on the types of securities or specific securities in which they wish to invest based on personal preferences, values, or beliefs. Such restrictions must be provided to the Adviser in writing and accepted prior to implementation. Clients may modify or amend these restrictions by submitting updated written instructions. Restrictions will only take effect once formally accepted. Compound will make reasonable efforts to adhere to client-imposed investment guidelines, including any reasonable limitations consistent with standard industry practices. However, clients should be aware that such restrictions may influence the performance of their accounts, potentially resulting in performance variations - both positive and negative - compared to similar accounts without such limitations. Additionally, these restrictions could hinder the achievement of a client's specific financial objectives. Upon receipt of written restrictions, Compound will assess the feasibility of the request, ensure that the client’s expectations are appropriately managed, and confirm that the client understands the potential consequences of the imposed restrictions. Compound reserves the right to reject specific restrictions or terminate the advisory relationship if such restrictions cannot be reasonably accommodated. In no event, irrespective of the advisory service provided, shall Compound be obligated to make any investment or engage in any transaction that, in its reasonable and good faith judgment, would violate any applicable federal or state law or regulation. 18  Wrap Fee Programs A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client's Account are charged for investment supervisory services, which may include portfolio management or advice concerning the selection of other investment advisers and the execution of client transactions. Compound does not offer a wrap fee program as part of its advisory services. Assets Under Management Compound offers its advisory services on a discretionary and non-discretionary basis. As of August 31, 2025, our client assets under management total $4,301,591,496. The following represents assets under management by account type: Type of Account Assets Under Management Discretionary Non-Discretionary Total $4,301,591,496 $ 0 $4,301,591,496 Item 5: Fees & Compensation __________________________________________________________________________________________________________________________ Adviser Fee Structure & Compensation Overview Standard Fee Structure Under Compound’s Standard Fee Structure, advisory clients agree to pay either a recurring, asset-based advisory fee based on assets under management (“AUM”) or a flat fixed, one-time or hourly fee arrangement depending on the advisory services selected, calculated and billed according to the schedules reflected herein, with any applicable refunds addressed as specified in the client’s finalized written and executed Advisory Agreement. Regardless of the fee structure selected, total fees for advisory services will not exceed the specified cap. Note that clients may incur fees such as third-party investment manager fees or custodial fees in addition to advisory fees. ● For qualified and non-qualified clients (as defined under Rule 205-3 of the Investment Advisers Act of 1940), total advisory fees will not exceed 2% of AUM. Fee Negotiation Availability Advisory fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by Compound, with the yearly maximum rate specified in the client’s written and executed Agreement. Compound, at its sole discretion, may reduce or waive fees based on various factors, including, but not limited to, the client’s pre-existing relationship with the Adviser, the total assets under management, inception date, number of accounts and account composition, expected future assets, the complexity of the client's personal situation, and the client's earning capacity. Other factors are also considered, such as the complexity of investment strategies, frequency of desired meetings or special reporting needs, anticipated future earning capacity, and client negotiations. In some cases, accounts held by the client, their family members, or related parties may be aggregated for fee calculation purposes. As a result, advisory fees will vary, and clients with similar circumstances can reflect different fee structures. While Compound seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients can pay higher (more) or lower (less) fees than other clients for services than if they had contracted directly with another provider. Lower fees for comparable services can sometimes be available from other sources. In all cases, clients are responsible for any tax liabilities that result from any transactions. Regardless of fee negotiation availability, under no circumstances will a client be required to pre-pay a Compound advisory fee more than six months in advance, in excess of $1,200. Advisory Fee Calculation, Billing & Refunds Compound follows the process outlined below for assessing, billing, collecting, and issuing refunds related to advisory services 19  fees: Fee Calculation AUM-Based Services Compound advisory services fees are billed on a monthly, quarterly, or engagement basis, either quarterly in advance or monthly in arrears (a "billing cycle"), as specified in the client’s written and executed Agreement, based on the selected advisory service. If billed quarterly in advance, the client’s initial bill for AUM-based services will be prorated based on the number of days the account was open and funded during the applicable billing cycle, with "funded" referring to the first deposit of money into the AUM account. For non-investment-related advisory services, such as financial planning, consulting, or fixed and hourly fee arrangements, fees are separately billed, as indicated in the Advisory Agreement. Compound reserves the right to: 1. invoice in advance based on an annual or semi-annual period, at its discretion, and charge the appropriate fee for such periods, 2. negotiate fees at its discretion, and 3. modify the fee schedule with a minimum of thirty (30) days' prior written notice to the client, subject to the client’s right to object and terminate the agreement. It is important for clients to understand the impact of fees on their investment portfolio. Ongoing advisory fees, when deducted from a client's investment portfolio, will reduce the total assets available for generating returns. As a result, clients may experience a reduction in their portfolio’s growth over time. We encourage clients to discuss the impact of these fees with their Financial Intermediary. Assets Under Management For the purpose of determining assets under management (“AUM”), assets include all U.S. and non-U.S. securities, cash, and other instruments in a client’s account, as advised by Compound’s Financial Intermediaries. Fees are calculated on a per-account basis unless accounts are designated as part of a household, as Compound determines in its sole discretion. Compound will adjust its advisory fee to reflect contributions and withdrawals to and from accounts on a time-weighted basis. Thus, a net contribution during a quarter will decrease the total fee amount, while a net withdrawal will increase the fee amount. Advisory fees may be calculated based on the actual number of days in a calendar quarter or four even calendar quarters, depending on the billing method chosen. (See Account Additions, Withdrawals & Terminations for additional information.) Cash Balances Compound considers cash to be an integral asset class within its investment strategies. Depending on market conditions, the Adviser may allocate assets to cash positions for varying durations. As such, cash balances are included in the total value of assets under our management, which serves as the basis for calculating our advisory fee unless otherwise specified in the Advisory Agreement (i.e., outstanding margin balances). The advisory fee billed on the cash portion of client accounts can exceed the yields of money market funds, particularly when such yields are lower than the advisory fees charged to the account. Compound typically invests client cash balances in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit, utilizing the exclusive cash vehicle (money market fund) made available by the custodian. Other cash management options may be available away from the custodian, with higher yields or safer underlying investments. In most cases, at least a partial cash balance will be maintained in a money market or FDIC-insured deposit account to allow for the debit of advisory fees or anticipated cash distributions to clients. We will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Please Note: Investment products are typically not insured or otherwise protected by the FDIC, the Federal Reserve Board, or any other government agency. Additionally, they are not deposits or obligations of, nor are they guaranteed by, Compound or any of its affiliates. All investments carry inherent risks, including the potential loss of the principal amount invested.) NAV Unless otherwise specified in the Advisory Agreement, advisory fees are calculated based on the net asset value (“NAV”) of the 20  client’s account. The NAV includes assets in cash, cash equivalents, accrued interest, and dividends, but excludes outstanding margin balances. Fees are typically billed based on the period-end value of the account during the billing period, according to the terms specified in the client’s agreement. To calculate NAV, any outstanding margin balances are subtracted from the total asset balance, while non-purpose loan balances are not deducted. The NAV is calculated on the last business day of the month preceding the billing cycle or, in some cases, quarterly, depending on the terms specified in the client’s Agreement. (See Valuation for additional information.) Valuation Securities for which a readily available market price is not accessible are valued at fair value, as determined in good faith by the custodian. If a custodian does not value the account or any asset, or if we determine a custodian's valuation of the account or an asset is materially inaccurate, we will value the account or such asset in good faith to reflect its fair value. Money market accounts and bank accounts, if any, shall be valued as of the valuation date. Unsettled transactions may be included in either the current or the following period, as determined for the account maintained with each custodian consistently. For clients with assets maintained with more than one custodian (or in more than one of our advisory services programs), we will typically calculate the value of accounts and the advisory fees separately for each advisory service program and custodian as we determine in our discretion; however, in our sole discretion, we may also aggregate the values for purposes of achieving any discounts which may be available under our Fee Schedule(s). The valuation method and periods used to value the account and calculate the advisory fees will be applied consistently for each custodian. Still, they may differ from the valuation method and periods used to value the account or calculate the combined advisory fees of other custodians. For client account assets in alternative investments, the alternative investment managers and underlying vehicles are responsible for providing the custodian with an asset's valuation following applicable laws and industry standards. For illiquid investments, Compound will calculate the value for billing and reporting purposes based on the valuation published by the investment sponsor, typically the entity managing the investment or fund. The Adviser does not utilize alternative valuation methods, including those derived from auction sites, secondary markets, tender offers by third parties or the investment sponsor, or valuations provided by third-party research providers. The timeliness of valuation reporting by sponsors varies, with updates occurring on different schedules (i.e., daily, monthly, quarterly, or annually). Some sponsors may only update valuations when a liquidity event occurs. Compound will typically use the valuation available as of the last day of each calendar month. If the sponsor does not provide an updated valuation, we will use the valuation from the prior billing cycle. It is important to note that the underlying or intrinsic value of an illiquid investment may differ from its published valuation. (For example, an increase in the net operating income of an investment property may lead to an appreciation in value relative to the last published valuation, while vacancies in the property may cause a decrease in value.) Given the volatility of illiquid investment valuations and the speculative nature of attempting to assess their true value, the Adviser does not reconcile discrepancies between the fees charged (based on the sponsor's published valuation) and a potentially more accurate fee derived from alternative valuation methods. As a result, we may charge fees that are higher or lower than the fair market value of the underlying investments. Method of Advisory Fee Payment Clients have several options to pay their Compound advisory fees and will indicate their preference on the Agreement they execute with us. The client may choose to have our advisory fees (1) directly debited from their account assets held at their custodian or (2) billed and be responsible for remitting their payment themselves. The process for each payment option follows: 1. Directly Debited Fees - Clients who wish to have their fees directly debited will provide written limited authorization instructions to their custodian, directing them to allow Compound to withdraw any advisory fees due. The limited authorization will authorize the Adviser to invoice the custodian directly for the client's advisory fees and instruct the custodian to debit any fees from the client's custodial account automatically. After each advisory fee payment transfer, the written instructions will also request that the custodian provide a "transfer of funds" notice to the client at their custodial address of record. The client may provide these instructions on the Qualified 21  Custodian's form or separately. The custodian will maintain actual custody of the client's assets. Compound will calculate the advisory fees owed based on the terms specified in the client's Agreement, and the custodian will remit payment to us as instructed. Upon receiving Compound’s instructions, the Qualified Custodian will automatically deduct and pay us from the client’s custodial account the fee amount due for the billing period. The account custodian does not verify the accuracy of our advisory fee calculation. Regardless of the market performance of the portfolio during the fee period, fees will be assessed as outlined in the Agreement. Compound’s account advisory fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from liquidating a portion of the client’s securities holdings. Additionally, the custodian will send the client a statement reflecting the fee amounts paid, which will be delivered to the client’s address of record or another authorized address designated in writing by the client. Compound may also charge an alternative payment method on file instead of deducting it from a client’s custodial account. 2. Billed Fees - Clients who prefer to be directly billed must authorize this payment method in writing as part of their Agreement. Under this arrangement, clients will receive advisory fee invoices from us for the advisory fees due, with payment due upon receipt. Clients will make their payments directly to Compound via check or credit card. Under no circumstances will such advisory fees be deducted from a client’s custodial account(s) unless directed otherwise by the client in writing. Payment for non-investment-related services may be made by credit card or check made payable to "Compound Planning." (Note: Checks should never be made out to any individual representative of the Adviser.) Please also note that when authorized by the client to debit advisory fees from client accounts, under the SEC’s Custody Rule, Compound is deemed to have custody of client assets to the extent that the adviser has the authority to instruct custodians to withdraw these fees directly from the client's account. As such, we are required to comply with all applicable requirements, including providing clients with account statements and ensuring proper safeguards are in place. Compound encourages clients to promptly review any statements received from their custodian(s) to ensure the accuracy of account transactions. Clients are advised to compare their account's investment performance with the relevant benchmark for the types of investments held, as well as any reports or information we provide. We strongly recommend that clients also compare their custodian account statements with any portfolio reports or data we supply upon receipt. Discrepancies may arise between our reports and custodian statements due to differences in accounting procedures, reporting dates, or valuation methodologies applied to specific securities. Should a client identify any discrepancies between our reports and custodian statements, they are encouraged to contact both us and their custodian directly. If a client does not receive statements directly from the custodian, we recommend reaching out to the custodian in addition to notifying their IAR. In all instances, clients should contact us promptly with any concerns regarding account activity before the next billing cycle and provide written follow-up. Failure To Timely Remit Payment If the client fails to remit payment for any outstanding fees within thirty (30) days from the billing date, the Adviser reserves the right to assess interest on the overdue amount at the maximum rate allowed by law. Compound is entitled to recover any costs incurred in the collection of the fees and interest, including reasonable attorney’s fees, for all outstanding amounts due. Unaffiliated Financial Intermediary Fees The following applies to clients engaging Compound through unaffiliated Financial Intermediaries across various service offerings: Compound’s Sub-Advisory Fee is separate from, and in addition to, the fees charged by unaffiliated Financial Intermediaries for their advisory services. These fees typically range from 0.80% to 2.00%, depending on the scope, structure, and delivery of services. In certain cases, clients whose Financial Intermediary provides or outsources specific services may incur a lower overall cost. 22  Unaffiliated Financial Intermediary fees may apply across various service offerings where Compound provides sub-advisory, investment management, operational support, or platform services. These arrangements may include - but are not limited to the Turnkey Asset Management Programs (“TAMPs”), separately managed accounts (“SMAs”), retirement plan services, and institutional advisory relationships. Clients should review the Financial Intermediary’s Disclosure Brochure for a detailed breakdown of their fees, including the methodology used for fee calculation and any applicable tiering or service-based adjustments. Unaffiliated Financial Intermediaries are responsible for ensuring that Compound is authorized to debit its sub-advisory fees directly from the client-designated account. In the event of account termination prior to the completion of services, any prepaid, unearned advisory fees will be prorated based on services rendered to date and promptly refunded to the client, in accordance with the termination provisions outlined in the Advisory Agreement. (See Account Terminations for additional information.) Specific Advisory Services Fee Schedules The following section outlines the fee schedules for specific advisory services and other important considerations for clients regarding our fees and compensation. SyntheticFi Securities-Backed Lending Program Clients participating in the SyntheticFi Securities-Backed Lending Program will pay an advisory fee to SyntheticFi, calculated based on the value-at-expiration of the synthetic loan contracts. Compound does not receive compensation from SyntheticFi based on capital gains or appreciation of client assets; however, the firm may receive reimbursement payments from SyntheticFi for marketing, education, and support services pursuant to a revenue-sharing addendum. These payments are calculated as a percentage of the synthetic loan size and disclosed in Exhibit I of the SyntheticFi agreement. The reimbursement payments create a financial incentive for Compound to recommend the SyntheticFi program. Compound addresses this conflict by disclosing the arrangement to clients and updating this Form ADV and other disclosures accordingly, and fully disclosing this arrangement to clients prior to the commencement of services. A copy of the firm’s Code of Ethics is available for review free of charge upon request. Franklin Managed Options Strategies Sub-Advisory Program Under the Franklin Managed Options Strategies Sub-Advisory Program, Franklin Managed is compensated via a management fee, as detailed in the relevant Strategy Account Specifics. The management fee is typically less than 1% per annum of assets under management, as agreed-upon between the client and the Franklin Managed and documented within the Agreement between the parties, paid directly from client accounts by the custodian or via invoice to Compound. These fees are distinct from brokerage, settlement, and custody fees, which are charged separately to the account. Franklin Distributors, Inc., an affiliate of Franklin Managed, may receive compensation in relation to this agreement. The receipt of compensation by Franklin Managed and its affiliates presents a potential conflict of interest. Compound mitigates this conflict by fully disclosing all fees, ensuring transparency, and not receiving any compensation for provider selection. No soft dollar arrangements are permitted. Turnkey Asset Management Program (“TAMP”) Services Fees The advisory fee for Turnkey Asset Management Program Services is assessed monthly, either in advance or in arrears, as specified in the client’s executed Agreement and based on the scope of services outlined in the TAMP Agreement. Fees are based on the TAMP Fee Schedule below and calculated based on the range of investment management services provided. These services may include, depending on the Financial Intermediary’s selection, asset allocation assistance, style allocation guidance, research and evaluation of investment strategies and funds, account rebalancing, performance calculations, reporting, billing administration, and other operational and administrative services. TAMP Fee Schedule Advisory Service Annual Fee Rate Range For AUM Under Management TAMP Platform At a minimum, 25 bps (0.25%) of the AUM or $60.00 per year, whichever is higher In-House Models 15 bps (0.15%) of the AUM per year Third-Party Models 0 bps to 200 bps (0-2.0%) of the AUM per year 23  Intermediary as Portfolio Manager 5 bps (0.05%) of the AUM per year Alternative Investment Strategies 35 bps (0.35%) of the AUM per year Note: Lower fees for comparable services can sometimes be available from other sources. Prior to engaging in any of the above advisory services, clients are responsible for reviewing all applicable fees and costs associated with the selected service. They are strongly encouraged to ask questions and consult with their outside advisers to ensure a full understanding of the total fees and expenses they will incur. All fees, costs, and potential conflicts of interest are fully disclosed in the applicable agreement and related documents. Compound’s portion of fees will not exceed any relevant legal or regulatory limitations. Compound is committed to transparency and regulatory compliance and strives to uphold its fiduciary duty by ensuring that clients receive clear, comprehensive information regarding all costs and compensation arrangements. Clients should carefully review all disclosure documents, including the Form ADV Part 2, privacy policy, and the executed advisory agreements provided in connection with their selected service, and seek independent advice as needed to make informed decisions. Investment Management Services Fees Investment Management Services fees follow the Adviser’s Standard Fee Structure. Unaffiliated Financial Intermediaries are responsible for ensuring that Compound is authorized to debit the fees from the client-designated accounts directly. Similar to the TAMP services, in the event of account termination prior to the completion of services, any prepaid, unearned advisory fees will be prorated based on the services rendered to date and promptly refunded to the client, following the provisions of the Advisory Agreement. Financial Planning & Consulting Services Fees Typically, initial Financial Planning & Consulting Services engagements are quoted as either a fixed project-based fee for standalone financial planning or consulting services of $500 up to $10,000 or, at the Adviser’s discretion, an hourly fee ranging from $100 to $500 per hour, depending on the time and materials required. If clients engage us for additional advisory services, Compound may discuss the possibility of offsetting a portion of its fees based on the fees and services provided in the client’s other engagement(s). Payment for non-investment-related services may be made by credit card or check made payable to "Compound Planning." Checks should never be made out to any individual representative of the Adviser. With respect to the fees and practices for each service option, the structure of fees will be determined based on the specific services selected by the client, as follows: Financial Planning Services Fees Financial Planning Services fees are based on an estimate of the total number of hours and expected cost to provide the Financial Plan, as outlined and agreed upon in the Financial Planning Services Agreement prior to the commencement of services. The following terms and conditions apply to these fees: 1. Compound charges an upfront retainer fee equal to 50% of the total estimated cost, which will be applied toward future hours worked. 2. The remainder of the balance will then be due within 30 days of the presentation of the financial plan or the agreed conclusion of the service(s). 3. Any services exceeding the initial agreed-upon estimate require advance written notice to the client of the proposed scope of work and additional charges, along with client approval to proceed. 4. The remaining balance is due upon delivery and presentation of the completed plan. 5. Any applicable travel expenses will also typically be collected. (Note: Extraordinary travel expenses are rarely incurred. However, in certain circumstances, such as when a client requests a meeting at their out-of-state vacation home, the Adviser may incur additional costs for plane flights, hotel accommodations, rental cars, or other related expenses. These costs will be discussed and agreed upon with the client in advance.) 24  A financial plan is considered to include the time required to gather, assemble, and present the completed written initial financial plan and excludes any ongoing plan updates, revisions, changes, or travel expenses that would be deemed above extraordinary, which will be separately quoted as needed, prior to the client's acceptance. It is Compound’s policy not to have an initial financial plan that takes more than six (6) months to complete from the date of the Financial Planning Agreement execution. If services are not completed within this timeframe, any prepaid unearned fees will be prorated, with a deduction for bona fide financial planning services rendered to date. (See Account Terminations for additional information.) Ongoing Financial Planning Updates Clients may request updates or additional reviews after receiving their financial plan, which may incur additional fees based on the firm’s current hourly rate. Revisions will be made based on the original plan and will take into account any changes in the client’s financial, tax, or legal circumstances. The client will be provided with an updated fee quote for review and acceptance based on the anticipated time required to review, adjust, and present the revised plan. All terms and conditions related to plan update services will be outlined in a new Financial Planning Services Agreement. Fees for subsequent updates are due at the beginning of the term during which the services will be provided. All Financial Planning Services terminate upon completing the deliverable as described within each executed Services Agreement. Alternatively, either party may terminate the Services Agreement at any time upon written notification. Consulting Services Fees Consulting Services fees are determined in a manner similar to those for Financial Planning Services. The IAR will consider factors such as the nature of the services to be provided, the frequency of client meetings and other interactions, the overall scope of services over the agreed-upon period, as well as intermediate and long-term considerations, the prospect for future investment management services, and the cost of providing the additional financial services selected by the client. Based on these factors, an estimated service cost will be provided to the client for review and acceptance prior to entering into the Consulting Services Agreement. If services and the scope of work are not completed within the agreed-upon timeframe, any pre-paid unearned fees will be prorated, with a deduction for bona fide financial planning services rendered to date. Consulting Services terminate upon completing the services described within each executed Services Agreement. Alternatively, either party may terminate the Services Agreement at any time upon written notification. Compound recognizes that a potential conflict of interest may arise in the course of providing Financial Planning & Consulting Services, particularly if such services lead to recommendations for products or services from which the Adviser or its Associates may receive compensation. Clients are under no obligation to act upon any recommendations made by Compound, nor are they required to execute transactions through the Adviser or any affiliated individual if they choose to implement the recommendations. In accordance with Compound’s policy and Code of Ethics, any material conflicts of interest related to the Adviser, its representatives, or any affiliated personnel that may reasonably be expected to impact the objectivity or impartiality of the advice provided will be fully disclosed to the client prior to the commencement of services. A copy of the firm’s Code of Ethics is available for review free of charge upon request. (See Account Terminations for additional information.) Third Party Adviser Management Referral Services Clients are advised that under this advisory service option, the referred Third-Party Managers may charge fees in addition to those disclosed herein. The advisory fees charged by a referred adviser are outlined in the Form ADV disclosure brochure provided by the adviser to whom clients are referred. These fees may or may not be negotiable; the TPM typically reserves the right to reduce or waive such fees at its discretion. Clients are strongly encouraged to review the referred adviser’s disclosure documents and agreement and consider both the referred adviser’s fees and our fees to fully understand the total costs associated with this advisory service option prior to engaging with the referred adviser. Additional fees may also apply to client account transactions and investments within the referred adviser’s portfolio model(s). These fees will be deducted from the client’s account assets in addition to the fees paid to us and the third-party referred adviser. Compound does not receive any portion of the commission fees or transaction costs associated with the referred client accounts. 25  Any additions, withdrawals, or terminations from referred advisory accounts may be governed by a separate agreement between the client and the referred adviser. This agreement will remain in effect until terminated by either the client or the referred adviser in accordance with its terms. The referred adviser is responsible for refunding any unearned service fees as outlined in the agreement. If the total value of the client’s account(s) falls below the minimum threshold for continued service or withdrawal, the referred adviser may terminate the agreement. Clients are strongly encouraged to review all relevant disclosure documents, investor profiles, and the agreement with the referred adviser before participating in the program. Institutional Advisory Services Fees for Institutional Advisory Services are billed and payable according to Compound’s Standard Fee Structure, as outlined in the applicable Advisory Agreement. These services may include investment management, operational support, and marketing services provided to financial institutions, retirement plans, and other entities. In certain cases, Compound may also offer access to specialized investment programs, such as securities-backed lending solutions structured through synthetic loan contracts, which are facilitated via third-party providers under sub-advisory agreements. Clients should refer to their executed Agreement for complete details regarding the scope of services, applicable fees, and any referral or revenue-sharing arrangements. In the event of account termination prior to the completion of services, any prepaid, unearned advisory fees will be prorated based on the services rendered to date and promptly refunded to the client, in accordance with the termination provisions of the Advisory Agreement. (See Account Terminations for additional information.) Educational Seminars & Workshops Services Fees Compound’s Educational Seminars & Workshop Services are offered at no cost to clients. Account Additions, Withdrawals & Terminations Clients can make additions to their Compound accounts in cash or securities at any time. Compound reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account, according to the type of authority granted to Compound. If Compound liquidates transferred securities, clients can be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level, such as contingent deferred sales charges, and tax ramifications. Clients can make withdrawals from their Compound accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures and costs. Additionally, if the client transfers their account to another firm, they can pay an outgoing account transfer fee to the Custodian. Generally, terminations of Compound’s advisory services may be made without penalty by providing written notice, either electronically or via certified mail, within five (5) business days of the Agreement’s execution date. Thereafter, the Agreement will continue in effect until either party terminates following the terms of the Agreement through similarly provided written notice. Termination shall become effective on the business day the written notice is received by the other party. (Note: A "business day" is defined as any day when the New York Stock Exchange is open for trading.) Termination of the advisory agreement will become effective upon receipt of notice from the client and will not affect the following: ● ● ● the validity of any actions previously taken by the Adviser under the Agreement, the liabilities or obligations of the parties arising from transactions initiated prior to the termination, and the client’s obligation to pay any management fees or other fees due, prorated through the termination date. The termination of investment-related services will not affect any investments in securities or insurance products made by the client based on the Adviser’s recommendations. These investments will remain subject to the terms of their respective offering memoranda or contracts. Upon receipt of a termination notice, the Adviser will initiate the process of delivering cash and/or securities according to the client’s instructions. If securities are liquidated, the client may incur liquidation fees or contingent deferred sales charges. Market conditions at the time of liquidation may result in a loss, and additional fees may be imposed by the custodian or broker-dealer involved in the liquidation process. If the client holds alternative investments or illiquid securities, they may be subject to specific redemption schedules, which could delay the process. Upon termination of investment-related services, the client’s funds will remain in their positions as of the termination date. The Adviser will have no further responsibilities regarding the account(s) or positions held within those accounts. Clients may not be able to liquidate or redeem illiquid investments immediately, and some 26  illiquid investments may not be transferable to other advisory firms. Fee Reconciliation Process Upon termination, Compound will perform a fee reconciliation to determine if a net credit or net debit is owed to the client. The reconciliation will proceed as follows: For Accounts Billed In Arrears - A final fee, if applicable, will be debited to the client’s fee reconciliation statement. The fee will be calculated by multiplying the number of calendar days worked - defined as the period between the first day of the termination month and the effective date of termination- by the monthly AUM fee, converted into a daily rate - calculated based on the total number of days in the termination month. (It is important to note that third-party SMA Programs may automatically assess pro-rata management fees upon account termination.) For Accounts Billed In Advance - A refund will be credited to the client’s fee reconciliation statement. The refund amount will be calculated as the difference between the total number of calendar days in the termination month and the number of days worked, multiplied by the monthly AUM fee, converted into a daily rate. Some legacy agreements may specify a contingent management fee that will be debited from the client’s fee reconciliation statement based on the number of billing months that have occurred at the time of termination for alternative investments that offer a net asset value discount, a bonus, or a rebated advisor commission. If the client is a natural person, the client’s death, disability, or incompetency will not automatically terminate or alter the terms of the Agreement. The Agreement shall terminate immediately upon the Adviser’s receipt of proof of the client’s death, along with a written instruction from the client’s duly authorized representative to terminate the Agreement. In the case of the client’s disability or incompetency, while the Agreement remains in effect, the client’s authorized representative may terminate the Agreement by providing written notice to the Adviser. Prior to termination, all directions given or actions taken by the Adviser, or any omissions, will remain binding upon the client and any successor or legal representative. Upon termination, the Adviser will no longer be entitled to receive fees from the termination date and will have no further obligation to recommend or act in relation to the client’s securities, cash, or other investments under the terminated Agreement. Other Fees & Expenses Advisory fees are separate and distinct from other costs and expenses clients may incur in connection with their accounts. A list of some of these additional fees and expenses includes, but is not limited to, the following: Mutual Funds, ETFs & Pooled Investment Vehicle Fees Mutual funds generally offer multiple share classes available for investment based on specific eligibility and/or purchase requirements. If such investments are selected for a client's account, the client and all other shareholders will pay an advisory fee to the fund's investment advisers. In addition to those underlying advisory fees, the client will bear a proportionate share of the fund's expenses, including 12b-1 fees and shareholder sub-accounting and distribution costs. Each offering prospectus will describe the offering’s complete fees and expenses, which can vary depending on the share class. Fee and internal expenses can be higher or lower depending on the selected share class. Certain funds do not charge a transaction fee but have higher internal expenses. Choosing funds with higher fees and costs can adversely impact an account's long-term performance. The appropriateness of a particular fund share class selection depends upon several considerations. Further, not all funds and share classes offered to the public are available through Compound, which a client might otherwise be eligible to purchase. Clients should consider these and our investment fees to fully understand the total amount paid when evaluating the advisory services provided. Before recommending this type of purchase, an analysis will occur to determine whether the recommended fund share class is in the client's best interest. When recommending these investments, it is our policy to consider all available share classes and select and recommend, whenever possible, that clients invest in the lowest cost share class available based on the client’s needs and various other factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges and availability, among others. (For example, in addition to retail share classes - typically Class A, B, or C shares, mutual fund companies may offer institutional or other share classes specifically designed for purchase by investors who meet particular eligibility criteria. Institutional share class mutual funds typically cost less than other share 27  classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund.) Therefore, in most cases, recommendations will be for institutional / advisers share classes with the lowest expense ratios. These are less expensive than other share classes and are usually available to investors in qualified fee-based adviser programs or accounts meeting specific minimum investment requirements. When deemed appropriate for an investor's specific situation, recommendations may also include selecting or holding a mutual fund share class that charges higher internal expenses than other available share classes for the same family. For share classes transferred in from other institutions, as soon as practicable upon receipt, an evaluation will occur on whether more appropriate share classes may be available for the client to exchange at no cost and recommend that the client switches to a lower-cost share class or recommend liquidating the existing holdings, which could result in the client having to pay contingent deferred sales charges, or other redemption fees and tax implications. Despite such considerations, clients should not assume they will be invested in the share class with the lowest possible expense ratio. Fees Charged by Custodians & Other Financial Institutions In addition to the above, clients should also be aware that our advisory fees are exclusive of bank, custodial or brokerage fees, commissions, trading and transactional costs, liquidation/transfer/termination fees, costs associated with certificate delivery or dealer profits, taxes, duties, and other governmental charges on brokerage accounts and securities transactions, wire and other transfer fees, mark-ups, mark-downs, regulatory fees, and other costs and expenses for the trades conducted in their custodial accounts. Clients must pay the price of the services provided by their custodian for arranging for the receipt and delivery of securities that are purchased, sold, borrowed or loaned for their account; making and receiving payments concerning account transactions and securities; maintaining custody of account securities and cash, receiving dividends, and processing exchanges, distributions, and rights accruing to the client's account, among others. The custodian may be compensated through commissions or other transaction-based fees for securities transactions executed through the custodian (or its affiliates), asset- based fees for investments settled into the custodian's accounts, or both. Client custodial costs can also include transactions in foreign securities and execution on foreign stock exchanges, resulting in foreign or other transaction expenses and costs associated with international exchange transactions. Additional securities charges can be incurred and will vary considerably based on individual portfolio construction. Some other customary fees and expenses clients can pay to other parties in connection with their accounts can include, but are not limited to: Margin Interest - the interest the client pays to a custodian/broker-dealer on loans to finance the purchase or sale of securities or securities in their investment account. The interest rate charged and other information about the loan, including how interest is calculated and other disclosures of risk and liability, will be described to the client in the separate margin account agreement the client executes with their custodian/broker-dealer. Fees for advice and execution on these securities are based on the total asset value of the account, which includes the value of the securities purchased on margin. While a negative amount may be shown on a client's statement for the margined security due to a lower net market value, the fee amount charged by the Adviser for our advisory services is based on the absolute market value of the client’s account. To calculate an account’s net asset balance, we deduct the amount of any outstanding margin balances from the account’s total gross asset balance, but do not deduct the amount of any outstanding non-purpose loan balances. This means if a client chooses to loan their securities, we will only charge the fee on the net value of the account (i.e., we will discount the net margin balance). Using margin can also result in interest charges and all other fees and expenses associated with the security involved, and Securities Execution Transaction Fees - as noted previously, these are the fees charged by a clearing broker-dealer to an introducing broker-dealer and passed through to the client for payment relating to the purchase and sale of securities in their investment account. A schedule of charges relating to the purchase and sales by type of security is provided to the client by each account’s custodian/broker-dealer of record, as well as any changes or updates to such fee schedules. The exact fees and terms of each custodian's services are described in the agreement the client will execute with their account custodian. (Refer to Item 12: Brokerage for additional information.) 28  The client should understand that all fees paid for our advisory services are separate and distinct from the asset-based management fees charged by the managers of mutual funds, ETFs, and pooled investment vehicles in which the client invests, as well as any additional fees discussed herein. Compound does not receive any portion of these fees, commissions, costs, or expenses; these fees are in addition to and exclusive of our advisory service fees. Furthermore, we do not reduce or offset our advisory fees by any 12b-1 fees or sales-related compensation received from custodians, brokers, mutual fund companies, or insurance companies, whether resulting from a client's purchase or sale of securities, insurance, or other investment products, or the value of the client's account, free credit balance, margin account balance, or retirement account balances. Unless otherwise specified in the Agreement, clients will be subject to our advisory fees in addition to the fees and expenses outlined above, based on the type of advisory service selected and the portfolio investments held, and are responsible for paying all applicable third-party fees. Fees & Compensation Evaluation To fully understand the total costs associated with their account, clients are responsible for reviewing and comprehending not only this document and their Agreement with Compound but also any offering documents, prospectuses, disclosures, and other legal materials provided by their custodian or relevant securities products. These documents outline the fees, costs, expenses, commissions, and other pertinent information regarding securities transactions in the client’s investment account, as well as all fees charged by Compound, the custodian, the broker-dealer, and other applicable parties based on the type of account established. When evaluating the overall costs and benefits of our advisory services, clients should consider not only our advisory fees but also both direct and indirect costs to fully understand the total expenses and assess the value of our services and the recommended investment products. We do not represent that our products or services are provided at the lowest cost. Our advisory fees and associated service expenses may be higher than those charged by other advisers or financial services firms for similar services. Clients have the option to obtain the same or similar products or services at a lower cost from different providers and may choose whether to act on our recommendations. Clients may purchase recommended investment products through any broker or agent, including those not affiliated with Compound. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss, Item 10, Financial Industry Activities and Affiliations, and Item 12: Brokerage Practices for additional information about the fees associated with our advisory service offerings.) Item 6: Performance-Based Fees & Side-By-Side Management __________________________________________________________________________________________________________________________ Performance-based fees are calculated based on a percentage of the capital gains or capital appreciation of a client’s account. This fee structure is contingent upon the performance of the account, aligning the advisor's compensation with the success of the investment strategy. Side-by-Side Management refers to the practice of simultaneously managing accounts that are subject to performance-based fees alongside accounts that do not incur such fees. This approach requires careful consideration to ensure that the interests of all clients are managed fairly and in accordance with applicable regulatory requirements. Compound does not accept performance-based fees or participate in side-by-side management. Item 7: Types of Clients __________________________________________________________________________________________________________________________ Types of Clients Compound typically provides investment advisory services to the following types of clients: Individuals (including High Net Worth Individuals) ● ● Businesses ● Corporations ● Family Offices ● Pension & Profit-Sharing Plans ● Trusts & Estates ● Charitable Institutions 29  ● Foundations & Endowments Compound likewise provides TAMP services to unaffiliated broker-dealers, registered investment advisers, and investment advisory firms. Account Minimums A minimum investment of $25,000 is required to establish a new advisory account under the Turnkey Asset Management Program (“TAMP”) Services or Investment Management Services. However, at its sole discretion, Compound may agree to accept clients with smaller portfolios based on criteria such as anticipated future earning capacity, expected asset additions, account composition, related accounts, and pre-existing client relationships, provided these portfolios do not materially increase investment risk beyond the client’s established risk tolerance. Additionally, advisory fees or minimum portfolio size requirements may be waived for employee, employee-related, and affiliate accounts or for aggregate family member portfolios to meet minimum portfolio size requirements. Compound does not require a minimum portfolio size to participate in our Institutional Advisory Services. Clients are not required to meet account establishment or minimums to participate in Financial Planning & Consulting Services. The minimum account size required by third-party managers under the Third-Party Adviser Management Referral Services is disclosed in each referred manager’s agreement. (Note: When selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they are entering into with the referred manager.) There is no account minimum requirement to participate in our Educational Seminars & Workshop Services. Clients should note that certain investment products may have their own minimum fees or asset requirements, which are separate from our account minimums. These requirements are determined by the product's characteristics, not by our policies. Clients are advised to review relevant disclosure materials and consult with their Financial Intermediary to understand the applicable minimum requirements before and during the investment process. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ____________________________________________________________________________________________________ Methods of Analysis Compound provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan designed to strive to meet the clients' expressed personal short- and long-term financial goals and objectives. We employ various methods and strategies to match the needs and goals of our clients. Multiple sources of information are used as part of the investment analysis process, which can include, but are not limited to: financial publications/newsletters/magazines, research reports and materials prepared by others, ● ● ● corporate rating services, ● SEC filings - such as annual reports, prospectuses, 10-Ks, etc., and ● company press releases. Compound will typically use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Charting Analysis – Charting analysis involves gathering and processing price and volume pattern information for a particular security, sector, broad index, or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Charting analysis may not always accurately identify anomalies or predict future price movements. It is important to note that current securities prices generally reflect all available information about a security. Daily fluctuations in market prices may follow random patterns, and predicting these changes with any reliable 30  degree of accuracy is not guaranteed. Cyclical Analysis - Cyclical analysis is a form of technical analysis that involves evaluating recurring price patterns and trends. Economic and business cycles, however, may not be predictable and can fluctuate between periods of long-term expansion and contraction. The duration of these cycles is often difficult to forecast with accuracy. As a result, the primary risk associated with cyclical analysis lies in the challenge of predicting economic trends and, consequently, the potential impact on the value of securities that these shifting trends may influence. Fundamental Analysis - Fundamental analysis involves evaluating individual companies and their respective industry sectors by examining factors such as a company's financial statements, the details of its product line, the experience and qualifications of its management team, and the overall outlook for the company and its industry. The data obtained through this analysis is used to assess the intrinsic value of the company’s stock relative to its current market price. The primary risk associated with fundamental analysis is the potential for inaccurate or incomplete information, which could lead to an erroneous estimate of earnings or a company’s true value. Additionally, if market prices adjust rapidly to new information, reliance on fundamental analysis may not result in favorable performance outcomes. Modern Portfolio Theory (“MPT”) - MPT is an investment strategy that aims to maximize a portfolio's expected return for a given level of risk or, alternatively, to minimize risk for a specified level of anticipated return through careful diversification of asset proportions. A key principle of MPT is that risk, particularly market risk, which is common to all securities within the same general class (such as stocks or bonds), cannot be eliminated through diversification. This theory seeks to optimize the balance between risk and return by carefully selecting and weighing various assets in a portfolio. Technical Analysis – This type of analysis involves examining historical price patterns, trends, and interrelationships within the financial markets to assess risk-adjusted performance and forecast the direction of both the overall market and specific securities. The risk associated with market timing based on technical analysis is that our predictions may not accurately identify anomalies or forecast future price movements. Current security prices often reflect all known information, and daily fluctuations in market prices may follow random patterns that are not reliably predictable. Financial Intermediaries will also consider macroeconomic factors that impact certain sectors, industries, or companies more significantly than others. Additionally, we consider non-qualitative factors, such as the strength and experience of a company’s or mutual fund’s management team. Other means of analysis may also be utilized as appropriate for the client’s portfolio. Investment Strategies Compound's investment strategies and recommendations are customized to each client’s financial priorities, objectives, and circumstances. We evaluate factors such as financial goals, risk tolerance, time horizon, liquidity needs, and other suitability considerations to determine the investments and asset allocations we consider suitable. These strategies are crafted with the client’s best interest in mind. Clients are obligated to promptly notify us of any material changes to their financial situation or circumstances, including alterations to income, tax status, or employment. Such changes may influence the investment strategy, as will client-imposed restrictions or guidelines. The following outlines the investment practices we may adopt based on individual client circumstances: Direct Indexing Solutions - We may implement direct indexing strategies to replicate market exposures while allowing for customization and potential tax optimization. Pursuant to our strategic business arrangement with FT FinTech Holdings, LLC, (“FTFH”), we have designed the Investor’s affiliated indexing and technology platform as it’s preferred direct and custom indexing solution for Compound advisors although the advisors are free to utilize other direct and custom indexing platforms where approptiate. While this arrangement could influence the selection and integration of certain investment products and technologies, we conduct regular due diligence on the platform’s offerings and considers them in good faith for inclusion in client portfolios and remain committed to our fiduciary duty independence in investment decision-making. These strategies are supported by a preferred technology platform affiliated with FT FinTech Holdings, LLC, our preferred direct and custom indexing provider under a strategic arrangement. While direct indexing may offer benefits such as tax-loss harvesting and ESG filtering, risks include tracking error, operational complexity, liquidity constraints, and over-customization, which may dilute diversification or performance. Further, our relationship with FTFH could influence the selection and integration of certain investment products and technologies. Clients should be aware that these arrangements present potential conflicts of interest. We mitigate these conflicts and maintain independence in investment decision-making by disclosing the relationship, conducting regular due diligence 31  on the platform’s offerings, considering them in good faith for inclusion in client portfolios, and remaining committed to our fiduciary duty and compliance protocols. ESG Investments - An additional level of scrutiny is added to Environmental, Social, and Governance ("ESG") investments. The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening risks include the fact that it may not encompass all environmental, social, or governance issues or may not lead to greater portfolio performance. Long-Term Purchases - We may purchase securities with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Using a long-term purchase strategy typically assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the market segment in which one is invested, or perhaps only one particular investment, will decrease over time, even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking up" assets that may be better utilized in the short term in other investments. Short-Term Purchases - We may use securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to strive to take advantage of the securities' short-term price fluctuations. Using a short-term purchase strategy assumes that we can predict how financial markets will perform in the short term, which may be very difficult and incur disproportionately higher transaction costs than long-term trading. Many factors can affect financial market performance in the short term (such as short-term interest rate changes, cyclical earnings announcements, etc.). Still, they may have a smaller impact over more extended periods. Synthetic Securities-Backed Lending Strategy - Compound offers access to a securities-backed lending strategy through its sub-advisory relationship with SyntheticFi LLC, an SEC-registered investment adviser. The strategy utilizes box spread constructions involving exchange-listed S&P 500 Index options to create fixed payoff structures. These synthetic loan contracts are designed to offer lower interest rates and may result in tax-deductible interest expenses. While the strategy is structured to minimize exposure to market movements, it carries specific risks, including margin maintenance calls, interest rate risk, particularly for longer-term fixed-rate products, and execution risk during periods of extreme market volatility. Clients may also be subject to margin loans if SyntheticFi is unable to roll over box spreads due to market illiquidity. Compound’s discretion to allocate client assets to this strategy also creates a potential conflict of interest due to a revenue-sharing arrangement with SyntheticFi. Compound mitigates this conflict by conducting suitability reviews and fully disclosing the arrangement in accordance with its Code of Ethics prior to the commencement of services. A copy of the Code of Ethics is available for review free of charge upon request. Franklin Managed Options Strategies Sub-Advisory Program - Compound offers eligible clients access to professionally managed options strategies through its Franklin Managed Options Strategies Sub-Advisory Program, designed for clients seeking exposure to options-based investment strategies, which may include covered and uncovered options, exchange-traded funds, and other instruments as outlined in the applicable strategy guidelines. Franklin Managed can employ a range of options strategies, including buying, selling, and shorting options, as well as other derivative instruments. These strategies are subject to various risks, including market volatility, interest rate fluctuations, liquidity constraints, and tax implications - particularly those governed by straddle tax rules under applicable Sections of the Internal Revenue Code. Typically, for any options strategies employed, clients will be required to acknowledge receipt of certain characteristics and risks of standardized options disclosure documents and confirm their understanding of the risks described therein. Past performance is not indicative of future results, and no guarantees are made regarding account performance. Clients are strongly encouraged to review all relevant disclosure documents, which detail the terms of the options management arrangement, applicable fees, and any limitations or risks associated with the selected strategy.. Trading - We may use frequent trading (selling securities within 30 days of purchasing the same securities) as an investment strategy when managing client accounts. Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid substantial losses. When a frequent trading policy is in effect, there is a risk that investment performance within an account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. 32  In implementing our investment strategies and balancing portfolios, we typically consider only the assets managed within the client’s account. Investments held outside of our management will not be factored into our portfolio decisions unless otherwise agreed upon in advance or specifically incorporated into a broader financial plan. Tax Considerations Our investment strategies may have significant tax implications, but unless otherwise agreed in writing, tax efficiency is not our primary focus. We strongly encourage clients to consult a qualified tax professional to understand the tax consequences of their investments. With respect to taxation, clients are reminded that custodians are required to report the cost basis of securities acquired in client accounts, typically using the First-In-First-Out ("FIFO") method. Clients are responsible for consulting their tax advisor to determine if this method is suitable. If an alternative method is preferred, clients must notify the custodian directly. All decisions regarding the cost-basis method must be made before trade settlement, as it cannot be changed afterward. Risks of Loss & Other Types of Risk Clients should be aware that investing in securities involves the risk of loss, which they must be prepared to bear. Past performance is not indicative of future results, and the value of assets may fluctuate, potentially being worth more or less than the initial investment. The degree of risk varies depending on the type of investment. Compound does not guarantee that a client's financial goals and objectives will be achieved, as the perception of financial loss may differ among clients and is influenced by various risks, each of which impacts the probability and magnitude of potential losses. There is no guarantee that any services or analytical methods provided will predict future outcomes, accurately identify market trends, or protect against losses during market corrections or declines, that any investment strategy or asset allocation will meet client expectations, or that past performance is indicative of future results. Investments are subject to numerous risks, and no strategy can guarantee profitability. Furthermore, no service or strategy provided by Compound can ensure specific tax or legal outcomes. The following list of securities and general risks, although not exhaustive, provides a general overview of common risks that prospective clients should carefully consider before engaging our services. Clients are also advised to thoroughly review all relevant disclosure brochures, legal documents, and offering materials, including those pertaining to the investment vehicles or strategies being recommended. Note: Items are presented alphabetically for ease of reading, not in order of importance Adviser's Investment Activities Risk - Our investment activities can involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by the Adviser. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Adviser investment decisions will not always be profitable. Annuities Risks - Annuities are financial products that pay out a fixed stream of payments to an individual, primarily used as an income stream for retirees. The period when an annuity is funded before the payouts begin is called the accumulation phase. The annuitization phase begins once payments commence. Annuities can be structured as fixed or variable. Fixed annuities provide regular periodic payments to the owner/annuitant. Variable annuities allow the owner/annuitant to receive larger periodic payments if the investments in the annuity do well; however, if the investments do poorly, the owner/annuitant will receive smaller payments. Annuities can often incur additional charges, expenses, and miscellaneous fees separate from those charged by an investment adviser. Artificial Intelligence Risks - We may leverage artificial intelligence ("AI") to enhance operational efficiency and improve client services. Currently, however, AI is not used in our investment selection process or in formulating specific investment advice. Instead, our AI applications are primarily focused on automating administrative and client service- related tasks, including meeting preparation, note-taking, CRM updates, task management, and generating meeting recap notes. We believe AI streamlines client engagement, reduces administrative burdens, and ultimately enhances the overall client experience. It is essential to recognize that AI models are inherently complex, and their outputs may sometimes be incomplete, inaccurate, or biased. While AI serves to augment our operations, its use introduces certain 33  risks, such as the potential for inaccuracies, decision-making errors, and challenges related to the effective deployment of the technology. Additionally, AI usage may pose risks to the confidentiality of the client or proprietary information. These risks include the potential exposure of sensitive data to unauthorized parties, violations of data privacy, or other instances of data leakage. For example, in the case of generative AI, confidential information—such as material non- public information or personally identifiable data—entered into an AI application could inadvertently become part of a broader dataset accessible to other users or systems, compromising confidentiality. Moreover, the regulatory framework governing AI is evolving rapidly, and future developments may necessitate adjustments to our AI adoption strategy. The use of AI also carries the potential for regulatory and litigation risks. To mitigate these risks, we have implemented stringent data protection measures, including encryption, access controls, and regular security assessments, to safeguard both client and proprietary information. We continuously evaluate the performance of AI technologies to ensure they are deployed in accordance with our fiduciary responsibilities and regulatory obligations. Additionally, our staff is trained to handle sensitive data with the utmost care, and we partner with trusted third-party vendors who adhere to best practices in data security and compliance. Bank Obligation Risks – Bank obligations, including bonds and certificates of deposit, may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or changes in banking regulation. Bond Risks - Corporate debt securities (or "bonds") are typically safer investments than equity securities. Still, their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default when the bond is set to mature, and whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character, paying the same rate of return. Bond Fund Risks – Bond funds have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high- quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - The risks associated with a specific industry or company. Certificates of Deposit Risk - Certificates of Deposit (“CDs”) are generally a safe type of investment since they are insured by the FDIC up to a certain amount. However, because the returns are usually low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - The securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest Risks - Inherent conflicts exist when investment advisers administer client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which ensures that the client's interest is always held above that of the firm and its associates. Corporate Bond Risks - Corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency Exchange Risk - Overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk – A portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more 34  rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk – Equity investment risk generally refers to buying shares of stock by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease in value; the investment may incur a loss. Financial Risk - The possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk – This risk, including agency, corporate and municipal bonds and all mortgage-backed securities, contains a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investment Risks - From time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, and enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risks - Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline in value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions increases. Horizon & Longevity Risk – The risk that your investment horizon is shortened because of an unforeseen event, such as the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause 35  the value of many fixed-income investments to decline. Lack of Registration Risk - Funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - Leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or using different leveraging strategies. Limited Partnerships Risk - A limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risks - The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - A managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade multiple derivative instruments, including (1) options, (2) futures, (3) forwards, or (4) spot contracts, each of which may be tied to commodities, financial indices and instruments, foreign currencies, or equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees on each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost money during the period. Margin Risk - Securities purchased on margin in a client's account are the firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting the loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. 36  Market Risk - Market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - Because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds Risks - A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. Investors can lose some or all of their principal if the share price decreases. The SEC notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from an FDIC-insured savings account (money market funds are not FDIC-insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. The final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project, like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Fund Risks - Mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager who trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stocks, and their price can fluctuate throughout the day. The costs of managing the funds can reduce the returns on mutual funds and ETFs. Also, while some mutual funds are "no-load" and charge no fee to buy into or sell out of the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with the performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risks - Investment in non-U.S. issuers or securities principally traded outside the U.S. may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or 37  nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Risk - These securities involve risks that are not necessarily in everyone’s best interest. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires, and a put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Put buyers hope that the stock price will fall before the option expires. The option trading risks of options buyers are the risk of losing their entire investment in a relatively short period. This risk increases if, as expiration nears, the stock is below the call's strike price (for a call option) or if the stock is higher than the put's strike price (for a put option). European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. In addition, specific exercise provisions of a particular option contract may create risks, and regulatory agencies may impose exercise restrictions, which stop you from realizing value. Selling options is more complicated and can be even riskier. The risks associated with option trading for option sellers include, but are not limited to: ▪ options sold may be exercised at any time before expiration, ▪ covered call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock, ▪ writers of naked calls risk unlimited losses if the underlying stock rises, ▪ writers of a naked put are exposed to a maximum loss of the strike price less the premium received from the sale, ▪ writers of naked positions run margin risks if the position goes into significant losses, and such risks may include liquidation by the broker, ▪ writers of call options can lose more money than a short seller of that stock on the same rise on that underlying stock - an example of how the leverage in options can work against the options trader, ▪ writers of naked calls must deliver shares of the underlying stock if those call options are exercised, ▪ call options can be exercised outside of market hours, such that the writer of those options cannot perform effective remedy actions, ▪ writers of stock options are obligated under the options that they sold, even if a trading market is not available or they cannot perform a closing transaction, and ▪ the value of the underlying stock may surge or drop unexpectedly, leading to automatic exercises. Other options trading risks include the complexity of some option strategies carrying a significant risk on their own, option trading exchanges or markets and options contracts are open to changes at all times, options markets have the right to halt the trading of any options, thus preventing investors from realizing value, there is a risk of erroneous reporting of exercise value, investors trading through that firm may be affected If an options brokerage firm goes insolvent. Further, internationally traded options have unique risks due to timing across borders. Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are derivatives of stocks. Options Contracts Risks - Options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Put buyers hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). 38  Political & Legislative Risk - Companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - An account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - Investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks - A private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the SEC. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risks - An adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and growing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - A real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations. Hence, cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - We may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same kind of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk - The risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - This risk occurs when investors have no right or power to 39  participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm, including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts (On Tangibles & Intangibles) Risks - A standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index at a specified price on a specified future date. Unlike options, the holder may or may not choose to exercise; futures contracts must be purchased of the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include, but are not limited to, futures contracts that have a margin requirement that must be settled daily, the risk that the market for a particular futures contract may become illiquid, and the market price for a specific commodity or underlying asset might move against the investor, requiring that the investor sell futures contracts at a loss. Short-Sales Risk - Short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risks - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks Risk - There are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health and the issuer. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the overall health of the economy. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"). The sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds Risks - Although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength, demand for products or services. Stock Market Risk - The market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - Individual institutions may be restricted from directly utilizing some investment strategies in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - An adviser's investment strategies and techniques may not work as intended. Structured Products Risk - A structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide 40  for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always insured by the Federal Deposit Insurance Corporation (“FDIC”); the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and other events that are difficult to predict. Supervising Trading Operations Risk - An adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks – These are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Tax Alpha Investment Risks - Tax Alpha Investments refer to investment strategies that aim to enhance an investor’s after-tax returns through tax-efficient management techniques. Tax Alpha can be generated through various methods such as tax-loss harvesting, asset location, tax-efficient fund selection, tax deferral and strategic withdrawals. The goal of tax alpha is to generate returns by minimizing the tax impact on an investment portfolio, ultimately providing better after-tax performance. In general, Tax Alpha Investments have long hold periods and should be considered illiquid. While each Tax Alpha Investment will have its own unique set of risks, all such investments should be regarded as speculative in nature, subject to a high degree of risk, including the risk of losing one’s entire investment, the risk of an audit at both the partnership and individual level, and the risk of not achieving or even losing desired tax mitigation outcomes. Investors should always consult their tax professional before considering a tax alpha investment. Some Tax Alpha Investments are based on Section 1031 of the Internal Revenue Code. Section 1031 governs like- kind exchanges and provides favorable tax treatment for assets held, depreciated, exchanged, and eventually passed on at death as part of an estate. Legislative changes or restrictions to Section 1031 could materially change the effectiveness or value of investment strategies designed to operate under this section. Conservation Easements are a form of Tax Alpha Investment that is classified as a "listed transaction" with the Internal Revenue Service, per Listing Notice 2017-10. Section l.6011-4(d) of the Treasury Regulations requires taxpayers who invest in Conservation Easements to disclose such transactions. Taxpayers who fail to disclose their listed transactions may be subject to penalties under section 6707 of the Internal Revenue Code. Additionally, the IRS has a history of auditing and litigating tax deductions resulting from Conservation Easements. A successful challenge by the IRS could result in the disallowance of a portion (or even all) of the deduction. In such a case, taxpayers could owe additional tax and interest and may incur valuation misstatement penalties. While the listing notice does not invalidate Conservation Easement transactions or prohibit investors from participating, it expressly states the IRS' intention to carefully evaluate the tax benefits investors receive based on the valuation of an easement. Due diligence on such programs is particularly important because of the increased scrutiny following this listing notice. Trading Limitation Risk - For all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - At times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - Identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk 41  and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - These are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants Risks - A warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company. In contrast, options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - An Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Compound generally employs investment strategies aligned with domestic and international equity markets, higher-risk strategies may be used in specific cases. In such instances, the Adviser’s practice is to provide enhanced communication to clients regarding the specific risks associated with the securities in the portfolio prior to implementation. Clients should understand that all investments carry risk, including the potential for losses that may exceed the initial principal invested, along with any gains, particularly if markets move unfavorably for the client. Past performance is not indicative of future results. Additionally, clients may forgo potentially more favorable returns by not considering alternative securities or commodities. Investments may experience both short- and long-term losses, and clients should expect fluctuations in account value and returns similar to the overall performance of the stock and bond markets. Clients should only invest if they are able to bear such risks. Before acting on any analysis, advice, or recommendations, clients are strongly encouraged to consult with their legal, tax, and other financial professionals to assess the suitability of any investment strategy based on their circumstances. Any inquiries regarding risks, fees, and costs should be directed to the client’s IAR. Item 9: Disciplinary Information __________________________________________________________________________________________________________________________ Legal or Disciplinary Events Disclosure Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its Management. Compound has disciplinary, legal proceedings, or outstanding private civil actions to disclose. In particular: On March 5, 2025, Choreo, LLC filed a lawsuit against Compound Planning, Inc. (F/N/A Atomi Financial Group, Inc. dba Compound Planning) and certain of its employees for alleged misappropriation of trade secrets under the Defend Trade Secrets Act of 2016. The lawsuit seeks an injunction to prevent the further misappropriation of the plaintiff's trade secrets. The case is currently before the U.S. District Court for the Southern District of Iowa, Case 4:25-cv-00077- SMR-SBJ. On March 12, 2024, Empower Advisory Group, LLC brought action against Compound. Compound has been actively recruiting potential lateral advisor recruit(s) in various markets as the firm continues its expansion into the financial advisory industry. Compound's recruiting efforts identified several advisors in Colorado from a Competitor, Empower Advisory Group, LLC. Compound was successful in recruiting 13 advisors from Empower as a result of significant material changes and related disorder at Empower, which the advisor recruits identified when they transitioned to Empower after that company purchased and merged other investment advisor companies into its operations. Arising out of or related to Compound's successful recruiting efforts, empower alleged in a complaint filed in the United States 42  District Court for the District of Colorado that Compound and its recruits conspired to misappropriate trade secrets, protected client Information, and utilized the information to solicit the clients to join the advisors at Compound. The allegations are common in these employment disputes, and Compound categorically denies conspiring, unlawfully removing or retaining any trade secret/confidential client information or soliciting any clients. Compound intends to vigorously defend these allegations of any/all wrongdoing and assert counterclaims, as may be available and appropriate, for engaging Compound and/or its advisors in litigation, which lacks a merited foundation. The case is currently before the U.S. District Court for the District of Colorado (Denver), Case No. 1:24-CV-00681. Compound encourages clients to view the Adviser’s complete disclosure documents and history directly on the SEC's IAPD website at www.adviserinfo.sec.gov by searching our firm name, Compound Planning, or CRD # 171787. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the firm, including any disclosure items. Item 10: Other Financial Industry Activities & Affiliations __________________________________________________________________________________________________________________________ Broker-Dealer & Registered Representatives of a Broker-Dealer Compound is not registered as a broker-dealer and does not intend to register as one. However, certain Associates of Compound, in connection with their approved outside business activities, are Registered Representatives ("RRs") of non- affiliated broker-dealers that are members of FINRA and SIPC. When acting in the capacity of RRs for these firms, Associates may sell securities products, such as stocks, bonds, mutual funds, exchange-traded funds, variable annuities, and commodities, to clients and receive commissions or other compensation in connection with the purchase and sale of such securities. Clients are advised that when they are offered brokerage products through unaffiliated broker-dealers by their Financial Intermediaries, the individual is acting in a brokerage capacity and is not acting on behalf of Compound in relation to the advisory services provided under the Advisory Agreement. Compound is not involved in such transactions and does not receive compensation for the Associate’s outside business activity. Associates providing brokerage services through these broker- dealers are independent contractors of those firms. Any compensation earned by these individuals as RRs is separate, additional to, and unrelated to our advisory fees or the advisory services provided under the Agreement. This arrangement presents a potential conflict of interest, as the objectivity of advice provided to clients may be influenced. Associates who provide investment advice on behalf of Compound while also serving as RRs for outside broker-dealers may be incentivized to recommend or effect securities transactions to generate commissions or other benefits rather than making decisions solely based on the client's needs. To address this conflict, Compound requires Associates to disclose their outside business activities and relationships to clients. Associates meet this requirement by informing clients of their role in any transaction, the nature of their relationship with the broker-dealers, and any compensation they may receive from those entities. We further mitigate this conflict through procedures designed to review client accounts in relation to their financial situation, ensuring that investment management services are appropriately aligned with the client's best interests. Compound is committed to overseeing Associates' adherence to the firm’s Code of Ethics and ensuring that both the Adviser and all Associates fulfill their fiduciary duty to clients and investors. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither Compound nor any Management Persons are registered or intend to register as a futures commission merchant, commodity pool operator, commodity trading adviser, or an Associated Person of the preceding entities. Relationships With Other Investment Advisers FT FinTech Holdings, LLC FT Fin Tech Holdings, LLC (“FTFH”) holds a financial interest in Compound’s parent entity, Alternativ Inc. Additionally, Compound has entered into a strategic business arrangement with FTFH’s affiliated indexing and technology platform. Under this agreement, the Adviser has designated the platform as its preferred direct indexing solution, subject to its fiduciary duty. These affiliations create potential conflicts of interest, particularly in the selection of investment products and technology vendors. Compound mitigates these risks through independent due diligence and compliance oversight. Legalist 43  Mr. Christian G. Haigh, one of the founding owners, President and Executive Chairman of Compound, is also an owner, General Partner and Chief Investment Officer of Legalist, Inc. (“Legalist”), an SEC-registered investment adviser (CRD # 297876) located in Las Vegas, Nevada, that serves as the investment manager of several investment limited partnerships, referred to collectively as the “Funds.” In this situation, a conflict of interest exists since Mr. Haigh’s time and attention may be divided between two investment adviser firms, which may affect time commitments with respect to each. Compound addressed this conflict by monitoring the allocation of the time and attention spent by each firm to ensure that they are reasonably and fairly spread out. Neither Compound nor any of its management persons have any other material relationships or conflicts of interest with any related financial industry participants other than those discussed in this brochure. SyntheticFi, LLC Compound has entered into a sub-advisory agreement with SyntheticFi LLC, which acts as sub-advisor for the firm’s securities- backed lending program and is responsible for executing the synthetic loan strategy. Compound retains discretion over client participation and suitability assessments. Our affiliation with SyntheticFi through the sub-advisory and revenue-sharing agreements can influence Compound’s recommendations. To mitigate conflicts, these relationships are disclosed to clients and proactively monitored for compliance with applicable regulations in accordance with the firm’s policy and Code of Ethics. Any material conflicts of interest related to the Adviser, its representatives, or any affiliated personnel that may reasonably be expected to impact the objectivity or impartiality of the advice provided will be fully disclosed to the client prior to the commencement of services. A copy of the firm’s Code of Ethics is available for review free of charge upon request. Franklin Managed Options Strategies, LLC Compound has entered into a sub-advisory agreement with Franklin Managed Options Strategies, LLC (“Franklin Managed”), an SEC-registered investment adviser under common ownership with FT FinTech Holdings, LLC (“FTFH”), a strategic investor in Compound. Through this arrangement, Compound may recommend Franklin Managed as a sub-adviser for professionally managed options strategies, which may include covered and uncovered options, exchange-traded funds, and other instruments as described in the applicable strategy guidelines and the provision of discretionary management of client accounts allocated to its strategies, to make investment decisions in accordance with defined objectives and restrictions. The affiliation between Franklin Managed and FTFH presents a material conflict of interest, as FTFH is a strategic investor in Compound and both entities are under common ownership. While Compound offers other options strategy providers and does not receive compensation for provider selection, this relationship could influence the recommendation of Franklin Managed. Compound mitigates this conflict by conducting ongoing due diligence on all providers, selecting strategies based solely on the client’s best interest, upholding its fiduciary duty at all times, and disclosing the affiliation and potential conflict to clients in accordance with regulatory requirements. Clients are encouraged to review all relevant disclosure documents and the executed advisory agreement with Franklin Managed, which specifies the terms of the options management arrangement, applicable fees, and any limitations or risks associated with the strategy. Third-Party Adviser Referrals Compound recommends or selects other investment advisers for its clients. In certain instances, Compound may receive compensation for the client referrals who utilize our Third-Party Adviser Management Referral Services via a fee-sharing arrangement with those advisers for any accepted clients. In this capacity, the Adviser also acts as a Promoter, introducing clients whose needs are deemed suitable and appropriate for the services offered by the third-party money managers. Before selecting an unaffiliated third-party investment adviser to participate in this service, Compound will conduct a review to ensure the manager meets the Adviser’s criteria and is properly licensed and registered as an investment adviser. Fees shared will not exceed any limits imposed by regulatory agencies. Compound will disclose any conflicts of interest related to the advice or services provided. Neither Compound nor its Financial Intermediaries will exercise discretion or make investment decisions or recommendations in accounts held with referred third-party money managers. If Compound is acting in a promoter capacity, the relationship between Compound and the third-party money manager will be disclosed in the contracts between the Adviser and the money manager, as well as in additional disclosure documents provided to the client, which will include whether a client or non-client of the referred adviser, the compensation to be received, any material conflicts of interest arising from the relationship and the complete terms of the referral arrangement. This arrangement presents a conflict of interest because Compound is compensated for making referrals, which could incentivize the Adviser to recommend certain third-party managers. To mitigate this conflict, Compound fully discloses the relationship and ensures referred clients are aware of the potential conflicts. Additionally, clients are under no obligation to use the services of 44  third-party money managers, and they can seek similar services from other firms, potentially at lower costs. Turnkey Asset Management Platform (“TAMP”) Adviser Referrals Financial Intermediaries may recommend the use of the Adviser’s Turkey Asset Management Platform (“TAMP”) Services, which include third-party managers and models. Compound provides advisory services to individual clients and receives compensation beyond the fees earned from money management services offered outside the TAMP. This creates a conflict of interest, as there is an incentive to recommend TAMP services, which can result in additional fees for the firm in addition to the advisory fees already collected from the client and cause them to recommend these services over others that may be more suitable or less expensive for the client. To mitigate these conflicts, Compound has implemented policies and procedures designed to safeguard that recommendations are made in the best interest of the client. These measures are intended to address the potential bias and ensure that clients receive impartial advice. Further, clients are under no obligation to use these services and are free to seek similar services from other firms, which may offer them at more competitive rates. Clients are encouraged to consider all available alternatives when making such decisions. Designations Certain Associates of Compound hold various designations related to their approved outside business activities, separate from their roles at Compound. Compound does not solicit clients to engage in services associated with these designations or related outside business activities. Any recommendations or compensation received by Associates for services related to these designations are distinct from the advisory services and fees provided by Compound. Clients are under no obligation to act upon any recommendations made by Associates in connection with these outside activities. Additionally, if clients choose to follow such recommendations, they are not required to execute transactions through the Associate, nor are they obligated to use the Associate's services in their capacity as part of an outside business activity. Insurance Services Certain Compound Associates are affiliated with Compound Insurance Services, Inc., a related licensed insurance agent with the State of Delaware or may be appointed as agents for unaffiliated insurance firms. These Associates are licensed to sell various insurance products, including long-term care, disability, annuities, life insurance, health insurance, and other products such as fixed, fixed-indexed, variable annuities, universal life insurance, or other insurance products offered by non-affiliated insurance companies. In their capacity as insurance agents, these Associates may recommend the purchase or sale of insurance products that are separate from the investments made in clients’ Compound advisory accounts. For such transactions, the Associates receive separate compensation, including commissions, bonuses, and trail commissions from the insurance companies with which they are affiliated, in addition to their compensation from our advisory services. Commissions and other compensation from the sale of insurance products are separate and distinct from our advisory fees. Insurance services clients may also engage Compound for advisory services. When making insurance recommendations, there is a conflict of interest, as the Associates can be incentivized to recommend insurance products that generate commissions or other forms of compensation, which could affect the objectivity of the advice provided to clients under the advisory relationship. Clients are under no obligation, either contractually or otherwise, to purchase insurance products or to receive investment advice through Associates acting in their capacity as licensed insurance agents. Clients have the right to decide whether or not to act on any insurance recommendations made by these Associates. Should clients choose to act on such recommendations, they retain the right to purchase these products from any broker-dealer, insurance agency, or financial institution of their choosing and may find that these products or services are available at lower (or higher) costs elsewhere. Tax Preparation Services Compound has a service arrangement with April Tax Solutions, Inc. (“April”), TrackCPA (“Track”), and WhyBlu Corporation (“WhyBlu”), each of which is an unaffiliated tax preparation firm. Compound offers its advisory clients the option to obtain tax filing services through these unaffiliated firms. Client payments are made directly to each service provider, which then makes a payment to Compound, where the Adviser earns a fee for coordinating the tax filing process. The arrangement between Compound and April, WhyBlu and Track creates a material conflict of interest as the Adviser earns additional compensation based on the fees paid to April, WhyBlu and Track, thus incentivizing Compound to recommend to its advisory clients the tax filing services provided by these companies. To mitigate this conflict, Compound discloses the full details of the compensation arrangement or the fee breakdown prior to the engagement. Additionally, the Adviser informs its clients that they can opt out of the service offering and engage other firms or service providers for their tax filing needs. 45  Third-Party Platform Service Providers Compound utilizes third-party platforms to enhance the services offered to its clients, including providing investment strategies, tools, and resources. These platforms may consist of proprietary or non-proprietary systems provided by external companies. The selection of these platforms is based on their ability to meet client needs effectively, and such decisions are made with the goal of best serving our clients' interests without creating a conflict of interest. In addition to offering investment tools, Compound can receive operational or technical support from the platform providers. This support is intended to assist with client account management, reporting, and the efficient delivery of advisory services. However, Compound retains full discretion and independence over investment recommendations, and these platform relationships do not influence our advisory services or the advice provided to clients. Unless otherwise indicated, Compound does not receive any additional compensation or other benefits for recommending or utilizing these third-party platforms. 401Go Compound partners with 401Go, which is a company based in Utah that offers a range of retirement solutions, including setting up and managing 401 (k) plans, for various market segments. 401Go provides a comprehensive selection of investment options, utilizing technology to make their platform more efficient and affordable while ensuring live support from highly-trained managers for employees, employers, and partners. 401Go charges a flat fee in addition to Compound’s advisory fee, both of which are disclosed during the 401Go onboarding process, which the client initiates utilizing 401Go’s onboarding platform. Fidelity Digital Compound will assist interested clients with establishing digital currency accounts through Fidelity Digital Asset Services, LLC (“FDAS”), a subsidiary of Fidelity Investments. FDAS is a platform for digital assets, which the Advisor offers as a possible portfolio management diversification strategy for clients who express an interest in exposure to digital assets. “Digital asset” shall mean a digital asset (also called a “cryptocurrency,” “virtual currency,” “digital currency,” or “digital commodity”), such as bitcoin, which is based on the cryptographic protocol of a computer network that may be (1) centralized or decentralized, (2) closed or open source, and (3) used as a medium of exchange and/or store of value. Clients will establish a Digital Asset account and transfer funds into an account opened on the FDAS platform. Modern Life Compound partners with Modern Life, a tech-enabled life insurance brokerage licensed in all 50 states. Modern Life offers a platform that provides financial advisors with access to a comprehensive range of insurance products from over 20 national carriers, including permanent life, term life, long-term care, and disability insurance. The platform enables advisors to compare quotes efficiently, utilize AI-driven underwriting, submit digital applications for expedited decisions, and manage cases with expert brokerage support. Compound refers advisors to Modern Life and uses the platform to meet clients' insurance needs. In return, Compound receives a referral fee, creating a conflict of interest. This fee may incentivize us to recommend Modern Life’s insurance solutions over other alternatives that might be more suitable or cost-effective for the client. To mitigate this conflict, we fully disclose the compensation arrangement to clients prior to any recommendation. Additionally, clients are informed that they are under no obligation to use Modern Life’s services and can opt to engage other firms or insurance providers for their insurance needs. Compound encourages clients to consider all available options when making insurance decisions. Pontera Compound utilizes Pontera, a third-party platform, to facilitate the management of held-away assets for accounts not held directly within our custody. A “held-away” account refers to an account that a client maintains with a financial institution other than a broker-dealer or custodian with whom we have a custodial relationship. In other words, it is an account that we do not hold, manage, or have custodial access. For example, a 401(k) account sponsored by your employer is a held-away account. When clients engage Compound in this capacity, they are responsible for keeping the Pontera platform link active so that we can access and manage the respective account without delay. The platform allows Compound to avoid being considered to have custody of client funds, as the Adviser does not have direct access to client login credentials to execute trades. This applies to accounts where we maintain discretion, such as defined contribution plan participant accounts (i.e., 401(k) accounts, HSAs, and other assets), under which we do not have custody. We are not affiliated with the platform in any way and do not receive any compensation from Pontera for using it. Clients are provided a link to connect their account(s) to the platform. Once the client’s accounts are connected, Compound will review the client’s current account allocations and regularly evaluate the available investment options in the accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary, and may leverage an Order Management System (“OMS”) to 46  implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. We will rebalance the account when necessary, considering client investment goals, risk tolerance, and current economic and market trends. The goal is to improve account performance over time, minimize losses during difficult markets, and manage internal fees that can negatively impact account performance. Client account(s) are reviewed at least quarterly, with allocation changes made as deemed necessary. SmartAsset Compound participates in SmartAsset’s lead generation platform, which connects individuals with vetted financial advisors who are fiduciaries and legally bound to act in the client’s best interests. The platform offers a user-friendly process that matches individuals with advisors based on their financial needs, goals, and preferences. SmartAsset’s services are available to users at no cost and facilitate seamless connections between individuals and advisors. SmartAsset also provides financial professionals with tools for client acquisition, marketing, and lead generation, enabling advisors to grow their businesses by gaining qualified, pre-screened leads from prospective clients seeking financial guidance. SmartAsset generates revenue by charging financial advisors for access to the platform and its lead-generation services. This compensation model creates a conflict of interest, as SmartAsset may prioritize advisors who pay for these services. While SmartAsset aims to match users with fiduciary advisors who meet their financial needs, clients and prospective clients should be aware that SmartAsset’s business model could influence the advisor selection process. Advisors who pay for the platform’s services may be more prominently featured or receive greater visibility. Additionally, SmartAsset may have relationships with specific advisors or firms that could limit the range of options available to clients. To mitigate this conflict, Compound will disclose its participation in SmartAsset’s platform and inform clients about the potential influence of the compensation model. Clients and prospective clients are encouraged to consider these potential conflicts when selecting an advisor and are free to explore other options outside the platform. Other Business Relationships Compound uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Compound sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise - neither the firm nor its Associates receive compensation for such use or referrals. Compound acknowledges that certain financial activities, affiliations, relationships, and services may create conflicts of interest. The Adviser and its Associates may have financial incentives to recommend specific companies or services due to compensation received in connection with the transaction, rather than based solely on the client's needs. To address these conflicts, Compound requires Associates to always act in the best interests of each client. Clients are under no obligation to act upon any recommendations or purchase additional products or services offered by us. If clients choose to act on a recommendation, they are not required to execute transactions through Compound - they may choose to place their business and securities transactions with any brokerage firm or third party of their choice. Compound makes no assurances that products or services offered by other entities are available at the lowest possible cost. Clients may obtain the same products or services from different providers at lower prices. The decision to retain products or services remains solely with the client. Outside of the relationships and affiliations disclosed herein, neither Compound nor its management persons have any additional material relationships or conflicts of interest with other financial industry participants to disclose Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading __________________________________________________________________________________________________________________________ Code of Ethics Rule 204A-1 under the Advisers Act requires all investment advisers registered with the SEC to adopt a Code of Ethics that sets forth standards of conduct and requires the investment adviser’s Supervised Persons to comply with the Federal securities laws. Compound takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of its Supervised Persons (“Associates”). The firm strives to comply with all applicable laws and regulations governing its practices. It is committed to upholding the highest standards of trust, fair dealing, and integrity with each advisory client. To that end, the Adviser has adopted a Code of Ethics (“Code”), which outlines the firm's conduct standards in alignment with its fiduciary obligations. 47  Our Code requires all Associates considered "Supervised Persons" under the Advisers Act to exercise a fiduciary duty by acting in each client's best interest and prioritizing the client's interests above all else. The Code also applies to other individuals as designated by the Chief Compliance Officer. Further, the Code specifies certain activities that may create actual or perceived conflicts of interest and sets forth reporting requirements and enforcement procedures. Associates are required to adhere to all relevant industry regulations and the firm’s written Policies & Procedures Manual, including any updates. At the time of hire and periodically thereafter, Compound distributes its Code to all Associates. Associates must affirmatively commit to complying with state and federal securities laws, maintaining client confidentiality, refraining from insider trading, complying with restrictions on accepting significant gifts, reporting outside activities, and adhering to personal securities trading procedures, among others, particularly for Access Persons. Associates are required to attest to their compliance and understanding of these provisions no less than annually. Compound also provides annual training on its Code and continuously monitors the activities of its Supervised Persons to confirm alignment. A copy of the firm’s Code of Ethics is available for review free of charge upon request. Recommendations or Transactions in Securities with Material Financial Interests Neither the Adviser nor any Associate recommends to clients or buys or sells for client account securities in which the Adviser or an Associate has a material financial interest, acts as a principal buying securities from (or selling securities to) clients, acts as general partner in a partnership in which Adviser solicits client investments, or acts as an investment adviser to an investment company that the Adviser recommends to clients. Participation or Interest in Investments in Securities Recommended to Clients Compound and its Associates may invest in the same securities as those recommended to clients or engage in securities transactions involving securities at or around the same time that such securities are recommended to clients. This situation presents a conflict of interest, as Compound and its Associates could seek to benefit from trading the same securities, either by executing personal trades ahead of client trades or otherwise. To mitigate such conflicts, Compound’s policy isto aggregate employee trades with client trades. If the aggregated transaction is filled entirely, it will be allocated among the accounts listed on the PreAllocation Order. If the order is partially filled, we will allocate it on a random basis ensuring client accounts are filled first. . The Adviser makes exceptions for transactions in securities that are direct obligations of the government of the United States; bankers' acceptances, bank certificates of deposit, commercial paper, and high-quality short-term debt instruments (including repurchase agreements); or shares issued by registered open-end investment companies. Personal Trading & Conflicts of Interest Compound monitors all firm and Associate personal trading activities to verify that such trades align with the fiduciary obligations owed to clients. Compound’s policies and procedures regarding personal trading are designed to ensure that all trading activities are conducted in the best interest of clients and full compliance with applicable regulations. All personal securities transactions require written clearance from the Chief Compliance Officer or Designee, subject to limited exceptions (i.e., mutual fund transactions), and the Adviser retains the discretion to disapprove such personal securities transactions if they appear to create a conflict of interest or if the transaction otherwise seems improper. In addition, Compound has a strict prohibition against insider trading and has implemented policies and procedures to ensure compliance with this policy. Associates are well-versed in the rules regarding material non-public information and insider trading and are prohibited from using such information for personal gain. Access Persons may engage in personal securities transactions based on individual investment considerations that the Adviser does not consider appropriate for client transactions. In all instances, the client’s best interests remain paramount when executing trades. Associates are required to disclose their personal securities transactions at the time of onboarding and periodically thereafter and submit trade confirmations to the Chief Compliance Officer or Designee for review. The firm conducts regular reviews of personal trading activity, with a comprehensive review occurring no less than quarterly. In the event that a conflict of interest is identified or a policy violation occurs, the firm will take appropriate corrective actions. 48  Personal Trading of Associates Affiliated with a Brokerage Firm In their capacity as Registered Representatives and in connection with approved outside business activities, Compound prohibits Associates from receiving payments from certain mutual funds distributed pursuant to a 12b-1 distribution plan or other such plans as compensation for administrative services, representing a separate financial interest. Agency Cross-Trades An agency cross-trade occurs when an investment adviser executes a trade between two or more of its advisory clients’ accounts. Compound does not engage in agency cross-trades. Principal Trades A principal trade is one in which an investment adviser, acting as principal for its account, buys securities from a client or sells securities to a client. Compound does not engage in principal trades. Trade Errors Even with the best efforts and controls, trade errors can happen. A "trade error" can include, among other things, the purchase or sale of an incorrect security, an incorrect amount of a security, or a failure to purchase or sell an intended security. Compound has internal controls in place to strive to prevent trade errors from occurring. We aim to detect trade errors prior to settlement and correct or mitigate them expeditiously. If a trade is placed for a client's account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters, our policy is to restore the account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions can include canceling the trade, adjusting an allocation, and/or reimbursing the account. The goal of error correction is to make the client whole. To the extent an error is caused by a counterparty, such as a broker, we will strive to recover any loss associated with such error from such counterparty. Generally, the client will be reimbursed for any loss incurred due to a Compound trade error. Any gains from our trade error will remain with the client. In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Compound maintains an accounting of each trade error within its books and records, including information about the trade and how such error was corrected. Item 12: Brokerage Practices __________________________________________________________________________________________________________________________ Preferred Custodians Compound works with multiple custodians and employs several FINRA-registered broker-dealers. After appropriate due diligence and careful consideration of the brokerage practices disclosed in this section, the Adviser has selected several preferred 'Qualified Custodians' it typically recommends, including, but not limited to, Charles Schwab & Co., Inc. (“Schwab"), Fidelity Brokerage Services LLC, and Goldman Sachs & Co., LLC, each an unaffiliated, SEC-registered broker-dealer, Members FINRA / SIPC. Additionally, custodians such as Digital Trust (formerly Kingdom Trust Co.), Nationwide Trust Company, and Fund Direct may also be used. Factors Used to Select & Recommend Custodians & Broker-Dealers Compound seeks to select and recommend custodians that will hold client assets and execute transactions on terms that are most advantageous relative to other available providers and their services. While the Adviser has designated certain preferred custodians, it regularly reviews and evaluates other custodians to ensure the reasonableness of their compensation structures. In selecting a custodian, the firm makes a good-faith determination that the commissions charged are reasonable, taking into consideration the value of the brokerage and research services provided by the custodian. Analysis will vary and may include a review of any combination of the following, in addition to other considerations: ● the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ● ● ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., 49  competitive trading commission costs, reporting tools, including cost basis and 1099 reports, facilitating tax management strategies, ● ● ● personal money management tools such as electronic fund transfer capabilities, dividend reinvestment ● ● ● ● ● ● ● ● programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and the availability of other products and services that benefit us. Custodial Support Services Custodians provide independent investment advisory firms with access to institutional brokerage services, including trading, custody, reporting, and other related services. These services, often unavailable to retail customers, are typically offered unsolicited; advisory firms do not need to request them. The custodial support helps advisers manage client accounts and grow their business. These services are available at no charge, provided a qualifying amount of client account assets is maintained with the custodian. (For current qualifying asset thresholds, contact us directly.) Below is a description of some standard support services Compound can receive from our preferred Qualified Custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some that the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available that benefit investment advisers but do not directly benefit our clients or their accounts. These products and services assist advisers with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: ▪ provides access to client account data (such as duplicate trade confirmations and account statements), ▪ facilitates trade execution and allocates aggregated trade orders for multiple client accounts, ▪ includes pricing and other market data, ▪ facilitate the payment of our fees from our clients’ accounts, and ▪ assists with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: ▪ educational conferences and events, ▪ technology, compliance, legal, and business consulting, ▪ publications and conferences on practice management and business succession, and ▪ access to employee benefits providers, human capital consultants, and insurance providers. Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. They can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs 50  Our custodians generally do not charge the firm’s clients' custodial accounts separately for their services. Instead, the custodian is compensated by charging clients commissions or other fees on the trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Compound’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Compound had not committed. In addition to commissions or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research-related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence us to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third party - originating from a party independent from the broker providing the execution services. A conflict of interest may exist in making a reasonable good-faith allocation between research services and non-research services because we allocate the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker- dealer. Receiving brokerage and research services from any broker executing transactions for our clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in our view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between us and our clients, as services received from our custodians benefit the Adviser because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give us an incentive to recommend that our clients keep their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, we may receive non-research, administrative or accounting services and research benefits from the broker- dealers' services. When this happens, we will make a good-faith allocation between the non-research and research portions of the services received and pay hard dollars for the non-research portion. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation we might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those of other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), we may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction, recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making 51  process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet our sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Compound’s preferred Qualified Custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services based on our interest in receiving the research or other products or services rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service; soft-dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred Qualified Custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that these custodial services do not only benefit us. Brokerage for Client Referrals Compound does not select or recommend a broker-dealer based on our interest in receiving client referrals, rather than solely prioritizing our clients' interest in receiving the most favorable execution. Best Execution Compound acts on its duty to seek “best execution.” As a matter of policy and practice, Compound conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Compound seeks to ensure compliance with the client's written Advisory and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Compound will seek competitive rates, it may not necessarily obtain the lowest commission rates for client transactions. Further, SyntheticFi executes trades directly in clients’ brokerage accounts. No client or lender approvals are required for collateral distribution or ACH transfers. SyntheticFi supports aggregated collateral from multiple accounts and offers both fixed and floating rate loan options. SyntheticFi’s control over execution could limit Compound’s ability to influence trade routing or pricing. Compound monitors execution quality and discloses the arrangement to clients as indicated herein. And, in accordance with Compound’s policy and Code of Ethics, discloses to the client any conflicts of interest with respect to this relationship prior to the commencement of services. A copy of the firm’s Code of Ethics is available for review free of charge upon request. Directed Brokerage Sometimes, a client may direct Compound in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. In this situation, the client will negotiate terms and arrangements for the account with the custodian. Compound will not seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for different accounts managed by us. As a result, the client may not achieve the most favorable execution of client transactions. Directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account that would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Compound may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. 52  Special Directed Brokerage Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Compound can arrange for the execution of securities transactions for 401 (k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy As a fiduciary, Compound is committed to acting in the best interests of its clients. Compound and its Associates may trade securities for client accounts while also trading for our accounts and may aggregate trades for clients with similar objectives, strategies, and restrictions. This practice can create a conflict of interest, such as trading ahead of client orders or obtaining more favorable prices. Compound’s policy is that all aggregated trades will be executed with the primary objective of ensuring that no client is disadvantaged and that each client receives fair and equitable treatment. The firm will aggregate transactions only when it is in the best interest of clients, such as to achieve best execution, negotiate more favorable commission rates, or allocate securities equitably among clients. Aggregated transactions will generally be allocated on a pro-rata basis, with the price averaged across all transactions on a given day. Prior to entering an aggregated order, an "Allocation Statement" will be prepared, specifying the participating client accounts and the intended allocation of securities. If the allocation differs from the Allocation Statement, the reason for the change will be documented and reviewed by the Head of Trading or designee. In certain circumstances, prorated allocation may not be appropriate. The allocation will then be based on relevant factors, such as the size of the order, investment guidelines, sector weightings, or cash availability in client accounts. For instance: ● If only a small percentage of the order is executed, shares may be allocated to the account with the smallest position or one that is out of line with sector weightings. ● Accounts with investment restrictions that prevent the purchase of certain securities may receive allocations in place of other accounts. ● Accounts that exceed investment guidelines may have their allocation redistributed to other clients. ● In cases where a pro-rata allocation results in a de minimis amount for some clients, those clients may be excluded, and the remaining accounts will receive the allocation. We may also aggregate trades for itself or associated persons with client trades, provided that: ● Aggregation is consistent with the duty to seek best execution for clients, which includes seeking the best price and is in accordance with the firm's investment advisory agreement. ● No client will be favored over another; all clients participating in an aggregated order will receive the average share price for all transactions on that day. ● A written Allocation Statement will be prepared specifying how the order will be allocated. ● ● If the order is partially filled, the allocation will be done on a pro-rata basis. If an allocation differs from the Allocation Statement, it will be explained and approved by the Chief Compliance Officer. Additionally, the Adviser will maintain accurate records of all aggregated orders and transactions for each client account. Compound will confirm that banks or broker-dealers hold the funds and securities for all aggregated client orders on a delivery versus payment basis and not have them collectively for longer than necessary to settle the transaction. Compound will not receive any additional compensation from aggregating orders, and each client will continue to receive individual investment advice and treatment. Furthermore, the Adviser subjects the firm’s aggregation and allocation procedures to regular compliance oversight to confirm adherence and mitigate potential conflicts of interest. Item 13: Review of Accounts 53  __________________________________________________________________________________________________________________________ Frequency & Nature of Account Reviews Compound’s Investment Professionals monitor Turnkey Asset Management Program (“TAMP”) Services, Investment Management Services and Institutional Advisory Services accounts and holdings ongoing, using automated tools and systems through periodic meetings with clients and internally for accuracy from an investment, accounting and administrative viewpoint. No less than annually, as indicated herein and within each executed Advisory Agreement, the Investment Professional will convene with the client to evaluate their accounts and discuss, at a minimum, the client’s current financial situation and circumstances, investment objectives, investment suitability, and portfolio exposures, among other topics, to ensure the advisory services provided remains consistent with the account’s chosen strategy, goals and performance objectives. More frequent reviews may be triggered by significant market, economic, or political events, client requests, changes in a client’s investment objectives or guidelines, alterations in their financial situation (such as retirement, job termination, relocation, or inheritance), or material cash flows in the account, whether expected or unexpected. Additionally, changes in tax laws, new investment information, and other changes in the client’s personal or financial circumstances may also prompt review, as will macroeconomic factors and company-specific events. Other reviews can be conducted upon client request. Third-Party Adviser Management Referral Services accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their referred adviser’s agreement for exact details. Financial Planning & Consulting Services accounts are reviewed in accordance with the terms agreed upon with each client. Financial plans are reviewed only upon client request unless the Adviser has been retained to update the plans on an ongoing basis. Members of the Compliance team will periodically review client account activity through random sampling to ensure IARs’ actions align with the client’s investment objectives, risk profile, and regulatory requirements. This includes verifying IARs’ monitoring efforts, client meeting frequency, trading activity, and portfolio performance in accordance with the Advisory Agreement, client Investment Policy Statements, and firm policies. Each of the above reviews is conducted as part of Compound’s contracted services; clients are not assessed additional fees for the assessments. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Advisers Act. Client Account Reporting The client’s selected Qualified Custodian will send the client written account statements, at least quarterly, itemizing activity and account transactions, specific investments held in the account, the portfolio's value, deposits, withdrawals and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as the client selects. Compound urges clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare account investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. Compound does not typically provide clients with additional or more frequent written statements on their accounts, although ad hoc reports can be requested. Item 14: Client Referrals & Other Compensation __________________________________________________________________________________________________________________________ Compound receives an economic benefit from the following entities or individuals for providing investment advice or other advisory services: 54  Preferred Qualified Custodian Benefits Compound receives an economic benefit from its recommended Qualified Custodians in the form of support products and services, which are provided as part of its arrangement to recommend that clients maintain accounts with these custodians. These benefits offset costs that we would otherwise have borne directly. While clients do not incur additional costs for assets held at a recommended custodian, they should be aware of potential conflicts of interest, including the nature of the products and services provided by custodians and the associated benefits to us when selecting a custodian. (See Item 12: Brokerage Practices for disclosures on research and other benefits we may receive from our relationship with your account Custodian.) Tax Preparation Services Benefits Compound has a service arrangement with April Tax Solutions, Inc. (“April”), TrackCPA (“Track”), and WhyBlu Corporation (“WhyBlu”), each of which is an unaffiliated tax preparation firm, as previously described in Item 10: Other Financial Industry Activities and Affiliations. The arrangement between Compound and these firms creates a material conflict of interest as the Adviser earns additional compensation based on the fees paid to them, thus incentivizing Compound to recommend to its advisory clients the tax filing services provided by these companies. To mitigate this conflict, Compound discloses the full details of the compensation arrangement or the fee breakdown prior to the engagement. Additionally, the Adviser informs its clients that they can opt out of the service offering and engage other firms or service providers for their tax filing needs. Third-Party Platform Service Provider Benefits Compound utilizes 401Go, Fidelity Digital, and Modern Life, each a third-party platform designed to enhance the services offered to its clients, including providing investment strategies, tools, and resources, as previously described in Item 10: Other Financial Industry Activities & Affiliations. In addition to offering investment tools, Compound can receive operational or technical support from the platform providers. The receipt of operational or technical support from these platform providers presents a potential conflict of interest, as such support may incentivize continued use of these platforms. Compound mitigates this conflict by ensuring that all recommendations and services are made in the best interest of clients, with no undue influence from the providers. Compound also receives client referrals and other forms of business development support from FT FinTech Holdings, LLC (“FTFH”), a company with which it maintains a strategic relationship involving an affiliated indexing and technology platform that offers indexing solutions, execution and custodial services. Similar support may be received from FTFH’s affiliated entities. Although these arrangements are not contingent upon client transactions or advisory fees, the receipt of referrals or business development support from a firm with which Compound has an ongoing strategic relationship presents potential conflicts of interest. Specifically, such relationships could create an incentive to favor affiliated services or platforms. Compound addresses these conflicts through full and transparent disclosure, ongoing compliance oversight, and strict adherence to its fiduciary duty to act in the best interests of each client. SyntheticFi, LLC Compound Planning, Inc. (“Compound”) receives reimbursement payments from SyntheticFi LLC (“SyntheticFi”) for client education and support services related to the SyntheticFi Securities-Backed Lending Program, calculated as a percentage of the synthetic loan size and paid monthly in arrears. This arrangement creates a financial incentive for Compound to recommend the SyntheticFi program. Compound addresses this conflict through full disclosure to clients prior to the commencement of services and compliance with applicable SEC rules, including required updates to Form ADV and related materials. A copy of the Code of Ethics is available upon request at no charge. Conflicts of Interest To further mitigate potential conflicts of interest associated with the referral arrangements and other compensation disclosed herein, Compound Planning, Inc. has adopted comprehensive compliance policies and procedures, including a formal written Code of Ethics, to which the firm and all personnel are required to adhere. These measures are designed to ensure that all client referral and compensation arrangements are handled with full transparency and in accordance with applicable regulatory standards. Clients are informed of any material benefits received by both Compound and the referring party prior to the execution of any transaction or engagement. Compound is dedicated to making referrals solely based on the appropriateness of the recommended services or products for the client’s specific needs, independent of any financial incentives. This approach reinforces the integrity of the advisory process 55  and reflects the firm’s ongoing commitment to acting in the best interests of its clients at all times. Apart from the items disclosed herein, Compound has no additional economic benefits related to client referrals or compensation to disclose. Further details of how we mitigate conflicts of interest can be found in the firm's comprehensive written compliance policies and procedures and Code of Ethics. A copy of the firm’s Code of Ethics is available for review free of charge upon request. Item 15: Custody __________________________________________________________________________________________________________________________ Compound does not have physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts. The Adviser prohibits the firm or its Associates from obtaining, accepting, or maintaining custody of client funds, securities, or assets in any manner. Clients will keep all account cash, securities and other assets with a Qualified Custodian governed by a separate written brokerage and custodial account agreement between the Qualified Custodian and client. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Compound is not authorized to withdraw any money, securities, or other property from any client custodial account, in the client's name or otherwise. The independent custodian will directly debit the client’s account(s) to pay Compound’s advisory fees. To authorize this, the client will provide written limited authorization instructions directly to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. The client will give these instructions on the Qualified Custodian's form or separately. The ability to deduct advisory fees from client accounts causes our firm to exercise limited custody over client funds or securities. Clients will receive account statements from the Qualified Custodian(s) holding their funds and securities at least quarterly to their e-mail or postal mailing address of record, which the client provided to the custodian. They will also receive at least quarterly reports from their custodian reflecting all disbursements for the account, including the amounts of any assessed advisory fees. The account statements from the custodian(s) will indicate the amount of our advisory fees deducted from their account(s) each billing period. Clients should carefully review statements provided by their custodian promptly upon receipt. If clients have any questions regarding their custodial account statement or did not receive a statement from their custodian, please contact us immediately. Wire Transfers, Check-Writing Authority & Standing Letters of Authorization Compound or persons associated with the firm may facilitate wire transfers from client accounts to one or more third parties designated in writing by the client without obtaining written consent for each transaction. Additionally, we may have signatory and check-writing authority for client accounts, provided the client has granted written authorization for such activities. This written authorization is referred to as a “Standing Letter of Authorization” (“SLOA”). Under SEC Rule 206(4)-2, an adviser with authority to conduct third-party wire transfers or sign checks on a client’s behalf is deemed to have custody of client assets in the affected accounts. However, the adviser is not required to undergo a surprise annual audit, typically required for advisers with custody, provided that it meets the following conditions: 1. The client provides a written, signed instruction to the qualified custodian, including the third party’s name, address, and/or account number at a custodian. 2. The client authorizes the adviser, in writing, to direct transfers to the third party, either on a specified schedule or on an as-needed basis. 3. The qualified custodian verifies the client’s authorization (i.e., signature review) and promptly provides a funds transfer notice to the client after each transfer. 4. The client retains the ability to terminate or modify the instruction at any time. 5. The adviser has no authority to designate or modify the third party’s identity, address, or any other information pertaining to the third party. 6. The adviser maintains records demonstrating that the third party is neither a related party to the adviser nor located at the same address as the adviser. 56  7. The client’s qualified custodian sends the client an initial notice confirming the standing instruction, along with an annual notice reconfirming the instruction. Compound affirms that it meets the above conditions in compliance with SEC requirements and avoids custody under the applicable rules, thus exempting the firm from the requirement of a surprise annual audit. Third-Party Adviser Management Referral Services clients will follow the custody and SLOA procedures of their referred adviser. Clients should refer to the third-party manager’s agreement for exact details. Item 16: Investment Discretion __________________________________________________________________________________________________________________________ Account Management Style Compound’s advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Advisory Agreement reflects complete information for account management style. Discretionary Authority Under discretionary account management authority, Compound will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: ● determine the security to buy or sell, ● determine the amount of security to buy or sell, and ● determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management authority through written authorization, granting Compound complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as deemed appropriate by the Adviser, in accordance with the client's investment risk profile and Investment Policy Statement. This authority may be subject to modifications agreed upon by the client and their IAR or Financial Intermediary from time to time (collectively, the “Investment Guidelines”). (Note: Please note this authority excludes certain money movement transactions. Compound will not initiate wire transfers or transfers of funds to third parties without the client's explicit written approval.) Discretionary authority is limited to investments within a client's managed accounts. Clients will execute a “Limited Power of Attorney,” either as a standalone document or as part of the account opening documentation provided by their custodian. Compound is only required to obtain or maintain client consent for trades involving positions explicitly discussed during the introductory meeting (such as inherited stock the client wishes to retain for sentimental reasons) or as otherwise specified. In all instances, discretionary authority will be exercised in alignment with the client’s stated investment objectives. This authority will remain in effect until the client terminates it through written notice to the Adviser, even in the event of the client’s incapacity or disability. Non-Discretionary Authority Where specifically requested by a client, Compound will manage the client’s account on a non-discretionary basis. Non- discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or other securities and refuse to approve securities transactions. Clients will execute all documents that Compound or their custodian requires to establish the account trading authorization. The Adviser will then recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate to further the client’s investment guidelines, with such changes as the client and their IAR or Financial Intermediary may agree to from time to time. Under this management style, Compound must receive approval from the client before placing any trades in the client's account. 57  As a result, until the client’s IAR / Financial Intermediary reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed-upon investment objectives, Compound reserves the right to cancel the client's Agreement after appropriate written notice. Similarly, the client reserves the right to cancel their Agreement with Compound according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Compound will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Compound seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. TAMP Services Compound provides ongoing and continuous oversight of the strategies and models offered through its platform for its Turnkey Asset Management Platform (“TAMP”) Services. However, the selection of the specific investment strategy for each client’s assets is based on suitability information gathered and reviewed by the Financial Intermediary, the client of Compound. Compound is primarily responsible for the implementation of the selected strategy, trading activity, and the overall management of the portfolio, which includes executing trades based on the parameters of the model or investment strategy chosen by the Financial Intermediary and their clients. Under the TAMP Agreement, Compound is granted discretionary trading authority. This authority is limited to the models and securities available through the platform. Compound has discretion over the timing, execution, and selection of securities within the chosen model or strategy, enabling it to manage trades without requiring prior consent from the Financial Intermediary or the client. Specifically, Compound is authorized to: ● buy, sell, exchange, and trade stocks, bonds, or other securities or assets, ● determine the amount and timing of such transactions, and ● place orders directly with the custodian. It is important to note that Compound, as a TAMP service provider, does not assume a fiduciary or investment advisory role in the following circumstances: (1) when assets are managed directly by an unaffiliated Financial Intermediary, using Compound's technology solely as an account management system, (2) when assets are under management by the Financial Intermediary outside of the Compound platform, or (3) when securities are transferred into the program for liquidation in order to allow Compound to commence discretionary management. In these cases, Compound's discretionary authority is exercised strictly in line with the investment objectives of the selected strategy for each client’s account. Financial Intermediaries are responsible for notifying Compound of any changes to the client’s investment objectives so that Compound can collaborate with the Adviser to make any necessary adjustments to the client’s portfolio. It remains the responsibility of the Financial Intermediary to monitor such changes and promptly inform Compound when needed. Item 17: Voting Client Securities __________________________________________________________________________________________________________________________ Proxy Voting Compound will not ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or custodian and are responsible for exercising their right to vote proxies. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds the proxy voting responsibility and authority for the plan account. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 58  While Compound may assist a client with their proxy questions, the Adviser shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in the above situations; it is the client's responsibility to vote their proxy. Clients should contact the security issuer before making their final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights of and remedies for large numbers of people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. The client is responsible for class action suits, claims, bankruptcies or other legal actions and proceedings involving securities purchased or held in their account. Compound will not advise or act for the client in these types of legal proceedings involving securities held or previously held by the account or the issuers of these securities. Compound does not provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy, and is not obligated to forward copies of class action notices received to clients or their agents. Item 18: Financial Information __________________________________________________________________________________________________________________________ Balance Sheet Compound does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore, does not need to include a balance sheet with this Brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither the Adviser nor its management has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Compound has no additional financial circumstances to report. Bankruptcy Petitions in the Previous Ten Years Compound has not been the subject of a bankruptcy petition. Item 19: Requirements for State Registered Advisers __________________________________________________________________________________________________________________________ Compound Planning, Inc. is an SEC-registered investment adviser. Therefore, this section is not applicable to the firm’s business model. Item 20: Additional Information ____________________________________________________________________________________________________ Business Continuity Plan Securities industry regulations require that financial firms inform their clients of their plans to address the possibility of a significant business disruption ("SBD") that potentially results from power outages, natural disasters, or other such events. Financial firms must be able to provide continuous, uninterrupted services to their clients, and the firm's critical systems must operate during such interruptions so that the firm can resume operations as quickly as possible, given the SBD's scope and severity. Firms must meet their obligations to clients, counterparties, and other business relationships during an emergency or SBD. Since the timing and impact of disasters and disruptions are unpredictable, firms must also be flexible in responding to actual events as they occur. Well thought-out, advanced preparations and effective procedures efficiently minimize downtime in the face of a disaster or outage and enable the firm to meet existing client obligations. Firm Policy To satisfy this requirement, Compound has developed a comprehensive Business Continuity Plan ("BCP"), which is reviewed, tested, and updated no less than annually to detail how the firm responds to an SBD event and assist clients in making educated decisions about whether to conduct business with us. Compound's guiding principle is that protecting clients, employees, and family members always takes precedence over preserving business assets. The firm's policy is to respond to an SBD by first ensuring the safety of clients, employees, and firm property, followed by conducting a financial and operational assessment, 59  rapidly recovering and resuming operations, enabling clients to continue transacting business, and safeguarding the firm’s books and records. If it is determined that the firm cannot continue its business, we will promptly advise our clients and other business relationships and assist them with the next steps as appropriate for our business model. BCP Summary While no contingency plan can eliminate all risks of service interruption, Compound's BCP strives to mitigate all reasonable risks while keeping up with changes to the firm's operations, structure, business, and location (as applicable). Our BCP - which is subject to revision, anticipates two kinds of SBDs: internal and external. Internal SBDs affect only the firm's ability to communicate and do business, such as a fire in the building. External SBDs prevent the operation of the securities markets for several firms and include a terrorist attack, a city flood, or a wide-scale regional disruption. Our BCP addresses mission-critical systems, office closing/relocation procedures, and the alternative physical location of employees. Operational risk systems and assessment procedures are defined to ensure continued communication with clients and employees and our critical business constituents, banks, counterparties, and regulators. A Succession Plan is in place in the event of key personnel absence, as are procedures for the safety of the data backup and recovery of firm books and records. Further, Compound requests its primary internal and external application providers to periodically test their backup capabilities to ensure that they can promptly provide the critical information and applications needed to continue or resume the firm's business in an emergency or SBD situation. When a minor or significant event occurs or appears to be developing, Compound's Disaster Recovery Executive Coordinator ("DREC") will be notified. Upon notification or becoming aware of an SBD event, the DREC will implement BCP emergency procedures, secure the headquarters as much as possible, refer to actions contained within our complete BCP, and advise all employees to contact the DREC directly at 404-596-4435. If a business disruption affects only Compound or a specific area within the firm, Compound will transfer its operations to a local worksite. In a disruption affecting the firm's business district, city, or region, operations will be transferred to an alternate worksite outside of the affected area. In either situation, the Adviser plans to continue conducting business and notify its clients how to contact the firm through a voice message reached via its main phone number and notification provided on its website. Telephone service will continue at any alternate worksites, and regular work processes will resume at the alternate location(s). Recovery times may vary depending on the nature and severity of the disruption; however, the recovery time objective for mission-critical operations is 0-72 hours. If the significant business disruption is so severe that it prevents the firm from conducting business, Compound will update its voice message and website appropriately, according to the BCP's provisions. For additional information on our BCP or questions, please contact us as follows: 115 Broadway, 5th Floor New York, NY 10006 Telephone: (888) 533-9364 www.compoundplanning.com Information Security Program Compound maintains an Information Security Program designed to reduce the risk that clients' personal and confidential information is breached. Please contact us directly at the above number with any questions regarding this Program. Privacy Practices Your relationship with us is based on trust and confidence. This privacy policy ("Privacy Policy" or “Policy”) describes the ways Compound Planning, Inc. collects, stores, uses, discloses, and protects the privacy of the personally identifiable and non- personally identifiable information we may collect from you or that you may provide. Our goal is to treat the information you furnish us with the utmost respect, following this Policy and safeguard and protect the information you have provided securely and professionally. We remain committed to this objective. 60  What is Personally Identifiable Information? Personally identifiable information ("PII") describes the information associated with you. It can be used to identify you and includes your name, address, phone number, zip code, e-mail address, and other similar data. Non-personally identifiable information (“non-PII”) is information that does not identify a specific person or is publicly available. Non-PII may include, for example, your IP address, browser type, domain names, access dates, and similar information. Categories of Information We Collect The personal information we collect and share will depend on the product or service. Confidential personal data collected about you can include, but not be limited to: ● ● ● information we receive from you via applications or other forms, such as your name, address, phone or social security number, occupation, assets, income, investment experience and other financial and family information, and information about your transactions with us or the brokerages, banks, and custodians with whom you hold investment or cash accounts, including account numbers, holdings, balances, transaction history, and other financial and investment activities. How We Collect Your Information We collect your personal information; for example, when you seek investment advice, tell us about your investment portfolio(s), open an account, make account deposits or withdrawals, or provide your income details. We also collect your personal information from others, such as other companies. We do not knowingly solicit information from or market our products or services to children. How We Use Your Information We may use information that we collect about you or that you provide to us, including any personal information, for any purpose, including but not limited to: compare information for accuracy and record verification, improve, modify, customize, and measure our services, ● personalize our contact with you, or verify your identity when accessing our services, ● ● provide information, materials, products, or the services you request, ● ● develop new products and services, ● send you administrative messages, content, and other services and features in which we believe you may be interested, ● provide you with information about our products and services, including while you are on our website online services or after you visit such online services, contact you for the potential purchase of insurance or other financial products, ● ● operate, provide, improve, and maintain our website to prevent abusive and fraudulent use of our website or ● enforce our Terms of Use and any other agreements between you and our firm, and for any other administrative and internal business purposes permitted by law. Sharing Non-Public Personal & Financial Information Financial companies must share customers' personal information to run their everyday business and provide services. Even when required to do this, we are committed to the protection and privacy of your personal and financial information. We will share your personal information with only those non-affiliated third-party service providers authorized to use your data as necessary to support our business operations, such as: for marketing services, ● when necessary to complete an account transaction, such as with the clearing firm or account custodians, ● when required to maintain or service an account, ● ● when requested by a fiduciary or beneficiary on the account, ● when required by a regulatory agency or for other reasons required or permitted by law, 61  ● ● ● ● ● ● to our attorneys, accountants, or compliance consultants, to provide customer service or resolve customer disputes, to provide data storage, payment, or technology support and services, or for risk solution provisions, analytics, or fraud prevention, in connection with a sale or merger of our business, or in any circumstance that requires your instruction or consent. The personal information we share for business purposes may include any categories of personal information identified in this Privacy Policy that we may collect. Protection of Personal Information We maintain various security measures to protect against the loss, misuse, and alteration of the information under our control. We restrict access to personal and account information to only those employees who need to know the information to provide products or services to you. Physical, electronic, and procedural safeguards are in place to guard client data using security measures that comply with federal law, such as computer protection, secured files, and buildings. Finally, although no business can wholly guarantee that information will remain free from unauthorized access, use, disclosure, or alteration, we make consistent, diligent, and good-faith efforts to maintain information security, utilizing safety measures designed to prevent unauthorized access or usage. Internet Use You can visit us on the Internet at www.compoundplanning.com without telling us who you are or revealing any information about yourself, including your e-mail address. In this case, our web servers may collect the domain name you used to access the Internet, such as www.aol.com, the website you came from and visited next, and other data. We use this data to monitor site performance and make the site more accessible and convenient. (Please see our Terms of Service here: https://legal.compoundplanning.com/terms-of-service.) Sharing Information & Consumer Choice When you provide information to us, we may share your information, to the extent provided by applicable law, with our affiliated companies and third parties to fulfill your requests and offer you other services that may interest you. Your information is not shared with any third party unless you request it or it is permitted by law. Under no circumstances will we sell or transfer your information to any ad network, ad exchange, data broker, or other advertising or monetization-related service. We may also aggregate statistics about our customers, sales, traffic patterns, and services and provide these statistics to third parties; however, when we do, the statistics will exclude any personal information that identifies individuals. We will not provide your personal information to mailing list vendors or Promoters. We require strict confidentiality in our agreements with unaffiliated third parties that need access to your personal data, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your records as the law permits. Further, federal law allows you to limit sharing information about your creditworthiness for affiliates' everyday business purposes, to affiliates from using your information to market to you, and to share with non-affiliates to market to you. State and international laws and individual companies may provide additional rights to limit sharing. (Please contact us directly for specific state and residence privacy requirements.) Former Customers Personally identifiable information about you will be maintained while you are a client and for the crucial period after that, as federal and state securities laws require, if you close your account(s) or become an inactive customer. After that time, information may be destroyed. Accessing or Correcting Your Information You may view the data we have collected from us by sending a request to the address below. If you believe that an error has been made in the accuracy of the information collected from you, we will correct such error upon adequate verification of the error and the person's identity seeking the correction. If you wish to access, remove, or correct any personally identifying information you have supplied to us or have any questions about this Privacy Policy, you may contact us by sending a letter to the address on the cover of this Brochure. 62  Use of Artificial Intelligence Compound Planning, Inc. may utilize artificial intelligence (“AI”) technologies to enhance operational efficiency and improve client services. These applications are limited to administrative and client service-related functions, such as meeting preparation, note-taking, CRM updates, and task management. AI is not used in the investment selection process or in formulating specific investment advice. While AI can streamline client engagement and reduce administrative burdens, its use introduces certain risks, including the potential for inaccuracies, decision-making errors, and data confidentiality concerns. For example, generative AI tools may inadvertently expose sensitive or personally identifiable information if not properly safeguarded. To mitigate these risks, Compound has implemented robust data protection protocols, including encryption, access controls, and regular security assessments. Staff are trained to handle sensitive data with care, and all third-party vendors are required to adhere to strict compliance and data security standards. Compound continuously evaluates the performance and regulatory alignment of its AI technologies to ensure they are deployed in accordance with fiduciary obligations and applicable laws. Regulation S-P: Incident Response Program & Notification In the Event of A Data Breach Although Compound Planning, Inc. makes reasonable efforts to maintain the security of client information, no firm or individual can guarantee that shared data will remain entirely free from unauthorized access, use, disclosure, or alteration. In the event that personally identifiable information is compromised, Compound will comply with all applicable federal and state laws in notifying affected individuals. To meet the requirements of the Securities and Exchange Commission’s May 2024 amendments to Regulation S-P, Compound has adopted a formal “Incident Response Program.” This written program is designed to detect, respond to, and recover from unauthorized access to or use of nonpublic personal information. It includes procedures for assessing the nature and scope of any breach, identifying affected individuals, and mitigating potential harm. If a data breach involving sensitive client information occurs, Compound will notify affected individuals as soon as practicable, and no later than 30 days after becoming aware of the incident. The notification will include: ● a description of the breach, ● ● the types of information compromised, and recommended steps for individuals to protect themselves. These procedures reflect Compound’s broader commitment to safeguarding client data and maintaining full compliance with applicable federal and state privacy regulations, including fiduciary obligations under the Investment Advisers Act of 1940. Changes to Our Privacy Policy We reserve the right to modify or supplement our Privacy Policy statement at any time. If we make any material changes, we will notify our existing clients and update our website to reflect such changes, including disclosing the Policy's last revised date. For additional information on our privacy practices or questions, please contact us as follows: 115 Broadway, 5th Floor New York, NY 10006 Telephone: (888) 533-9364 www.compoundplanning.com 63