Seedsafe Financial LLC

Item 1: Cover Page SeedSafe Financial, LLC www.seedsafefinancial.com Business Address Personal residence Austin, TX Form ADV Part 2A – Firm Brochure (360) 602-1274 Dated June 9, 2026 This Brochure provides information about the qualifications and business practices of SeedSafe Financial, LLC, “SSF”. If you have any questions about the contents of this Brochure, please contact us at (360) 602-1274. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. SeedSafe Financial, LLC is registered as an Investment Adviser with the Securities Exchange Commission. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about SSF is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the firm’s identification number 283887.  Item 2: Material Changes In this Item, SSF is required to identify and discuss material changes since the last time this brochure was updated. Since filing its last annual updating amendment on February 11, 2025, SSF has implemented the following changes: ● SSF is now registered with the Securities Exchange Commission. ● SSF has added Misty Cherniss as an IAR. ● SSF has updated services in Items 4 to disclose Canopy by SeedSafe. ● SSF has updated its fees in Item 5 to disclose fees for Canopy by SeedSafe, and update fees for Financial Planning Services. ● SSF has updated fees in Item 5 for hourly consulting Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Seedsafe Financial. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our CRD number 283887. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (360) 602-1274.  Item 3: Table of Contents Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 1 2 3 4 10 14 14 14 18 18 19 20 25 26 26 28 28 28  Item 4: Advisory Business Description of Advisory Firm SeedSafe Financial, LLC is registered as an Investment Adviser with the Securities Exchange Commission. We were founded in April 2016 and became a Registered Investment Advisor in 2016. Rebecca Jackson is the principal owner of SSF. SSF currently has $125,174,066 in discretionary and $0 non-discretionary assets under management as of December 31,2025. Types of Advisory Services Investment Management Services (SSF manages accounts) We are in the business of managing individually tailored investment portfolios. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation target. We may also review and discuss a client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5 of this brochure. Investment Management Services (Canopy by SeedSafe) SSF offers a limited-scope investment management service known as Canopy by SeedSafe (“Canopy”). Canopy is designed for clients with relatively straightforward financial circumstances who seek professional discretionary investment management without ongoing comprehensive financial planning. Under the Canopy program, SeedSafe provides discretionary portfolio management services, including asset allocation, implementation, ongoing monitoring, and periodic rebalancing. Clients may also receive limited financial guidance on an as-needed basis; however, Canopy does not include ongoing comprehensive financial planning services. Canopy is a service line of SeedSafe Financial and operates under the same custodial relationships, compliance oversight, investment philosophy, and portfolio management framework as SeedSafe’s full-service advisory offering. Clients may engage SeedSafe for financial planning services under a separate agreement or may be referred to SeedSafe’s full-service advisory platform if appropriate.  Investment Management Services (Outside Firm manages accounts) We offer investment management services by referring clients, where appropriate, to third party money managers (“Outside Managers”) for portfolio management services. We assist clients in selecting an appropriate allocation model, completing the Outside Manager’s investor profile questionnaire, interacting with the Outside Manager and reviewing the Outside Manager. Our review process and analysis of outside managers is further discussed in Item 8 of this Form ADV Part 2A. Client may impose reasonable restrictions on their account. Additionally, we will meet with the client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. Fees pertaining to this service are outlined in Item 5 of this brochure. For Investment Management Services, whether we directly manage the account or utilize an outside manager will depend upon client preferences and size of account. Initial Comprehensive Financial Planning Projects This service involves working one-on-one with a planner to cover a certain scope of financial planning needs in one hourly project. Planning is estimated by the number of hours worked under the contract scope and term and is paid by a 50% deposit up front and 50% payment upon completion. The initial financial planning project entails retirement analysis, stock compensation analysis, tax planning, and may involve education planning, insurance reviews, and basic estate planning discussions. Following the initial financial planning project, clients may choose to continue working with the financial planner to enact the action items listed and to maintain close communication while implementing plan recommendations. This may include continued stock compensation analysis, tax projections and further analysis, home purchase education, etc. Comprehensive Financial Planning Subscription This service involves working one-on-one with a planner over an extended period of time. Planning is estimated by the number of hours worked under the contract term and paid on a monthly or quarterly basis. By paying a monthly or quarterly fee, clients get continuous access to a planner who will work with them to continue modifying their plan and assist with implementation. The planner will monitor the plan, recommend any changes and ensure the plan is up to date. SeedSafe Financial primarily works with entrepreneurs, executives and employees in the technology industry. The main purpose of financial planning is to provide a spending plan/cash flow plan to assist the individual in meeting their goals, develop a debt reduction strategy, manage and analyze stock compensation and current stock holdings, review personal risks and set a plan for management, tax planning, and to develop a simplified investment plan. Upon desiring a comprehensive planning initial project and subscription, a client will be taken through establishing their goals and values around money. They will be required to provide information to help complete the following areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee benefits, retirement planning, insurance, investments, college planning and estate planning, as agreed to in the proposal. Once the client’s information is reviewed, their plan will be built and  analyzed, and then the findings, analysis and potential changes to their current situation will be reviewed with the client. Clients subscribing to this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. If a follow up meeting is required, we will meet at the client's convenience. The plan and the client’s financial situation and goals will be monitored throughout the year and follow-up phone calls and emails will be made to the client to confirm that any agreed upon action steps have been carried out. On an annual basis there will be a full review of this plan to ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time. In general, the financial plan will address any or all of the following areas of concern. The client and advisor will work together to select the specific areas to cover. These areas may include, but are not limited to, the following: ● Business Planning: We provide consulting services for clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. ● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. ● College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate). ● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. ● Stock Compensation Planning: We review current stock grants and vesting parameters to better understand your cash flow over the next few years. Then we take a look at the tax implications and risks of different strategies available to you based on your expected time with the company and/or personal changes that may affect those strategies. ● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your  current estate plan, which may include whether you have a will, powers of attorney, trusts and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. ● Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. ● Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. ● Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ● Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. ● Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long‐term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self‐insuring”). ● Tax Planning Strategies: Advice may include ways to minimize current and future income  taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area, if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Comprehensive Financial planning includes the following planning services for Clients engaged in Seed Safe Full Service. For Clients engaged in Canopy, these services are limited: Category SeedSafe Full Service Canopy by SeedSafe Financial Independence Path ✓ ✓ Annual Life and Strategy Review ✓ ✓ Annual Cash Flow Review ✓ Detailed 5 Year Projection ✓ Current Year Projections ✓ ✗ Multiple Mid-Year Check-In’s and Q&A Action Steps for Optimizing Finances ✓ All Areas ✓ Cashflow and Investments Equity Compensation ✓ All Types of Equity Comp ✓ RSUs only Insurance and Benefits Review ✓ ✗ Estate Planning Review ✓ ✗ Year-End Tax Meeting ✓ ✗ Project-Based Financial Planning We provide project-based financial planning services on a limited scope one-time engagement. Project-Based Financial Planning is available for Clients looking to address specific questions or issues. The Client may choose from one or more of the above topics to cover or other areas as requested and agreed to by SSF. For Project-Based Financial Planning, the Client will be ultimately responsible for the implementation of the financial plan.  Personal Tax Return Preparation We provide optional tax preparation services for our clients to assist with the filing of federal and state tax returns for individuals and businesses for an additional fee. We may ask for an explanation or clarification of some items, but we will not audit or otherwise verify client data. The client is responsible for the completeness and accuracy of information used to prepare the returns. Our responsibility is to prepare the returns in accordance with applicable tax laws. We will utilize the services of a third-party tax preparation software to facilitate the preparation and filing of your tax return and we will work with you and the third-party software in order to gather the necessary information as part of this service. We may observe opportunities for tax savings that require planning or changes in the way the client handles some transactions. While an engagement for tax return preparation does not include significant tax planning services, we will share any ideas we have with you and discuss terms for any additional work that may be required to implement those ideas. Educational Seminars and Webinars We may provide seminars on an “as announced” basis for groups seeking general advice on investments, offer negotiations, and other areas of personal finance. The content of these seminars will vary depending upon the needs of the attendees. These seminars are purely educational in nature and do not involve the sale of any investment products. Information presented will not be based on any individual’s person’s need, nor does SSF provide individualized investment advice to attendees during these seminars. From time to time, Webinars are conducted on a variety of financial planning topics. With this service, there is also an optional follow-up study group event to be conducted within 30 days of the date the webinar is completed, to address any follow-up questions, concerns and ideas of the attendee. Client Tailored Services and Client Imposed Restriction We offer the same suite of services to all of our clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement or Suitability Questionnaire which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Wrap Fee Programs We do not participate in wrap fee programs. For clients who receive our Financial Planning services, we must state when a conflict exists between the interests of our firm and the interests of our client. The client is under no obligation to act upon our recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through our firm.  Item 5: Fees and Compensation Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the client within five (5) business days of signing the contract without penalty. How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below. All fees listed below are negotiable based upon certain criteria, such as the complexity of the client’s portfolio, the level of expertise required to provide services, the staff time involved in servicing the client, legacy pricing, client householding, dollar amount of assets to be managed, employee friends and family relationships, and pro bono activities among other factors we deem appropriate. Investment Management Services The fee is based on a percentage of assets under management. The annualized fees for investment management services are based on the following fee schedule: Category SeedSafe Full Service Canopy by SeedSafe Investment Portfolio Assessment ✓ ✓ Asset Allocation and Analysis ✓ ✓ Asset Location Strategy ✓ ✓ Tax-Efficient Investment Strategy ✓ ✓ Backdoor Roth Planning ✓ ✓ Concentrated Stock Strategy ✓ ✓ Tax Loss Harvesting ✓ ✓ Lump Sum Investing Strategy ✓ ✓ Ongoing Investment Plan Review ✓ ✓ Implementation ✓ ✓ Fees 0.50% up to $2M 0.25% over $2M *No minimum 0. 75% up to $2M 0.25% over $2M *$600K minimum or $4,500 minimum annual fee The annual advisory fee is paid quarterly in arrears based on the value of Client’s account(s) as of the last  day of the billing period. The advisory fee is a blended fee. For example, for assets under management of $3,000,000 under Canopy, a Client would pay 0.75% on the first $2,000,000 and 0.25% on the remaining balance. The formula for the quarterly fee is determined by the following calculation: (($2,000,000 x 0.75%) + ($1,000,000 x 0.25%)) ÷ 4 = $4375. No increase in the annual fee shall be effective without agreement from the client by signing a new agreement or amendment to their current advisory agreement. The above listed fee schedule does not include the Outside Manager’s fee. Dimensional Fund’s SMA platform fee is 0.29% for the direct security sleeve (the SMA strategy). The Outside Manager will deduct the fees from the client’s account. Total client fees will not exceed 3% of assets under management when a third-party investment adviser is used. Advisory fees are directly debited from client accounts, or the client may choose to pay by check. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 30 calendar days in advance. Since fees are paid in arrears, no rebate will be needed upon termination of the account. Legacy clients may have a different fee schedule and termination period that was applicable at the time such legacy clients signed an advisory agreement with us. Comprehensive Financial Planning Comprehensive Financial Planning consists of an initial financial planning project (between $4,500 to $23,500) and an ongoing fee that is paid monthly or quarterly in advance, at the rate of $375.00 to $2,000 per month. The fee is determined based on the estimated working hours to accomplish the tasks to meet the objectives and needs of the client. Upon termination of any financial planning engagement, any unearned fees will be pro-rated and returned to the client. The prorated fee will be calculated based on the total prepaid fees less the percentage of financial planning deliverables completed. Fees are collected via electronic funds transfer, credit card, or debit card. Cash or check will not be accepted. SSF does not require or solicit prepayment of more than $1,200 in fees per client six months in advance. The Comprehensive Financial Planning Fees are based on estimated hours of work for the initial year of planning to be done and then on an ongoing quarterly basis following the first year. The initial engagement is for a term of one year, however, this service may be terminated with 30 days’ notice. We will continue the engagement for clients who wish to continue working with SSF after the first year. To the extent a client’s financial life increases in complexity such that it expands the nature and extent of the Comprehensive Financial Planning services rendered by SSF, an additional fee shall apply. The specific complexity-based additional fees are listed below: ● Purchasing a rental property: $900 for the year of purchase ● Business ownership/starting a business: $1,500 per year of ownership ● Public Offering - S-1 filing: $3,000 per year for the first two years ● Merger / Acquisition: $2,000 for the first year of purchase SSF will provide at least 30 days’ advance written notice before any additional complexity-based fees shall apply. With the exception of complexity-based fees, no increase in the annual fee shall be effective without agreement from the client by signing a new agreement or amendment to their current client agreement. The annual fee will be re-evaluated every one to two years. The annual fees are negotiable.  Project-Based Financial Planning We charge an hourly fee for Project-Based Financial Planning. Our hourly rate is $450. Fees are negotiable and the final agreed upon fee will be outlined in your Advisory Contract. SSF collects a portion of the fee to be collected in advance with the remainder due upon completion of the services. In the event of early termination by client, any fees for the hours already worked will be due. Fees for this service may be paid by electronic funds transfer. We use an independent third-party payment processor in which the client can securely input their banking information and pay their fee. Personal Tax Return Preparation The total fees for Personal Tax Return Preparation will be determined based on the complexity of the return and quality of recordkeeping. Basic tax returns are $625 and depending upon complexity, may cost up to $2,800. Additional hourly services for amended tax returns and other items may be provided, based on our hourly rate of $450. The fees may be negotiable in certain cases,will be agreed upon at the start of the engagement, and are due at the completion of the engagement. Clients are not required to utilize any third-party products or services that we may recommend and they can receive similar services from other professionals at a similar or lower cost. Hourly Financial Planning At the firm’s discretion, limited hourly financial planning engagements are offered at the rate of $450 per hour. The fee may be negotiable in certain cases and is due at the completion of the engagement. In the event of early termination by the Client, any fees for the hours already worked will be due. Fees for this service may be paid by electronic funds transfer, debit card, or credit card. For fees paid by electronic funds transfer, debit card, or credit card, we use an independent third-party payment processor in which the client can securely input their banking information and pay their fee. Educational Seminars and Webinars Rebecca Jackson currently offers seminars and does speaking engagements, per the below: Educational Seminar Seminars are offered to organizations and the public on a variety of financial topics. Fees range from free to $3,000 per seminar or free to $300 per participant. Half of the fees are due prior to the engagement, and the other half are to be paid the day of, no later than the conclusion of the Seminar. The fee range is based on the content, amount of research conducted, number of hours of preparation needed, and the number of attendees. In the event of inclement weather or a flight cancellation, the Speaker shall make all reasonable attempts to make alternative travel arrangements to arrive in time for the presentation. If travel proves impossible, or the event is otherwise canceled, the Speaker’s fee is waived, but the Client will still be responsible for reimbursement of any non-refundable travel expenses already incurred.  In the event that the Client decides to cancel or change the date of the event for any reason besides weather or similar unforeseen causes, the Client will still be responsible for reimbursement of any non-refundable travel expenses already incurred and will provide payment for 50% of the Speaker’s fee if the cancellation occurs within 30 days of the event. In the event that the Speaker must cancel due to health or similar unforeseen circumstances, the Speaker will make all attempts to find a reasonable alternative engagement date and will absorb any incremental additional costs for obtaining alternative travel arrangements. If an alternative date cannot be obtained, the Client will not be responsible for any travel costs already incurred by the Speaker or any portion of the Speaker’s fee. In the event of a virtual seminar, travel fees and expenses will not be charged to the Client and the refund of travel expenses does not apply. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client’s transactions and determining the reasonableness of their compensation (e.g., commissions). We do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds.  Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees. Item 7: Types of Clients We provide financial planning and portfolio management services to individuals, and high net-worth individuals. Our minimum account size requirement is $600,000 to open or maintain an account under our management under our Canopy Service. SSF may reduce or waive the minimum account size requirement on a case-by-case basis. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss When clients have us complete an Investment Analysis (described in Item 4 of this brochure) as part of their financial plan, our primary methods of investment analysis are fundamental, technical, cyclical and charting analysis. Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market.  Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Charting analysis involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. Charts may not accurately predict future price movements. Current prices of securities may not reflect all information about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Passive Investment Management We primarily practice passive investment management. Passive investing involves building portfolios that are comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are typically index mutual funds or exchange traded funds. Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal). In contrast, active management involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Academic research indicates most active managers underperform the market. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition.  Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions we may be unable to sell or liquidate investments at prices we consider reasonable or favorable, or find buyers at any price. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity.  Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are delisted from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which client’s invest. Digital Securities Risk. Investing in digital assets like bitcoin or ethereum, e.g., whether directly through an exchange or indirectly through another product, involves the general risks of investing in other investment vehicles. In addition, the value of digital assets are subject to significant fluctuations,  can be highly volatile, and can change dramatically even intra-day. The price of digital assets could drop precipitously for a variety of reasons, including, but not limited to, a crisis of confidence in the network or a change in user preference to competing assets. Digital assets represent an emerging asset class. As a result, the market infrastructure through which it is exchanged and the regulatory foundation upon which it is regulated are still in their respective infancy when compared to more traditional assets like stocks, bonds, mutual funds, ETFs, or similar. Digital assets are not protected by the Federal Deposit Insurance Corporation or the Securities Investor Protection Corporation. Any exposure to digital assets can result in substantial losses and bitcoin investors should be able to withstand significant if not complete loss of invested capital. Digital assets facilitate decentralized, peer-to-peer financial exchange and value storage that is used like money, without the oversight of a central authority or banks. The value of digital assets are wholly derived from their monetary premium and is not backed by any government, corporation, other identified body, or other physical assets. The exchange and availability of digital assets are dependent on the availability and proper functioning of the internet, the electronic platforms storing such digital assets, and the owner’s control and possession of any needed password or digital key. Any downtime, unavailability, cybersecurity breach, or loss of access is a risk that a digital asset investor should be prepared to bear. The loss, destruction, or compromise of a private key may result in a loss of the digital assets, typographical errors may lead to loss of the digital assets, and digital asset trade errors cannot be unwound. Accordingly, the indirect exposure to digital assets through securities of publicly listed companies is also susceptible to these risks. Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SSF or the integrity of our management. We have no information applicable to this Item. Item 10: Other Financial Industry Activities and Affiliations No SSF employee is registered, or has an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. No SSF employee is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor.  SSF only receives compensation directly from clients. We do not receive compensation from any outside source. We do not have any conflicts of interest with any outside party. No Employee of SSF is licensed to sell life and health insurance and does not engage in product sales with our clients, for which they will receive additional compensation. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below. • Integrity - Associated persons shall offer and provide professional services with integrity. • Objectivity - Associated persons shall be objective in providing professional services to clients. • Competence - Associated persons shall provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. • Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. • Confidentiality - Associated persons shall not disclose confidential client information without the specific consent of the client unless in response to proper legal process, or as required by law. • Professionalism - Associated persons’ conduct in all matters shall reflect credit of the profession. • Diligence - Associated persons shall act diligently in providing professional services.  We will, upon request, promptly provide a complete code of ethics. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a transaction for a client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm and its “related persons” (associates, their immediate family members, etc.) may buy or sell securities the same as, similar to, or different from, those we recommend to clients for their accounts. A recommendation made to one client may be different in nature or in timing from a recommendation made to a different client. Clients often have different objectives and risk tolerances. At no time, however, will our firm or any related party receive preferential treatment over our clients. Trading Securities At/Around the Same Time as Client’s Securities In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific securities transactions. Any exceptions or trading pre‐clearance must be approved by our Chief Compliance Officer in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation. Additionally, SSF requires adherence to its Insider Trading Policy, and the CFA Institute's Asset Manager Code of Professional Conduct and Code of Ethics and Standards of Professional Conduct. Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers SeedSafe Financial, LLC does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to clients based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. 1. Research and Other Soft-Dollar Benefits SSF does receive soft-dollar benefits through its relationship with Charles Schwab & Co., member FINRA/SIPC. SSF does receive soft-dollar benefits through its relationship with Betterment LLC. These benefits are specifically outlined below, in the section labeled “Services Available to us via Betterment LLC.” 2. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use  We do recommend a specific custodian for clients to use, however, clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing clients to choose a specific custodian, we may be unable to achieve the most favorable execution of client transactions, and this may cost clients money over using a lower-cost custodian The Custodians and Brokers We Use Charles Schwab Seedsafe Financial (“we”/“our”) does not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We [recommend/request/require] that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker- dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). Your brokerage and trading costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds, and U.S. exchange-listed equities and ETFs) may not incur Schwab commissions or transaction fees. Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available at no charge to us. Following is a more detailed description of Schwab’s support services:  Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, record keeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets  in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such decisions based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/custodians”) and not Schwab’s services that benefit only us. Betterment SeedSafe Financial LLC does not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw advisory fees from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use MTG, LLC dba Betterment Securities (“Betterment Securities”), a registered broker-dealer and member of the SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Betterment Securities. Betterment Securities will hold your assets in a brokerage account and buy and sell securities when we and/or you instruct them to. While we recommend that you use Betterment Securities as custodian/broker, you will decide whether to do so and will open your account with Betterment Securities by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Betterment Securities, then we cannot manage your account on Betterment for Advisors (defined below). HOW WE SELECT BROKERS/CUSTODIANS We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including: ● Capability to execute, clear, and settle trades (buy and sell securities for your account) itself or to facilitate such services. ● Capability to facilitate timely transfers and payments to and from accounts. ● Availability of investment research and tools that assist us in making investment decisions. ● Quality of services. ● Competitiveness of the price of those services and willingness to negotiate the prices. ● Reputation, financial strength, and stability. ● Prior service to us and our other clients. YOUR BROKERAGE AND CUSTODY COSTS For our clients’ accounts that Betterment Securities maintains, Betterment Securities does not charge you separately for custody/brokerage services but is compensated as part of the Betterment for Advisors (defined below) platform fee, which is charged for a suite of platform services, including custody, brokerage, and sub-advisory services provided by Betterment and access to the Betterment for Advisors  platform. The platform fee is an asset-based fee charged as a percentage of assets in your Betterment account. Clients utilizing the Betterment for Advisors platform may pay a higher aggregate fee than if the investment management, brokerage and other platform services are purchased separately. Nonetheless, for those Clients participating in the Betterment for Advisors platform, we have determined that having Betterment Securities execute trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). SERVICES AVAILABLE TO US VIA BETTERMENT FOR ADVISORS Betterment Securities serves as broker-dealer to Betterment for Advisors, an investment and advice platform serving independent investment advisory firms like us (“Betterment for Advisors”). Betterment for Advisors also makes available various support services which may not be available to Betterment’s retail customers. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Betterment for Advisors’ support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Betterment for Advisors’ support services: 1. SERVICES THAT BENEFIT YOU. Betterment for Advisors includes access to a globally diversified, low-cost portfolio of ETFs, execution of securities transactions, and custody of client assets through Betterment Securities. In addition, a series of model portfolios created by third-party providers are also available on the platform. Betterment Securities’ services described in this paragraph generally benefit you and your account. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Betterment for Advisors also 2. makes available to us other products and services that benefit us, but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts, such as software and technology that may: Assist with back-office functions, recordkeeping, and client reporting of our clients’ accounts. Provide access to client account data (such as duplicate trade confirmations and account – – statements). – Provide pricing and other market data. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Betterment for Advisors, 3. we may be offered other services intended to help us manage and further develop our business enterprise. These services include: – – Consulting (including through webinars) on technology and business needs. Access to publications and conferences on practice management and business succession.  OUR INTEREST IN BETTERMENT SECURITIES’ SERVICE The availability of these services from Betterment for Advisors benefits us because we do not have to produce or purchase them. In addition, we do not have to pay for Betterment Securities’ services. BETTERMENT FOR ADVISORS’ TRADING POLICY When using the Betterment for Advisors platform, we and you are subject to the trading policies and procedures established by Betterment. These policies and procedures limit our ability to control, among other things, the timing of the execution of certain trades (including in response to withdrawals, deposits, or asset allocation changes) within your account. You should not expect that trading on Betterment is instant, and, accordingly, you should be aware that Betterment does not permit you or us to control the specific time during a day that securities are bought or sold in your account (i.e., to “time the market”). Betterment describes its trading policies in Betterment LLC’s Form ADV Part 2A. As detailed in that document, Betterment generally trades on the same business day as it receives instructions from you or us. However, transactions will be subject to processing delays in certain circumstances. In particular, orders initiated on non-business days and after markets close generally will not transact until the next business day. Betterment also maintains a general approach of not placing securities orders during approximately the first thirty minutes after the opening of any market session. Betterment also generally stops placing orders arising from allocation changes in existing portfolios approximately thirty minutes before the close of any market session. Betterment continues placing orders associated with deposit and withdrawal requests until the market closes. Betterment maintains a general approach of not placing orders around the time of scheduled Federal Reserve interest rate announcements. Furthermore, Betterment may delay or manage trading in response to market instability. For further information, please consult Betterment LLC’s Form ADV Part 2A. Aggregating (Block) Trading for Multiple Client Accounts Generally, we do not combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). The cost of not block trading may mean different prices for each trade submitted. Item 13: Review of Accounts Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by Rebecca Jackson. During the regular review, the account's performance is compared against like-managed accounts to identify any unacceptable performance deviation. Additionally, reasonable client-imposed restrictions will be reviewed to confirm that they are being enforced. Events that may trigger a special review would be unusual performance, addition or deletions of client-imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per client's needs.  Comprehensive Financial Planning clients maintain access to a client portal that relays progress toward financial planning goals. Clients are offered meetings, at least semi-annually, to review progress in the client portal and discuss changes in their financial situation. Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. SSF will provide written reports to Investment Management clients on a quarterly basis. We urge clients to compare these reports against the account statements they receive from their custodian. Item 14: Client Referrals and Other Compensation We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to our clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for client referrals. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). We receive a non-economic benefit from Betterment for Advisors and Betterment Securities in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Betterment Securities. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). The availability to us of Betterment for Advisors’ and Betterment Securities’ products and services is not based on us giving particular investment advice, such as buying particular securities for our clients.  Item 15: Custody SSF does not have custody, except for in the instance of withdrawing client fees. When client fees are deducted via a qualified custodian, SSF is deemed to have “limited” custody. Prior to having fees deducted via a qualified custodian, SSF will: Possess written authorization from the client to deduct advisory fees from an account held (a) by a qualified custodian Send the qualified custodian written notice of the amount of the fee to be deducted from (b) the client’s account. (c) Send the client an itemized invoice including any formulae used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based. Each time a client fee is deducted, SSF sends a copy of the invoice to the custodian or trustee and concurrently sends a copy to the client. This invoice includes the fee(s), the formula used to calculate the fee(s), and the time period covered by the fee(s). The custodian sends quarterly statements to the client showing all disbursements for the custodian account, including the amount of the advisory fees. Clients provide written authorization permitting SSF to be paid directly for their accounts held by the custodian or trustee. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains the client's investment assets. Under government regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct Betterment Securities to deduct our advisory fees directly from your account. Betterment Securities maintains actual custody of your assets. Your statements will be available for you to review on the activity section of your Betterment for Advisors account portal. You will also receive account statements directly from Betterment Securities at least quarterly at www.bettermentsecurities.com. You should carefully review those statements promptly. For any accounts with an SLOA in place, we will follow the custody rules for the relevant jurisdiction, including submitting to a surprise audit as applicable. We will also follow the conditions set forth below. 1. The client will be required to provide written instruction to the qualified custodian that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s accoun t number at a custodian to which the transfer should be directed. 2. The client will authorize Adviser in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian will perform appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and will provide a transfer  of funds notice to the client promptly after each transfer. 4. The client will have the ability to terminate or change the instruction to the client’s qualified custodian. 5. Adviser will have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. Adviser will maintain records showing that the third party is not a related party of Adviser or located at the same address as Adviser. 7. The client’s qualified custodian will send the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion For those client accounts where we provide investment management services, we may maintain discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney which will grant our firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client. In the past, clients could choose investment management services on a non-discretionary basis but we no longer provide this moving forward. For these legacy clients, SSF will receive client acknowledgement and permission prior to the purchase or sale of any security in the client’s account. Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies.  Item 18: Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding. We do not have custody of client funds or securities or require or solicit prepayment of more than $1,200 in fees per client six months in advance.