DRAPER ASSET MANAGEMENT, LLC

Draper Asset Management LLC Form ADV Part 2A – Disclosure Brochure Effective: March 30, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Draper Asset Management LLC (“Draper Asset Management” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (631) 361-4925. Draper Asset Management is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Draper Asset Management to assist you in determining whether to retain the Advisor. Additional information about Draper Asset Management and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 148136. Draper Asset Management LLC 116 Terry Road, Smithtown, NY 11787 Phone: (631) 361-4925 https://www.draperasset.com/  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Draper Asset Management. Draper Asset Management believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Draper Asset Management encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes Although there have been no material changes to this Disclosure Brochure since the last annual amendment filing on March 26, 2025, the Advisor notes that revisions were made in the Brochure to conform with its existing practices, including but not limited to the removal of all references to performance-based fees, client referral fees, Northeastern Partners LLC, and Union Partners Advisors, LLC – which are all inapplicable to the Advisor’s business practices. Additionally, the Advisor has revised its Disclosure Brochure to enhance clarity and streamline the presentation of its disclosures. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually, and if a material change occurs. At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 148136. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (631) 361-4925. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 2 https://www.draperasset.com/  Item 3 – Table of Contents Item 1 – Cover Page Item 2 – Material Changes 1 2Item 3 – Table of Contents 2Item 4 – Advisory Services 4A. Firm Information 4B. Advisory Services Offered 4C. Client Account Management 5D. Wrap Fee Programs 5E. Assets Under Management 5Item 5 – Fees and Compensation 5A. Fees for Advisory Services 5B. Fee Billing 6C. Other Fees and Expenses 6D. Advance Payment of Fees 6E. Compensation for Sales of Securities 6Item 6 – Performance-Based Fees and Side-By-Side Management 6Item 7 – Types of Clients 6Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss 7A. Methods of Analysis 7B. Risk of Loss 7Item 9 – Disciplinary Information 8Item 10 – Other Financial Industry Activities and Affiliations 9Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 9A. Code of Ethics 9B. Personal Trading with Material Interest 9C. Personal Trading in Same Securities as Clients 9D. Personal Trading at Same Time as Client 9Item 12 – Brokerage Practices 9A. Recommendation of Custodian[s] 9B. Aggregating and Allocating Trades 10Item 13 – Review of Accounts 10A. Frequency of Reviews 10B. Causes for Reviews 10C. Review Reports 11Item 14 – Client Referrals and Other Compensation 11A. Compensation Received by Draper Asset Management 11B. Compensation for Client Referrals 11Item 15 – Custody 12Item 16 – Investment Discretion 12Item 17 – Voting Client Securities 12Item 18 – Financial Information 12Privacy Policy 13 Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 3 https://www.draperasset.com/  Item 4 – Advisory Services A. Firm Information Draper Asset Management LLC (“Draper Asset Management” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of New York. Draper Asset Management was founded in October 2008 and is owned and operated by Robert F. Draper Jr. (Managing Member and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Draper Asset Management. B. Advisory Services Offered Draper Asset Management offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and charitable organizations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Draper Asset Management's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Draper Asset Management provides customized investment advisory solutions for its Clients. This is achieved by providing discretionary investment management and advisory services. Draper Asset Management works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Draper Asset Management will then construct an investment portfolio, consisting predominantly of individual stocks, bonds, and/or options contracts to achieve the Client’s investment goals. The Advisor may also utilize Real Estate Investment Trusts (“REITs”), and other types of investments, as appropriate, to meet the needs of its Clients. As part of the Advisor’s overall investment process, the Advisor may hold varying levels of cash in client accounts based on the client’s investment objectives, financial goals, liquidity needs, or in response to market conditions and volatility. In certain circumstances, cash positions may be held for extended periods while the Advisor evaluates investment opportunities or manages risk, which may reduce the account’s participation in market gains during those periods. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Draper Asset Management’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Draper Asset Management will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Draper Asset Management evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Draper Asset Management may redistribute investment allocations to diversify the portfolio. Draper Asset Management may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Draper Asset Management may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Draper Asset Management accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 4 https://www.draperasset.com/  Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging Draper Asset Management to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Draper Asset Management, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – Draper Asset Management will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – Draper Asset Management will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – Draper Asset Management will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Draper Asset Management does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Draper Asset Management. E. Assets Under Management As of December 31, 2025, Draper Asset Management manages $230,959,228 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in arrears of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the calendar quarter. Investment advisory fees are 1.25% annually. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management (including assets held in cash) with the Advisor. All securities held in accounts managed by Draper Asset Management will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 5 https://www.draperasset.com/  The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of those commissions, fees, or costs. The Advisor does not charge Clients investment advisory fees for cash management only accounts, or assets under advisement (“AUA”) accounts. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor and deducted from the Client’s account[s] at the Custodian on a quarterly basis. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Draper Asset Management at the end of each quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the investment advisory fee. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Draper Asset Management, in connection with investments made on behalf of the Client’s account[s]. The Advisor's recommended Custodian may charge commissions, transaction fees, and handling fees. The Client is responsible for all fees charged by the Custodian, as applicable. The fees charged by Draper Asset Management are separate and distinct from these custody and execution fees. In addition, all fees paid to Draper Asset Management for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Draper Asset Management, but would not receive the services provided by Draper Asset Management, which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Draper Asset Management to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees Draper Asset Management does not take advance payment of fees from its Clients. E. Compensation for Sales of Securities Draper Asset Management does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Draper Asset Management does not charge performance-based fees for its investment advisory services. The fees charged by Draper Asset Management are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Draper Asset Management does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Draper Asset Management offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and charitable organizations. Draper Asset Management generally does not impose a minimum relationship size. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 6 https://www.draperasset.com/  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Draper Asset Management primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from Draper Asset Management are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of evaluating the company's financial situation, understanding their role in the ecosystem, any possible macroeconomic headwinds or tailwinds, or any intrinsic value of the company that might not be fully appreciated by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Draper Asset Management generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Draper Asset Management will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Draper Asset Management may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Draper Asset Management will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. The following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 7 https://www.draperasset.com/  on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For Example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). Equity (Stock) Risks Common stocks are susceptible to general stock market fluctuations and to volatile increases or decreases in value as market confidence in and perceptions of their issuers change. If an investor held common stock or common stock equivalents of any given issuer, they may be exposed to greater risk than if they held preferred stocks and debt obligations of the issuer. Preferred stocks can be affected by interest rate and liquidity risks (described in adjacent paragraphs). Also note that their dividend payment is not guaranteed; some are subject to a call provision, meaning the issuer can redeem its preferred shares on demand, and usually when interest rates have fallen. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Draper Asset Management or its owner. Draper Asset Management values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 148136. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 8 https://www.draperasset.com/  Item 10 – Other Financial Industry Activities and Affiliations Draper Asset Management is not a broker-dealer, and does not does not manage futures. Draper Asset Management does not use independent managers or advisers to manage its Client’s portfolios. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Draper Asset Management has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Draper Asset Management (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Draper Asset Management and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Draper Asset Management’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (631) 361-4925. B. Personal Trading with Material Interest Draper Asset Management allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Draper Asset Management does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Draper Asset Management does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Draper Asset Management allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures described in the Code of Ethics. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Draper Asset Management requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Draper Asset Management allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Draper Asset Management, or any Supervised Person of Draper Asset Management, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Draper Asset Management does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Draper Asset Management to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Draper Asset Management does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Draper Asset Management does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 9 https://www.draperasset.com/  recommended by Draper Asset Management. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Draper Asset Management may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. The Advisor currently recommends that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits. Please see Item 14 – Client Referrals and Other Compensation below. The following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Draper Asset Management does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Draper Asset Management does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Draper Asset Management will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Draper Asset Management will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Draper Asset Management will execute its transactions through the Custodian as authorized by the Client. Draper Asset Management may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Robert Draper Jr., Chief Compliance Officer of Draper Asset Management. Formal reviews are generally conducted at least annually. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Draper Asset Management if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 10 https://www.draperasset.com/  C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Draper Asset Management Draper Asset Management is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Draper Asset Management does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Draper Asset Management may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Draper Asset Management may receive non- compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like the Advisor. As a registered investment advisor participating on the Schwab Advisor Services platform, the Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits can influence the Advisor's recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab may provide participating advisors with access to technology, research, discounts and other services such as deducting advisory fees directly and providing access to Client statements. In addition, the Advisor has access to duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit each Client. Services that May Only Benefit the Advisor – Schwab may also offer other services to the Advisor that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates an incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. The Advisor currently believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 11 https://www.draperasset.com/  Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have policies and procedures to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Draper Asset Management has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Draper Asset Management. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Draper Asset Management will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Draper Asset Management does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Draper Asset Management, nor its management, have any adverse financial situations that would reasonably impair the ability of Draper Asset Management to meet all obligations to its Clients. Neither Draper Asset Management, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Draper Asset Management is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 12 https://www.draperasset.com/  Privacy Policy Effective: April 15, 2026 Our Commitment to You Draper Asset Management LLC (“Draper Asset Management” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Draper Asset Management (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Draper Asset Management does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements questionnaires and suitability Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment documents Other information needed to service account The Advisor’s SMS messaging provides the Client with timely and relevant communications directly from the Advisor. Client’s can expect to receive periodic messages. Messages are related to day to day services, which include but are not limited to, meeting confirmations, service commentary, market updates or addressing your specific needs and/or requests. Message frequency will vary based on your needs and/or our action items. We will not share your phone number with any third parties for marketing purposes. You can cancel SMS service at any time. Just reply STOP. Once you reply STOP to us, we will send a message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just notify us via email or text and we will start sending SMS messages to you again. If you are experiencing issues with the messaging program you can reply with the word HELP for more assistance, or you can get help directly at info@draperasset.com. Carriers are not liable for Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 13 https://www.draperasset.com/  delayed or undelivered messages. As always, message and data rates may apply for any messages exchanged with this number. If you have any questions about your text or data plan, contact your phone provider. How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our employees are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No to: processing Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Marketing Purposes Draper Asset Management does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Draper Asset Management or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons documented to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Draper Asset Management does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (631) 361-4925. Draper Asset Management LLC 116 Terry Road, #16, Smithtown, NY 11787 Phone: (631) 361-4925 Page 14 https://www.draperasset.com/