QUORUS INC.

Quorus Inc. Form ADV Part 2A – Disclosure Brochure Effective: April 3, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Quorus Inc. (“Quorus” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (929) 560-2588. Quorus 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 Quorus to assist you in determining whether to retain the Advisor. Additional information about Quorus 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# 323161. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io  Item 2 – Material Changes Quorus filed to become a registered investment advisor with the SEC on April 3, 2026. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 Item 4 – Advisory Services ..................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 6 D. Wrap Fee Programs ....................................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................................ 6 Item 5 – Fees and Compensation ........................................................................................................................... 6 A. Fees for Advisory Services ............................................................................................................................................. 6 B. Fee Billing ...................................................................................................................................................................... 7 C. Other Fees and Expenses .............................................................................................................................................. 8 D. Advance Payment of Fees and Termination ................................................................................................................... 8 E. Compensation for Sales of Securities ............................................................................................................................. 9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................... 9 Item 7 – Types of Clients ......................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................. 9 A. Methods of Analysis ....................................................................................................................................................... 9 B. Risk of Loss .................................................................................................................................................................. 11 Item 9 – Disciplinary Information ......................................................................................................................... 16 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 16 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 16 A. Code of Ethics .............................................................................................................................................................. 16 B. Personal Trading with Material Interest ......................................................................................................................... 16 C. Personal Trading in Same Securities as Clients ........................................................................................................... 17 D. Personal Trading at Same Time as Client .................................................................................................................... 17 Item 12 – Brokerage Practices .............................................................................................................................. 17 A. Recommendation of Custodian[s] ................................................................................................................................. 17 B. Aggregating and Allocating Trades ............................................................................................................................... 18 Item 13 – Review of Accounts .............................................................................................................................. 18 A. Frequency of Reviews .................................................................................................................................................. 18 B. Causes for Reviews ..................................................................................................................................................... 18 C. Review Reports ............................................................................................................................................................ 18 Item 14 – Client Referrals and Other Compensation .......................................................................................... 18 A. Compensation Received by Quorus ............................................................................................................................. 18 B. Client Referrals from Solicitors ..................................................................................................................................... 19 Item 15 – Custody .................................................................................................................................................. 19 Item 16 – Investment Discretion ........................................................................................................................... 19 Item 17 – Voting Client Securities ........................................................................................................................20 Item 18 – Financial Information ........................................................................................................................... 20 Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 3  Item 4 – Advisory Services A. Firm Information Quorus Inc. (“Quorus” or the “Advisor”) is a registered investment advisor with the SEC, located in the State of Connecticut. The Advisor is organized as a Corporation under the laws of the State of Delaware. Quorus was founded in July 2022 and is principally owned and operated by John W. Hill, CFA® (Chief Executive Officer and Chief Compliance Officer) and Scott R. Shumway (Chief Technology Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Quorus. Please contact John W. Hill (Chief Executive Officer and Chief Compliance Officer) with any questions pertaining to this Disclosure Brochure. B. Advisory Services Offered Quorus is a technology-powered asset manager that delivers personalized investment solutions. Quorus provides professional portfolio management services to Registered Investment Advisors (“RIAs”) and other wealth managers who serve individuals, families, family offices, businesses, small endowments and foundations (each referred to as a “Client”). Quorus specializes in creating and managing custom portfolios that are unique to each investor and reflect their individual values. Our core offering is delivered as a Separately Managed Account (“SMA”) for each end investor. 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. Quorus’ 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. The Quorus platform provides access to investment strategies or models (each a “Model”) that Clients can choose for their accounts. Each Model is provided by either Quorus, a traditional asset manager, a hedge fund or alternative investment manager (each a “Third Party Model Provider”), or an index provider (each an “Index Provider”). Excluding Index Providers, all are registered either with the SEC or one or more state securities regulator or affiliated with same. • Quorus Models are developed internally by Quorus and seek to mirror the strategies of popular exchange- traded fund (“ETF”) strategies. Quorus will reference public filings and holdings data to provide representative performance of these models with their comparable ETF. • Third-Party Models are investment strategies provided by a Third Party Model Providers. A Model Manager provides Quorus with securities and weights and transactional history associated with the Model in order for Quorus to create and maintain the Model Portfolio for its Clients. • Index Provider models seek to track the return of a target benchmark index. Quorus delivers portfolio management services primarily as a sub-advisor to registered investment advisors (“RIAs”) and wealth managers (herein an “Advisor Client”) for the underlying investors. Quorus may, in certain circumstances, deliver portfolio management services direct to Clients without a primary RIA (herein a “Direct Client”). Portfolio Management Services Quorus delivers portfolio management services on behalf of other RIAs and wealth managers on a sub-advisory basis. Advisor Clients select the desired model for a Client SMA from the Quorus platform and provide Quorus with the amount of funds, either in terms of dollars or as a percent of the account’s value to be invested in the Model. Quorus will implement the positions in proportion to the amount of assets invested. Quorus will rebalance positions automatically based on the drift parameters to bring the account in balance with the desired Model. Advisor Clients may also provide instructions to restrict the purchase or sale of certain securities in the SMA. Additionally, Advisor Clients can provide instructions to harvest taxable gains or losses in the SMA. If any Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 4  Advisor Client restrictions prevent Quorus from properly servicing the account, or if the restrictions would require Quorus to deviate from its standard suite of services, Quorus reserves the right to end the relationship. Quorus maintains a limited power of attorney to direct trading of each SMA (“Trading Discretion”) to purchase and sell securities in the SMA’s selected Custodian. Trading Discretion is granted to Quorus through a Sub-Advisory Agreement with an Advisor Client (“Advisor Sub-Advisory Agreement”). The Custodian may require an additional agreement from the Advisor Client to grant Trading Discretion to Quorus. An Advisor Client may choose to terminate the relationship with Quorus and revoke Trading Discretion of Quorus at any time. In sub-advisory arrangements, Quorus works closely with the Advisor Client to understand their investor’s Investment Policy Statement (“IPS”), and to integrate our portfolio management services in-line with the IPS. Sub- advisory arrangements may be provided on a discretionary or non-discretionary basis. In either arrangement, Quorus will work closely with the Advisor Client to deliver portfolio management services in-line with the investor’s needs and the specific mandate assigned to Quorus. Direct Clients In certain circumstances, Quorus offers ongoing portfolio management to Direct Clients. These services are tailored to the individual needs, goals, values, time horizon, and risk tolerance of each investor. For Direct Clients, Quorus creates an Investment Policy Statement (“IPS”), which outlines the client’s current situation (including risk tolerance level and cash flow needs) and constructs an asset allocation and portfolio that matches each Client's specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • Personal investment policy • • Asset allocation • Asset selection • Risk management • Transition management • Ongoing portfolio management • Regular rebalancing In carrying out these services, Quorus evaluates the suitability of current investments, carefully considering the Client’s risk tolerance, time horizon, objectives, and values as documented in the IPS. Quorus typically provides portfolio management services on a discretionary basis. However, the Client may also engage on a non- discretionary basis. In a discretionary arrangement, Quorus receives such authority from the Client to effect securities selection and trading directly on their behalf as part of the Investment Management Agreement. Third-Party Sponsor Clients Quorus also provides services and solutions to registered broker-dealers, banks, trust companies, and larger registered investment advisors (herein “Third-Party Sponsors”) that want to offer their own third-party platforms (“Third-Party Platforms”) to their advisors and underlying investors. Third-Party Sponsors are responsible for selecting Models and Model Managers to participate on Third- Party Platforms. Third-Party Sponsors can charge different fee schedules than Quorus. Third-Party Sponsors maintain their own custodial accounts and/or custodial relationships and offer execution and clearing services. Third-Party Sponsors can offer additional services and have different requirements and qualifications for participating. Advisors should carefully review a Third-Party Sponsor’s Disclosure Brochure to understand the terms and conditions of the Third-Party Platform. Quorus’ 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. Quorus 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. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 5  Quorus evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Prior to introducing Pennsylvania clients to another investment adviser (“IA”), Quorus will be responsible for determining whether the investment advisory firm is properly licensed, notice filed, or exempt from registration with the Pennsylvania Department of Banking and Securities. 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 Quorus 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 – Quorus, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Quorus 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 – Quorus will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Quorus will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Quorus does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Quorus. E. Assets Under Management As of March 31, 2026, Quorus manages $148,224,228 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 Sub-Advisory Clients Sub-advisory fees are typically charged quarterly, in arrears of the calendar quarter. However, the Advisor and the Client may instead establish a fee arrangement for fees to be paid in advance of the quarter. The fee methodology will be agreed upon in the sub-advisory agreement. Fees are based on the market value of assets under management at the end of the respective calendar quarter. Fees range from 0.10% to 2.00% annually based on several factors, Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 6  including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions, Third Party Model Providers, and other complexities may be charged fee at the higher end of the range above. At no point will the Client’s fee exceed 3% of assets under management. The 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 with the Advisor. All securities held in accounts managed by Quorus will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Fees to Quorus cover the investment strategy provided by the Model Manager and the day-to-day account management provided by Quorus. In cases where clients utilize a Third Party Model Provider or an Index Provider, Quorus will pay a portion of the fee to the selected model providers. In cases where Quorus is the model provider, all fees are retained by Quorus. 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 these commissions, fees, and costs. Please note that lower fees for comparable services may be available from other sources. We encourage all Clients to evaluate our services and fees relative to other investment advisory service providers. Direct Clients Investment management fees for direct Clients are typically charged quarterly, in arrears of the calendar quarter. However, the Advisor and the Client may instead establish a fee arrangement for fees to be paid in advance of the quarter. The fee methodology will be agreed upon in the investment management agreement. Fees are based on the market value of assets under management at the end of the respective calendar quarter. Fees range from 0.10% to 2.00% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions, Third Party Model Providers, and other complexities may be charged fee at the higher end of the range above. The 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 with the Advisor. All securities held in accounts managed by Quorus will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Fees to Quorus cover the investment strategy provided by the Model Manager and the day-to-day account management provided by Quorus. In cases where clients utilize a Third Party Model Provider or an Index Provider, Quorus will pay a portion of the fee to the selected model providers. In cases where Quorus is the model provider, all fees are retained by Quorus. 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 these commissions, fees, and costs. Please note that lower fees for comparable services may be available from other sources. We encourage all Clients to evaluate our services and fees relative to other investment advisory service providers. B. Fee Billing Sub-Advisory Clients Sub-advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian, unless otherwise agreed in the sub-advisory agreement. If the fees are deducted from the account[s], the Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] for the respective billing period. The amount due is calculated by applying the quarterly rate (annual rate Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 7  divided by a proration factor calculated as the number of days in the quarter divided by 365) to the total assets under management with Quorus at the end of the respective quarter-end date. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. In addition, the Advisor will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Quorus to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Direct Clients Investment management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] for the respective billing period. The amount due is calculated by applying the quarterly rate (annual rate divided by a proration factor calculated as the number of days in the quarter divided by 365) to the total assets under management with Quorus at the end of the respective quarter-end date. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. In addition, the Advisor will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Quorus to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Quorus, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Quorus are separate and distinct from these custody and execution fees. In addition, all fees paid to Quorus 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. The Client may also be charged margin fees, tax/transfer fees, wire/transfer and other account fees by the Custodian. 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 Quorus, but would not receive the services provided by Quorus 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 Quorus to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Quorus may be compensated for its investment management services in advance of the quarter in which services are rendered. The payment methodology is defined in the agreement between the Client and the Advisor. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. If the Client has not received the Disclosure Brochure and Brochure Supplement within forty-eight (48) hours the Client may cancel the agreement within five (5) business days of signing the agreement. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement without penalty. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 8  unearned, prepaid fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Quorus 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 fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Quorus does not charge performance-based fees for its investment management or sub-advisory services. The fees charged by Quorus are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Quorus 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 Quorus is a technology-powered asset manager that delivers personalized investment solutions. Quorus provides professional portfolio management services to RIAs and other wealth managers who serve individuals, families, family offices, businesses, small endowments and foundations. Quorus may also provide its services to Direct Clients, which are individuals and high net worth individuals. Quorus generally requires a minimum relationship size of $250,000 to effectively implement its investment process. Quorus may reduce this minimum at its sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Quorus focuses both on analyzing Models and ensuring Clients have the material information necessary to determine whether a particular Model meets a Client’s investment objectives. Advisors should consult the Quorus platform for more details regarding the Model Manager’s method of analysis and the investment strategy offered by the Model. Please consult Quorus for more information on a particular Model. Quorus analyzes a Model Manager’s background, including reviewing the firm’s investment offerings, the firm’s operational history, and the firm’s regulatory history. Quorus will further review the backgrounds of key principals, including regulatory history, credit history, in terms of any judgements, liens, and criminal history. The primary objective of the Model Manager due diligence review is to identify any issues that could affect the Model Manager’s ability to consistently deliver the same level of investment advice in the future as was provided historically. After reviewing each Model Manager, Quorus will analyze each Model independently. The Model analysis determines (i) if a particular Model can be delivered through the Quorus platform, (ii) which account types and configurations are necessary to implement the Model in a SMA, (iii) which custodians can support both the necessary account configurations and the strategy underlying the Model, and (iv) the minimum investment necessary to effectively implement the Model. Factors used in the analysis of a particular Model include, but are not limited to, the types of securities held in the Model, the number of unique positions held in the Model, and the activity levels of trading in the Model. In certain cases, Advisors if they choose, can request Models from asset managers that have not completed the Quorus Model Manager due diligence process. Quorus will make these Models available to the requesting Advisor. When a Client selects a Model for a particular SMA, Quorus analyzes the SMA’s configuration, including margin types, option permissions, registration types and custodian, as well as the funds available for allocation to the selected Model, before approving a Model selection. Clients are ultimately responsible for determining whether a particular Model meets the Investment Objectives for the SMA. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 9  For each transaction in the SMA, Quorus will analyze the transaction to compare the benefits of tracking the selected Model as closely as possible to the impact of the inherent transactional costs, which could include brokerage commissions, bid- ask spreads, markups and markdowns, sales loads, redemption penalties, regulatory fees and taxes. Quorus does not attempt to do analysis on the investment merits of a security or group of securities. Quorus relies on the Model Manager to determine whether a particular security is appropriate for a particular Model and on the User to determine whether a particular Model is appropriate for a particular SMA or if a particular security is appropriate in a particular SMA. Quantitative analysis involves assessing securities based on a set of measurable factors (as distinguished from qualitative considerations such as the character of management or the state of employee morale). Quorus’ quantitative analysis may use, but not be limited to, statistical risk factors, published financial ratios, market data, and environmental, social and governance scores. The most common investment strategies utilized by the Models on Quorus include fundamental analysis for securities selection, technical analysis for securities selection, quantitative analysis for securities selection, strategic asset allocation, tactical asset allocation, and global macro analysis. Long/Short Investment Strategy The Firm may utilize a long/short investment strategy in certain client accounts. A long/short strategy seeks to generate returns by establishing long positions in securities the Firm believes are undervalued and short positions in securities the Firm believes are overvalued or otherwise expected to decline in price. The objective of this strategy may include capital appreciation, risk mitigation, or reduction of overall portfolio volatility relative to traditional long-only investment strategies. In implementing this strategy, the Firm may sell securities short, meaning the Firm borrows securities from a broker-dealer and sells them in the open market with the expectation of repurchasing them later at a lower price. If the security declines in value, the Firm may repurchase it at the lower price and return it to the lender, realizing a gain (net of transaction costs and borrowing expenses). If the security increases in value, the Firm will incur a loss when repurchasing the security at a higher price. Short selling involves significant risk and is considered a speculative investment technique. Unlike long positions, where the maximum loss is generally limited to the amount invested, short positions involve theoretically unlimited risk because there is no cap on how high the price of a security may rise. In addition, short positions are subject to risks including, but not limited to: • Short squeezes and forced buy-ins • Margin calls and increased collateral requirements • Borrowing costs and stock loan availability risk • Counterparty and broker-dealer risk • Increased portfolio turnover and transaction costs • Market, sector, and macroeconomic risk • Liquidity risk Long/short strategies may involve the use of margin, which magnifies both gains and losses. The use of margin results in interest expenses and may require the liquidation of portfolio positions to meet margin calls at times that may be disadvantageous. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 10  There can be no assurance that a long/short strategy will be successful. The effectiveness of the strategy depends on the Firm’s ability to correctly identify relative mispricing between securities. If the Firm’s analysis proves incorrect, both long and short positions may result in losses. During periods of strong directional markets (particularly strong upward markets), short positions may significantly detract from performance. Long/short strategies may result in higher portfolio turnover, which may increase brokerage costs and may result in taxable short-term capital gains in taxable accounts. Clients should understand that long/short strategies are more complex and generally involve a higher degree of risk than traditional long-only investment strategies. Accordingly, such strategies may not be appropriate for all investors. All investments involve risk of loss, including the possible loss of principal. Past performance is not indicative of future results. Fundamental analysis attempts to identify the intrinsic value of a security by looking at economic and financial factors, including but not limited to the overall economy, industry environment, the financial condition of the company and the management team behind the company, to determine if the security is undervalued, indicating a buying opportunity, or overvalued, indicating a selling opportunity. Technical analysis attempts to utilize historical price and trade data to make predictions about future price movements. Proponents of technical analysis often use charts and pattern recognition to make buy and sell decisions of securities. Quantitative analysis attempts to create a mathematical model that utilizes securities data to determine if the security presents a buying opportunity or a selling opportunity. Factors can be based on the same or similar factors to fundamental analysis or on other quantifiable metrics. Strategic asset allocation attempts to build a portfolio of securities by focusing on broader asset classes. Proponents of strategic asset allocation believe that diversifying across asset classes, investors can achieve a specified risk and return profile, as measured by standard deviation and annualized returns (or similar metrics). Each asset class is given a specific ratio to the portfolio, and the portfolio is rebalanced occasionally to eliminate the impact of deviations for the target weights. Strategic asset allocation is commonly related to “Buy and Hold” strategies. Tactical Asset Allocation attempts to generate improved risk-adjusted returns by actively changing the portfolio weights of asset classes within a portfolio. Proponents of Tactical Asset Allocation will use discretionary or systematic approaches to rebalancing a portfolio. Discretionary approaches generally look for evidence of market sentiment to choose to remain in a particular portfolio weighting or to rebalance the portfolio. Systematic approaches typically look at imbalances between asset classes compared to historical norms to determine whether to rebalance the portfolio or maintain the current weightings. Global Macro Analysis attempts to take advantage of economic themes and trends at a very high level. Proponents look to broadly invest in positions that will profit from changes in the industrial landscape, global political environments, or growth rates in particular economies around the world. B. Risk of Loss 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. Following are some of the risks associated with the Advisor’s investment strategies: Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 11  Alternative Investment Risk - Alternative investments are speculative, involve a high degree of risk, including the potential loss of your entire investment, and are not suitable for all investors. A primary risk is their significant illiquidity, as there is no public market for these assets, and your ability to sell or redeem your interest is severely restricted. You must be prepared to hold the investment for an indefinite period, often for many years. Furthermore, these investments involve complex and subjective valuation, as their underlying assets often lack readily available market prices. They are also subject to high fees and expenses, which typically include both a management fee and a performance-based fee (or "carried interest") that will reduce your returns and may create an incentive for the fund manager to take greater risks. Finally, these Alternative Investments are not subject to the same regulatory oversight or transparency requirements as traditional investments like mutual funds, and they involve complex tax structures that typically generate a Schedule K-1, which can complicate your tax filing. Your investment success is highly dependent on the skill of a single manager, and you must carefully review the fund's specific offering documents (such as the Private Placement Memorandum) to understand the full details of the strategy, fees, and conflicts of interest before investing. Concentration Risk - the concentration of investments can cause a strategy to be susceptible to an increased risk of loss, including losses due to idiosyncratic risks that affect the strategies’ investments more than the market as a whole, to the extent that the strategies’ investments are concentrated in the securities of a particular issuer or issuers, country, group of countries, region, market, industry, group of industries, sector or asset class. Cybersecurity Risk - Quorus is a technology company that stores information about its business and Clients. This information may be susceptible to both intentional and unintentional breaches of the systems Quorus has set up to safeguard its information. The risk that information will be exposed can include but is not limited to the malicious actions of third parties to access confidential information and cyberattacks intended to disrupt Quorus’ business or inadvertent disclosure of information by a Quorus employee. Moreover, Quorus engages third-party vendors for a variety of services that may have access to stored Client data and other confidential information or may be relied on by Quorus to perform key business functions. If such a third party were to be hacked, a Client’s confidential information may be shared, Quorus may not be able to access key business functions required for it to carry on with its business. Economic and Political/Regulatory Risk - this type of risk can result in fluctuation in the value of securities due to political, geographical, economic and regulatory changes. Political or regulatory conditions can impact the operational and financial performance of companies, geographies, or industries specifically, as well as the market and benchmark performance as a whole. Equity Risk - equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions, and the general economic environments. ESG Data Risk - Quorus uses third-party data providers whose data may be missing, incomplete, or inaccurate. Data that was obtained by third parties can cause Quorus to improperly assess a company’s ESG risk. Additionally, ESG practices differ across regions and industries, and as a result, a company’s practices may materially differ from Quorus’ assessment. Some of the data used at Quorus is predictive based on historical data collected from third parties. Quorus will, in its sole discretion, continue to test models and update the frameworks as it sees fit. There are no assurances that these models are accurate or that they will help Clients achieve their financial objectives. Moreover, changes to the regulatory landscape may curtail Quorus’ ability to gather data and implement its sustainability related models. Health Crises, Pandemics, War, and Terrorism Risk - A Client is subject to the risk that significant events may impact a particular company, a region in which it operates, or impact the entire world. In the past, events like pandemics, terrorist attacks, and wars have influenced markets and have had adverse effects on companies' profits. These events may have negative long-term effects on world economies and markets more generally over the short and long terms. The risk of loss may increase during these periods, and a Client's overall portfolio performance can go down. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 12  Long-Term Trading Risk - long-term trading is generally designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose Clients to various types of risk that will typically surface at various intervals while the Client owns the investments. Market Risk - market value changes can result in long term investment strategies losing money over short periods due to short-term market movements and over longer periods during more prolonged market downturns. Non-U.S. Company Risk - non-US company securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Quantitative Model Risk - Quantitative analysis investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Sustainability Screening Risk - sustainability or other screening criteria limit the types and number of investment opportunities available and, as a result, strategies with screens may underperform other strategies or funds that do not have a sustainable focus or do not require companies to meet a sustainable standard. Tax-Managed Investing Risk - Quorus’ strategies that seek to enhance after-tax performance may be unable to realize strategic gains or harvest losses due to market volatility, among other possible factors. Quorus only monitors tax-loss harvesting opportunities and potential wash sales in client accounts enrolled with Quorus. The TLH Algorithm is designed to conduct a daily review of client accounts for tax-loss harvesting opportunities. When the tax-loss harvesting threshold is met, the TLH Algorithm will initiate a tax-loss harvesting trade recommendation for enrolled accounts. During this process, certain securities in the client’s account may be sold at a loss to offset potential capital gains (although Quorus does not monitor the type and amount of capital gains). The TLH Algorithm also recommend a buy order to replace the securities sold for tax-loss harvesting purposes with the securities that Quorus reasonably believes are not substantially similar to the one sold. The performance of the new securities may be better or worse than the performance of the securities that are sold for tax-loss harvesting purposes. The utilization of losses harvested through the strategy will depend upon the recognition of capital gains in the same or a future tax period, and in addition may be subject to limitations under applicable tax laws. Losses harvested through the strategy that are not utilized in the tax period when recognized generally may be carried forward to offset future capital gains, if any. Clients should consult with their professional tax advisors or check the Internal Revenue Service (“IRS”) website at www.irs.gov about the consequences of tax-loss harvesting in light of their particular circumstances and its impact on their tax return. Neither the tax-loss harvesting strategy, nor any discussion herein, is intended as tax advice, and Quorus does not represent that any particular tax consequences will be obtained. Market Neutral Risk - Trading risks in market-neutral strategies primarily come from two sources: differences in prices between related securities (including their derivatives), and changes in how volatile these price differences are. These risks can become more severe during times of market stress, which may hurt the performance of market-neutral portfolios. Additionally, these portfolios face risks from changes in credit spreads and potential defaults. The credit spread market often lacks efficiency and has limited trading activity, making it challenging to determine the right discount rates for valuing financial instruments. Fundamental Analysis Risk - Fundamental analysis investment strategies may not accurately predict a security’s intrinsic value. Economic conditions, industry developments, management decisions, accounting inaccuracies, or unforeseen events may cause actual performance to differ materially from expectations. Securities identified as undervalued may continue to decline in value, and those deemed overvalued may continue to rise, resulting in potential losses. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 13  Technical Analysis Risk - Technical analysis investment strategies rely on historical data to forecast future movements. There is no assurance that past patterns or trends will persist in the future. Market sentiment, sudden news events, or changes in liquidity can render technical indicators ineffective, leading to inaccurate trading signals and investment losses. Quantitative Analysis Risk - Quantitative analysis investment strategies using mathematical models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Model performance can also be adversely affected by inaccurate data inputs or unforeseen market conditions. Strategic Asset Allocation Risk - Strategic asset allocation investment strategies are based on long-term assumptions about asset class returns and risk relationships. There is no guarantee that these assumptions will remain valid over time. Changes in market conditions, economic cycles, interest rates, or geopolitical events may cause the performance of asset classes to deviate from expectations. Maintaining fixed asset allocations may also result in underperformance during certain market environments. Tactical Asset Allocation Risk - Tactical asset allocation investment strategies seek to improve returns through short- or medium-term shifts among asset classes. These strategies involve timing risk. This creates risk that changes in allocations may be made too early or too late to benefit from market movements. Frequent trading may also increase transaction costs and tax liabilities, and systematic or discretionary signals may fail to identify profitable opportunities, leading to losses. Global Macro Analysis Risk - Global macro investment strategies are subject to the risk that anticipated global economic, political, or market trends may not occur as expected. Unexpected geopolitical developments, government policy changes, currency fluctuations, and interest rate shifts may adversely affect investment outcomes. Because global macro strategies often involve significant exposure to international markets, they may also be subject to additional risks related to foreign exchange, emerging markets, and differing regulatory environments. Use of Leverage - Clients may use borrowed money (leverage) to increase their investments. While leverage can boost returns when investment gains exceed borrowing costs, it also creates risks: 1) losses become larger than they would be without borrowing, 2) clients may need to sell investments quickly at poor prices if lenders require additional collateral, 3) investment returns may not cover borrowing costs, 4) changes in interest rates on borrowed money can reduce profits. If investment values drop suddenly, clients might not be able to sell assets fast enough to repay loans, leading to even bigger losses. In difficult credit markets, obtaining leverage may become impossible, making it hard to execute certain investment strategies. If lenders suddenly demand repayment, clients may be forced to sell investments at unfair prices. Banks and dealers who provide financing can change their lending terms, collateral requirements, and valuation policies at their discretion. These changes - whether driven by market conditions or regulatory actions - may trigger large collateral calls, loss of financing, forced sales at poor prices, and defaults across multiple lending agreements. These problems can worsen if multiple lenders impose restrictions simultaneously. In extreme cases, clients may need to liquidate their entire portfolio at unfavorable prices, potentially losing all their invested capital. Short Selling Risk - When clients engage in short selling (betting against a security), they face unique risks. Potential losses can exceed their initial investment and grow rapidly without limit. A significant risk occurs when lenders of the borrowed securities demand their return on short notice. If this happens when many other short sellers are also being forced to return the same security (known as a "short squeeze"), clients may have to buy back the securities at much higher prices than for what they originally had sold them. This can force clients to purchase securities at the worst possible time and at significantly inflated prices. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 14  Tracking Error Risk - Tracking error is the divergence of the investment strategies’ performance from that of the adviser selected benchmark. Differences between securities selected by the strategy and those included in the selected benchmark, differences in transaction costs, differences in cash held, differences in timing of the accrual of or the valuation of dividends or interest, tax gains or losses contribute to tracking error. This risk may be heightened during times of increased market volatility or other unusual market conditions. Mutual Funds - Investing in mutual funds carries the risk of capital loss. Mutual funds are typically comprised of a group of underlying securities, and subject to risk arising from the individual issuers of the fund’s underlying securities. Mutual funds also carry the risk of fund level capital gains, as the funds are required by law to distribute capital gains to shareholders on an annual basis. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual value fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from its actual value during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to the underlying assets. Exchange Traded Funds (ETFs) - Similar to a mutual fund, an ETF is made up of a group of underlying securities, and thus are subject to risk arising from the individual issuers of the fund’s underlying securities. ETFs also are subject to annual capital gains distributions to shareholders. Unlike mutual funds, shares of ETFs are listed on securities exchanges, and are priced and traded throughout the market day at negotiated prices. As such, ETFs typically provide greater intraday liquidity than mutual funds. However, ETFs may experience abnormal pricing and limited liquidity under extreme market conditions. Investing in ETFs carries the risk of capital loss. The trading prices of an ETF’s shares may differ significantly from its actual value during periods of market volatility, which may, among other factors, lead to the ETF’s shares trading at a premium or discount to the underlying assets. Trades in an ETF are generally limited by the investment strategy employed. An investment in ETFs that track other asset categories is subject to the risks that impact the prices of such categories. In addition, investment techniques such as short selling and margin debt may be used with ETFs, which would expose the portfolio to the risks associated with those investment techniques. Equity - investment generally refers to buying shares of stock of a corporation in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases and is sold. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environment. Investing in Equities carries the risk of capital loss (sometimes up to a 100% loss in the case of a company bankruptcy). Fixed income - investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities. All fixed income securities carry interest rate risk (as interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities). Fixed income securities may also carry inflation risk, liquidity risk, call risk, and credit and default risks of both issuers and counterparties. Quorus will typically invest in fixed income securities via ETFs and/or Mutual Funds, where a group of fixed income securities is held, providing a level of diversification. Nonetheless, Fixed Income securities, including government issued securities, carry the risk of capital loss. Currencies, Commodities, and Real Estate investments provide return streams that typically have lower correlations with Equity and Fixed Income investments and may provide diversification and risk management benefits when employed within a portfolio. Quorus may invest client assets into foreign exchange (currencies), commodities including energy and agricultural commodities, precious metals, and other commodities, and publicly traded REITs. Quorus will likely invest in these asset types via exchange traded products (ETFs or ETNs) or mutual funds, however we may invest in individual assets in certain cases. These investments do carry the risk of extreme price movements, particularly in times of economic stress, and thus carry the risk of capital loss. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 15  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 Quorus or its management persons. Neither Quorus, Inc. nor any of its management persons have not been subject to any criminal or civil actions, administrative proceedings, or self-regulatory organization (“SRO”) proceedings. Quorus 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# 323161. Item 10 – Other Financial Industry Activities and Affiliations As part of its business, Quorus licenses Models from Third Party Model Providers and Index Providers for use by RIAs and Clients. As part of this process, Quorus will share fees with respect to the use of the Model. This includes but is not limited to Models from Quorus affiliate WisdomTree Asset Management, Inc. Similar arrangements have been made with our Third-Party Model providers and offered at the request of our Clients. WisdomTree, Inc., the parent company of WisdomTree Asset Management, Inc. (“WTAM”), holds a seed investment in Quorus Inc. As a result, Quorus is considered affiliated with WisdomTree through this ownership relationship. WTAM serves as an adviser to registered investment companies and develops asset-allocation models. WTAM is not subject to state notice filing requirements. Quorus operates exclusively as a tax-overlay and implementation manager. Its role is to partner with asset managers who create investment models and strategies, and to implement those strategies in a tax-aware manner on behalf of the Clients of RIAs. To facilitate this, Quorus licenses each Model from the relevant Third Party Model Provider or Index Provider to ensure Quorus has the appropriate rights and instructions necessary to implement the strategy accurately. Quorus does not otherwise recommend or select investment advisors for Clients. All Models created by Third Party model Providers are provided at the request of a Client or RIA. There is no conflict of interest with licensing models. In addition, neither Quorus nor its representatives are registered as or have pending applications to become a Broker-Dealer, Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. As applicable, Quorus will ensure that the other advisers are properly licensed and registered as an investment adviser prior to recommending other adviser to its Clients. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Quorus 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 Quorus (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Quorus and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Quorus’ 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 (929) 560-2588. B. Personal Trading with Material Interest Quorus allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Quorus does not act as principal in any transactions. In addition, the Advisor does Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 16  not act as the general partner of a fund, or advise an investment company. Quorus does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Quorus 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. 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. When trading for personal accounts, 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 Quorus 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 Quorus 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 Quorus, or any Supervised Person of Quorus, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Quorus does not have discretionary authority to select the broker-dealers/custodians for custody and execution services. The Client will engage the broker-dealers/custodians (herein the "Custodians") to safeguard Client assets and authorize Quorus to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Quorus does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade- by-trade basis. Where Quorus does not exercise discretion over the selection of the Custodians, it may recommend the Custodians to Clients for custody and execution services. Clients are not obligated to use the Custodians recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Quorus. However, the Advisor may be limited in the services it can provide if the recommended Custodians are not engaged. Quorus may recommend the Custodians 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 Custodians’ offices. Quorus will generally recommend that Clients establish their account[s] at either Charles Schwab & Co., Inc. (“Schwab”) or Fidelity Brokerage Services, LLC (“Fidelity”), both FINRA-registered broker- dealers and members SIPC. Schwab or Fidelity will serve as the Client’s “qualified custodians”. Quorus maintains an institutional relationship with Schwab and Fidelity, whereby the Advisor receives economic benefits from Schwab or Fidelity. Please see Item 14 below. In sub-advisory arrangements, Quorus will utilize the custodian designated by the Advisor Client. 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-dealers/custodians in exchange for research and other services. Quorus does not participate in soft dollar programs sponsored or offered by any broker- dealers/custodians. However, the Advisor receives certain economic benefits from the Custodians. Please see Item 14 below. 2. Brokerage Referrals - Quorus does not receive any compensation from any third party in connection with the recommendation for establishing an account. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 17  3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Quorus 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]). Quorus 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. Quorus permits Clients to direct brokerage and that, by doing so, the Firm may be unable to achieve the most favorable execution of its clients transactions, as a result, and that directing brokerage may cost clients more money. B. Aggregating and Allocating Trades When possible, we may choose to aggregate or block trades for Client accounts with those of other Client accounts. When we place a block trade, all participants included in the block receive the same price per share on the trade. The price is calculated by averaging the price of all of the shares traded. Due to the averaging of price over all of the participating accounts, aggregated trades could be either advantageous or disadvantageous. Commission costs are not averaged. The Client will pay the same commission whether your trade is placed as part of a block or on an individual basis. The objective of the aggregated orders will be to allocate the executions in a manner that is deemed equitable to the accounts involved. Item 13 – Review of Accounts A. Frequency of Reviews Quorus accounts undergo a daily, automated review process with all results presented to the Quorus portfolio management team for final review. Accounts are evaluated according to a number of portfolio characteristics to ensure adherence to account policy settings. All accounts at Quorus are assigned to this reviewer. 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 Quorus 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. 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]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Quorus Quorus is a fee-based advisory firm, which is compensated solely by its Clients and not from any investment product. Quorus does not receive commissions or other compensation from product sponsors, broker-dealers or any un- related third party. Quorus 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, Quorus may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform Quorus has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Quorus. As a registered investment advisor Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 18  participating on the Schwab Advisor Services platform, Quorus 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 potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one 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 provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives 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 all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and support to Quorus that may not benefit the Client, including educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Quorus believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Client Referrals from Solicitors Quorus does not engage paid solicitors for Client referrals. Item 15 – Custody All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Quorus to utilize that Custodian for the Client’s security transactions. Quorus does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. The ability to deduct its fees results in the Advisor having a limited form of custody, which is mitigated as follows. • All Clients must maintain accounts at a “qualified custodian”; • The Advisor shall obtain written authorization to deduct its fee via the Client agreement and Custodian documents; • The Advisor shall send an invoice to the Custodian instructing the Custodian to deduct the fee; and • The Advisor shall send a statement to the Client each time it deducts a fee, which includes: the time period covered by the fee; the assets under management utilized to calculate the fee; and the applicable fee rate. Clients will receive account statements, at least quarterly, from the Custodian; Clients should review statements provided by the Custodian and compare to any reports or invoices provided by Quorus to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 19  Quorus generally 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 Quorus. 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 Quorus will be in accordance with each Client's investment objectives and goals. The Firm will properly secure the Client’s permission prior to effecting securities transactions in client accounts managed on a non-discretionary basis. Item 17 – Voting Client Securities Quorus generally 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. For sub-advised Clients, proxy-voting may be delegated to Quorus via the sub-advisory agreement. Item 18 – Financial Information Neither Quorus, nor its management, have any adverse financial situations that would reasonably impair the ability of Quorus to meet all obligations to its Clients. Neither Quorus, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Quorus is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $500 or more for services to be performed six months or more in the future. Quorus Inc. 500 Post Road 2nd Floor, Suite 303, Westport CT 06880 Phone: (929) 560-2588 | Website: https://quorus.io Page 20