SHARIAPORTFOLIO, INC.

Item 1. Cover Page Item 1: Cover Page Firm Brochure (Part 2A of Form ADV) ShariaPortfolio, Inc. 1331 S. International Parkway, Suite 2291 Lake Mary, Florida 32746 Phone: (321) 275-5125 Fax: (321) 275-5126 www.shariaportfolio.com March 31, 2026 This Firm Brochure (“brochure”) provides information about the qualifications and business practices of ShariaPortfolio, Inc. (“ShariaPortfolio”), a registered investment adviser. If you have any questions about the contents of this brochure, please contact us at (321) 275-5125 or by email at info@shariaportfolio.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC does not imply a certain level of skill or training. Additional information about ShariaPortfolio is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2. Material Changes This Brochure contains updated information about ShariaPortfolio, Inc.’s (referred to herein as “ShariaPortfolio”, “Company”, and/or the “Firm,”) business since the last annual update on March 14, 2025. This section of the Brochure will address only those “material changes” that have been incorporated since the last annual delivery of this document on the SEC’s public disclosure website (IAPD). The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. The following material changes have been made: Iten #4 – Advisory Business  Under Private Equity Fund, any reference to the SP Funds RE, LLC was removed to clarify the Firm’s role with respect to such fund. Certain private funds including SP Funds RE, LLC are operated by affiliated entities and/or their principals. The structure and allocation of responsibilities among these entities vary and the Firm’s affiliates participate in the investment and operational activities of such funds. It was clarified the difference between Sub-Advisor and Advisory to the related ETFs.   Renamed the section - Retirement Planning to Benefit Plan Services/Corporate Retirement Planning and updated the section to better align with the services provided by the Firm. Item #5 – Fees and Compensation  This Item was updated to better align with the various fees the Firm receives Item #6 – Performance Fees and Side-by-Side Management  This Item was updated to better describe the fees it receives from the Fund and the Aggressive Growth Accounts. Item #8 – Methods of Analysis, Investment Strategies and Risk of Loss  This Item was fully replaced to better align with the Firm’s advisory services provided. Item 12 – Brokerage Practices  This Item was updated to better describe the brokerage practices of the Firm. Item 15 – Custody  This Item was updated to reflect the Firm has constructive custody of the assets of the Fund. Item 17 – Voting Client Securities  This Item was updated to clarify the Firm’s proxy voting practices with respect to the private fund managed by the Firm, EthicalEdge Digital Fund LLC. General Updates This Brochure is prepared according to the SEC’s requirements and rules. Other amendments may have been made to this Brochure, which may not have been discussed in this summary, and consequently, we encourage you to read this Brochure in its entirety. Currently, our Brochure may be requested by contacting ShariaPortfolio at (321) 275-5125. Clients and prospective clients are strongly encouraged to review this Brochure very carefully. Pursuant to SEC Rules, ShariaPortfolio will ensure that clients receive a summary of any materials changes to this 1  Brochure within 120 days of the close of our fiscal year, along with a copy of this Brochure or an offer to provide the Brochure. Additionally, as ShariaPortfolio experiences material changes in the future, we will send you a summary of our “Material Changes” under separate cover. For more information about the firm, please visit www.shariaportfolio.com. Additional information about the firm and our investment adviser representatives is available on the SEC’s website at www.adviserinfo.sec.gov. 2  Item 3. Table of Contents Item 3: Table of Contents ............................................................................................................................ 3 Item 4: Advisory Business ........................................................................................................................... 4 Item 5: Fees and Compensation ............................................................................................................... 10 Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 16 Item 7: Types of Clients ............................................................................................................................ 19 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 20 Item 9: Disciplinary Information ............................................................................................................. 31 Item 10: Other Financial Industry Activities and Affiliations ............................................................... 32 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading . .................................................................................................................................................. 32 Item 12: Brokerage Practices.................................................................................................................... 33 Item 13: Review of Accounts .................................................................................................................... 35 Item 14: Client Referrals and Other Compensation ............................................................................... 36 Item 15: Custody ....................................................................................................................................... 37 Item 16: Investment Discretion ................................................................................................................ 38 Item 17: Voting Client Securities ............................................................................................................. 38 Item 18: Financial Information ................................................................................................................ 38 1  Item 4. Advisory Business ShariaPortfolio, Inc., (hereinafter referred to as “ShariaPortfolio”, “Company”, “the Firm”, “we”, “us” and “our”) is a fee-only registered investment advisor incorporated October 30, 2014 as a Florida corporation. ShariaPortfolio is a boutique asset management firm focusing on Islamically-compliant investing to assist you, our client, achieve your financial goals. Naushad Virji, Portfolio Manager (CRD 5027106) and Wasia Sheikh, Shareholder (CRD 6422969) are the principal owners of the Company with the remaining interests owned by minority investors in the Firm. Aliredha Walji (CRD 6531250) is the Chief Executive Officer and manages the day-to-day operations of the Company. Types of Advisory Services ShariaPortfolio offers professionally managed portfolio solutions to clients to help achieve their financial goals while conforming to Islamic principles (the “Services”). The Firm provides Services on a fee basis, which includes fees based upon the net asset value of the assets under management by the Firm, as well as fees based on performance of the Fund and certain client accounts in which it provides such Services. Applicable fees are set forth in detail in each clients Investment Advisory Agreement (“IAA”), or the Fund/Electronic Trading Funds (“ETF”) offering/prospective documents. A brief summary of the Firm’s fees is provided below. Investors should refer to the relevant offering/prospective documents for a complete understanding of how the Firm is compensated for its Services. We manage wealth tailored to the individual needs of our clients. Our advisory services begin with stressing the importance of you making fiscally responsible decisions and disciplined economic choices in your personal life so we can effectively help you achieve your monetary goals for today’s needs, tomorrow’s dreams, and a strategy to build a lasting legacy for future generations. As mentioned above, the Firm intends to operate in a manner consistent with the Islamic principles as it pertains to financial investing. In particular the Firm will comply with the following:  No Interest-Based Investments: They will not engage in transactions that generate or rely on interest (riba). Any financing must be structured in an Islamically-compliant form (e.g. murabaha, musharaka, ijara) approved by the Sharia advisor  No Prohibited Sectors: Will not invest in businesses that derive material revenues from activities considered impermissible under Islamic principles, including but not limited to alcohol, pork products, gambling, adult entertainment, conventional financial services, or weapons.  Screening and Oversight: Engage qualified Islamic scholars and advisors to review investment opportunities, provide ongoing oversight, and confirm compliance with Islamic principles. The Firm will engage scholars or advisory firms in Islamic Finance, who will conduct reviews of all investments. The Firm will use its best efforts to ensure that all investments and operations of the Firm adhere to these guidelines. However, investors should note that interpretations of Sharia law may vary, and no assurance can be given that all investors will agree with the Firm’s application of these principles. The Firm’s Services are tailored to meet a client’s individual investment objectives and guidelines, as well as any client investment restrictions or limitations, which will be documented in the client’s profile. ShariaPortfolio investment adviser representatives (“IA-Reps”) use questionnaires, review of current holdings, goals, and objectives to better understand each client’s investment profile, including the client’s risk tolerance, time horizon and investment needs. No less than annually, the Firm will review client information to ensure that each client’s investment profile is up-to-date and accurate. The Firm provides ongoing Services to individuals, high net-worth individuals, families, pension and 1  profit-sharing plans, and businesses. ShariaPortfolio tailors its Service to each individual client needs. In addition to our Services, we offer, retirement plan consulting, strategic planning, investment policy development services and coordinate with other advisers, and financial professionals as necessary to meet each client’s needs. The Firm also acts in the capacity as an advisor and sub-advisor to Private Funds and Electronic Trading Funds (“ETFs”) that are affiliated with the Firm. Clients who impose investment restrictions or limitations might affect their account’s performance and limit the Firm’s ability to employ various investment strategies. This may result in investment performance that differs from that of a benchmark or other client account(s) utilizing the same or similar investment strategy. Prior to providing its Services, ShariaPortfolio will perform an evaluation of the client’s current holdings and its risk tolerance, time horizon, investment objectives and goals. a) Portfolio Management Services - Access Program The focus of our management begins with identifying your standards of living and quality of life expectations for us to gain deeper insight into your investment mentality, objectives, and desires. We will conduct a pre-advisory consultation, which includes gathering information in a profile questionnaire and/or management software, to assess your risk tolerance, current income and expenses, career objectives, personal goals, investment time horizon, targeted rate of return, and prior investment experience. Our pre-advisory consultation is designed to:  Define and narrow objectives and investment options. Identify areas of greatest distress.   Develop a strategy for addressing future concerns.  Cultivate peace of mind; and,  Create a unique picture of your financial condition. Once your investment parameters have been identified, we will prepare a recommended allocation plan using one, or a combination of, our model portfolios with the appropriate investment strategy in an effort to achieve the most optimal return on your investment capital. The securities we use in our model portfolios will be a mix of equity (“stock”) positions, Investment Company (“mutual funds”) products, and ETFs based on your unique investment expectations and risk tolerance levels. For its clients, ShariaPortfolio requires that a written Investment Advisory Agreement (“IAA Agreement”) be signed by the client prior to the engagement of Services. The IAA Agreement outlines the services rendered by ShariaPortfolio and the fees that the client will be charged. The IAA Agreement grants ShariaPortfolio written authority to deduct fees from client custodial account(s). Clients are advised to promptly notify ShariaPortfolio if there are any material changes in their financial situations, including investment objectives, or in the event they wish to alter any guidelines. The IAA Agreement authorizes ShariaPortfolio to perform various functions, at the client’s expense, without further approval from the client. Such functions include the determination of securities to be purchased or sold. Once a client’s portfolio is constructed, ShariaPortfolio will provide continuous supervision and rebalancing of the client’s portfolio. If there are changes in the client’s circumstances, upon notification, ShariaPortfolio may recommend changes or rebalancing if required. ShariaPortfolio will have discretionary authority, to manage advisory accounts and will not obtain approval prior to placing trades on behalf of a client’s account(s). The IAA Agreement will continue until you notify us otherwise in writing. 2  For certain qualifying clients, ShariaPortfolio will recommend that a portion of such client’s assets be invested in one or more private investment funds in which the Company acts as the investment manager to the Funds. These usually include, private real estate and Digital funds, but can include other types of private funds (collectively “Private Funds”). When determining which clients should receive a recommendation to invest in a Private Fund, ShariaPortfolio considers a number of factors, including but not limited to a client’s sophistication and qualification, risk tolerance, and investment objectives. Our goal is to allocate these investment opportunities in a fair and balanced manner; however, given differing factors, the allocation of investment opportunities in Private Funds to clients is mainly subjective and not all qualifying clients will be provided an investment opportunity. Clients that receive a recommendation to invest in Private Funds will be provided with a copy of each fund’s offering documents, which should be read in their entirety prior to investing in order to understand the investment objectives, fees, risks and conflicts pertaining to such investments. Information regarding our management fee structure is disclosed under “Portfolio Management Fee” in Item 5, “Fees & Compensation” and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss”. b) Actively Managed – Aggressive Growth Account(s) The Firm has a few legacy client(s) that were looking for above average risk in order to seek usually high returns. Therefore, the Firm created Aggressive Growth Accounts utilize various aggressive tools including margin, market timing, sector fund selection, concentrated equity positions, and specialized securities designed to magnify (and in some cases produce inverse of) the performance of various market indexes. This strategy may not be tax efficient and is best implemented in qualified accounts such as IRA’s. i. Regulatory Restrictions To participate in the Aggressive Growth Account, you must meet the minimum requirements of SEC Rule 205-3(d)(1), which are only available to you if:  You fully understand the risks involved in performance-based fee management.  You have at least $1,100,000 under management with us or a net worth equal to or greater than $2,200,000; or,  You are a “qualified purchaser” under Section 2(a)(51)(A) of the Investment Company Act of 1940. ii. Performance-Based Management Conflicts In a performance-based fee account, we can earn a substantially higher fee based on the returns we generate in your account. This poses a potential conflict of interest, which could affect the objectivity of our advice and recommendations in the following ways:  Such Aggressive Growth Accounts create greater incentives for us to be more aggressive so as to achieve higher returns. When we do this, you absorb a greater risk of possible loss due to excessive trading (churning) in the account while we would only lose potential performance- based management fees.  Focus on such performance-based accounts could consume much of our time and therefore those other non-performance managed accounts could lose out on valuable time that should be devoted to all investments.  Lower fees for comparable services may be available from other sources 3  Notwithstanding such potential conflicts, we strive to serve your best interest; as well as, ensuring such performance-based management follows the Investment Advisor Act of 1940, Rule275.205-3. c) Private Funds ShariaPortfolio provides investment management services to a private fund, (i) EthicalEdge Digital Fund LLC, (the “Fund”), it qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940. ShariaPortfolio is affiliated with several other companies that serve as general partners/investment managers and/or administrators that are responsible for running the day-to-day operations of the Fund. The Fund’s investment objective is long-term capital appreciation, pursued through a dynamic, risk-based portfolio of digital assets and equities at the intersection of blockchain, fintech, and AI innovation. The Fund invests in leading digital tokens, including Bitcoin, Ethereum, Solana, and Solana-based Layer 2 protocols, alongside equity positions in “crypto proxies” or “digital asset treasuries”- public companies holding significant digital assets like Bitcoin or Solana on their balance sheets or operating in blockchain- related industries. Managed through custodial accounts with providers like Schwab and BitGo for secure digital asset storage, the Fund flexibly allocates between liquid tokens and equities based on market conditions, targeting high-growth opportunities in decentralized finance, infrastructure (e.g., miners), and emerging technologies while adhering to ethical guidelines. Additional yield may be pursued through prudent staking, airdrops, or other opportunities to optimize returns. Additionally, the Fund’s assets may be invested in publicly traded securities or cash. The publicly traded securities selected will focus on income and stability investments, including, among other things, equity stocks and mutual funds that pay dividends, with an emphasis on stability and high yield. Clients should refer to the relevant offering documents for a complete understanding of Fund’s Investment Strategy along how the Firm and its affiliated are compensated for its Services. In addition, it is recommended for each client intending to authorize the Firm to invest clients’ assets in the Fund to review the offering documents that set forth their investment strategies, guidelines, and restrictions. d) Sub-Adviser Services to ETFs The Firm acts as a Sub-Advisor to the following: (i) SP Funds Dow Jones Global Sukuk ETF (the “Sukuk ETF”), (ii) The SP Funds S&P 500 Sharia Industry Exclusions ETF (the “SPUS ETF”), and (iii) The SP Funds S&P Global REIT Sharia ETF (the SPRE ETF”), collectively the (the “Sub-Advisor ETFs”), each is independently registered with the SEC under the Investment Company Act of 1940 (the “’40 Act”). ShariaPortfolio, Tidal Investments, LLC (f/k/a Toroso Investments, LLC), CRD # 164201, an SEC registered investment adviser, (“Tidal”), the investment adviser to the Sub-Advisor ETFs, , have entered a sub-advisory agreement (the “ETF Sub-Advisory Agreement”), which Tidal has agreed to pay the Firm a sub-advisory fee equal to 0.02% of the Sub-Advisor ETFs daily average net assets; which identifies each parties’ respective financial obligations and right to any profits associated with the Sub- Advisor ETFs. ShariaPortfolio is responsible for recommending portfolio securities and other investment instruments on behalf of the Sub-Advisor ETFs. The trading of the underlying securities are subject to the supervision of Tidal. Like all other ETFs, the Sub-Advisory ETFs are not tailored to the individualized needs of any fund shareholder or investor and an investment in such a vehicle does not, in and of itself, create an advisory relationship between the shareholder, investor, the Firm or Tidal. Clients of Sharia Portfolio may authorize the Firm to purchase these Sub-Advisory ETFs in their accounts by signing a specific section of their IAA which outlines the Sub-Advisory ETFs, the fees pursuant to the Sub-Advisory and Support Agreements, and any conflicts of interest that may arise. 4  Clients and the public can invest directly in each of the Sub-Advisory ETFs without paying additional separate account management fees to the Firm. It is recommended each client carefully review both the Sub-Advisory ETFs fees and ShariaPortfolio’s advisory fees to fully understand the total amount of fees clients will pay for their investments managed by the Firm. In addition, it is recommended for each client intending to authorize the Firm to invest their assets in the Sub-Advisory ETFs to review the investment objectives, risks, charges, and expenses, please read the Sub-Advisory ETFs’ prospectus and summary prospectuses (collectively, “prospectuses”), statement of additional information, and other reports to shareholders for complete disclosures relating to the Sub- Advisory ETFs before investing. The advisory services provided to the Sub-Advisory ETFs are typically not specifically tailored to the individual needs of underlying investors in the Sub-Advisory ETFs; the investment advice and authority for each Sub-Advisory ETF are tailored to the investment objectives of that ETF. Please refer to Item 16 below for additional disclosures on our discretionary authority. e) Adviser to ETFs The Firm acts as the Advisor to the following: (i) SP Funds S&P World ETF (“the SPWO ETF”) and (ii) The SP Funds S&P Global Technology ETF (the “SPTE”), collectively the (the “SP ETFs”), each is independently registered with the SEC under the Investment Company Act of 1940 (the “’40 Act”). As stated above, it is recommended for each client intending to authorize the Firm to invest their assets in the SP ETFs to review the investment objectives, risks, charges, and expenses, please read the Advisory ETFs’ prospectus and summary prospectuses (collectively, “prospectuses”), statement of additional information, and other reports to shareholders for complete disclosures relating to the SP ETFs before investing. The advisory services provided to the SP ETFs are typically not specifically tailored to the individual needs of underlying investors in the SP ETFs; the investment advice and authority for each SP ETF are tailored to the investment objectives of that ETF. Please refer to Item 16 below for additional disclosures on our discretionary authority. f) Wrap Fee Program ShariaPortfolio also sponsors a wrap program, wherein it offers its discretionary portfolio management services via an automated online interactive website (the “Express Program”). Details regarding this program are outlined in our Form ADV Part 2A – Appendix 1 (“Wrap Brochure”). g) Benefit Plan Services/Corporate Retirement Planning ShariaPortfolio provides investment advisory services and consulting services to employer sponsored retirement plans, including 401(k) and profit-sharing plans (“Plans”), and plan sponsors (“Plan Sponsors”) subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). These services may include:  Retirement plan design and communications.  Retirement plan services provider due diligence.  Retirement plan investment advisory services including: investment analysis, selection, implementation, and ongoing monitoring of plan investments; and  Participant educational services and retirement education. ShariaPortfolio may also provide additional types of administrative services to Plans on an individually negotiated hourly basis. All services, whether discussed above or customized for the Plan will be detailed in the written agreement with the Plan Client. The Firm’s goal is to establish a thorough investment due diligence process that is employed in the 5  selection and ongoing monitoring of investment options and is compliant with applicable fiduciary obligations and the client’s investment policy statement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g. the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. ERISA sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, ShariaPortfolio will be considered a fiduciary under ERISA. For example, ShariaPortfolio will act as an ERISA §3(21) fiduciary when providing non- discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain ShariaPortfolio to act as an investment manager within the meaning of ERISA §3(38), ShariaPortfolio will provide discretionary investment management services to the Plan. With respect to any account for which ShariaPortfolio meets the definition of a fiduciary under Department of Labor rules, ShariaPortfolio acknowledges that both ShariaPortfolio and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between ShariaPortfolio and client. ShariaPortfolio may be engaged to provide one or more of the following services for Corporate Retirement Plans, the Plan Sponsor:  Investment Selection. The Firm may provide recommendations regarding the investment options to be made available under the Plan along with a relevant benchmark recommendation to the Plan Sponsor. The Firm shall be responsible for the ongoing monitoring of the Plan’s investment options and will report at least annually to the Plan Sponsor on performance and provide an analysis of the recommended investment options.  Participant Services. The Firm does not provide advisory services to Plan participants (“Participants”). The Firm will not sit with participants of the Plan Sponsor to provide advice on how, specifically, each individual should /will allocate their desired holdings in the account. We do have input on the fund selection offered in the plan, but investment selection is solely on the Participant (employee in the plan). Any recommendation made from us to a Participant (employee in the plan) will be of a categorical nature and backed from material presented by the Plan Sponsor. For example, identifying to the client in chart format what would fall into the category of Large Growth, Bonds, Small Cap funds, etc.  Assistance with Oversight of Service Providers. The Firm will aid the Plan Sponsor regarding the selection and monitoring of service providers to the Plan.  Education and Sponsor Consulting Services. The Firm will assist the Plan Sponsor and Plan Trustees in meeting their fiduciary duties to administer the Plan in the best interests of the Plan Participants and their beneficiaries. The Firm may offer periodic education and consultation to the Plan Sponsors. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without a client’s consent. 6  Assets Under Management As of December 31, 2025, ShariaPortfolio had approximately $2,993,961,239 in discretionary assets under management, as well as approximately $15,915,983 in non-discretionary assets under management, totaling approximately $3,009,877,222 in assets under management. The Firm’s regulatory assets under management include only assets for which the Firm provides continuous and regular supervisory or management services. Item 5. Fees and Compensation Investment Management Fees Portfolio management services are provided on an asset-based fee arrangement (the “Fee”) to provide discretionary portfolio management services. The Fee is an annual fee based on a percentage of the client’s assets under management (including cash, cash equivalents, and as applicable accrued interest and dividends) on the last business day of the previous calendar quarter multiplied by one- fourth the corresponding annual percentage rate (i.e., 1.50% / 4 = 0.375%). The Fee will be appropriately prorated to reflect any withdrawals and/or contributions which occur during billing cycle and shall be paid to the Firm regardless of the account’s profitability. The Firm reserves the right to discount fees based on the needs and circumstances of clients. All the below-referenced Fees are negotiable. Lower Fees for comparable services may be available from other sources. Any Fees due to the Firm shall be debited from the client’s account(s) invoiced to the client when due and shall be paid by a direct debited from the clients’ account(s). If a client opts to pay Fees by any other method than a debit of their investment account(s), those Fees are due no later than the twenty-fifth (25th) business day after the Fee is assessed. We retain discretion to negotiate the management fee within each tier on a client-by-client basis depending on the size, complexity, and nature of the portfolio managed. In addition, as your portfolio value exceeds each tier level, either through additional deposits or asset growth, a fee break will occur. The tier breaks are as follows: Standard Portfolios Up to $500,000 ........................................................................ 1.50% $500,001 to $1,000,000 ........................................................... 1.20% $1,000,001 to $5,000,000 ........................................................ 1.00% Over $5,000,000 ...................................................................... 0.75% Mutual Fund Portfolios/ETF Portfolios All Account Values ................................................................. 0.50% Defined Contribution Portfolios All Account Values .................................................................. 0.75% We generally suggest a minimum initial investment of $100,000 when opening a managed account. However, we retain the right to waive or reduce any minimum amount if we feel circumstances are 7  warranted. Clients may terminate their account(s) within five (5) business days of signing the IAA with no obligation. The Firm will be entitled to a pro rata fee for the days that service was provided in the final quarter. Client shall be given thirty (30) days prior written notice of any increase in Fees, and client will acknowledge, in writing, any agreement of increase in said Fees. Express Program Fees Our Express Program is charged a separate fee from our other programs listed in this Brochure. Information regarding the Express Program fees may be found in Item 4.B of our Form ADV Part 2A Appendix 1. Fees for the Private Fund The Firm generally receives an annual management fee of 2% for from the Fund’s assets under management, paid either monthly or quarterly, usually in advance, based on the net asset value of the Fund at the end of each month or quarter. The percentage advisory compensation rate may vary from share class to share class within the Fund, and is based on a variety of factors that may include the types and mix of assets involved; the nature and complexity of the assets; the nature and complexity of the particular Fund; the nature of the services provided; the size of the Fund; and the types and size of investors in the particular Fund. Certain strategic clients may be charged management fees and incentive allocations at lower rates than those set forth herein. In addition, the Firm may grant certain investors preferential rights with respect to various matters, including, without limitation, the right to most favorable economic terms for their investments; notice of certain events or changes in policies or practices; increased periodicity of reporting; greater transparency of the portfolio; more favorable redemption rights; and the right to make new investments when the Fund is otherwise closed to new investments. Any such fee reductions or other preferential rights shall be determined by the Firm on a case-by-case basis. The Firm or one of its affiliates also will generally receive an incentive fee or incentive allocation of up to 20% of the aggregate profits or distributions, as applicable, to investors, which is in addition to advisory and administrative fees and expenses, as described more fully in the offering documents of the Fund, as permitted by 17 C.F.R. 275.205 and/or section 205 of the Investment Advisors Act. Different share classes within the Fund may have materially different terms, including terms regarding fees charged, minimum subscription, withdrawal or redemption rights and investment options. The Firm and/or Manager of the Fund is generally permitted to open new share classes and sometimes grants requests from existing investors to transfer their interest to new share classes. The Firm/Manager of the Fund may on occasion also grant interests in new share classes to persons or entities with whom it is affiliated or otherwise associated with the Firm. In some cases, the Firm or its affiliates receive administrative servicing fees and/or re-imbursement of certain expenses from the Fund, as described in the offering documents and periodic reports of the Fund. These reimbursements are for expenses deemed by the Firm in its discretion to be beneficial services to the Funds. There is no secondary market for interests in the Fund, so investors are required to hold the interests for an extended time. The Fund is governed by a contractual relationship or other governing instrument that specifies the terms of withdrawal by an investor in the Fund for each type of investment. In general, no withdrawal is permitted other than according to the terms of the governing documents of the Fund, subject to the right in some cases of the Firm, Directors, Trustee or other affiliated entities, in their sole discretion, to waive the requirements for investors on a case-by-case basis. 8  The Firm and/or Manage of the Fund are permitted to pay placement fees, certain expenses, and servicing fees to broker-dealers acting as placement agent that place investors for the Fund, as described in the offering documents of the Fund, that may be based on a percentage of the assets initially invested, or assets remaining invested over time, from the investor, or based upon fees received by the Firm, in respect of the investors placed by that placement agent. Sub-Advisory Services to ETFs As mentioned above, pursuant to the ETF Sub-Advisory Agreement, Tidal pays Firm a sub-advisory fee equal to 0.02% of the Sub-Advisor ETFs daily average net assets. For all ShariaPortfolio clients who invest in the Sub-Advisory ETFs must acknowledge that the Asset Management Fee they pay to Sharia Portfolio based on their assets under management is in addition to the fees charged by the Sub-Advisory ETFs to which Sharia Portfolio serves as sub-advisor (which are incorporated into the price of the security and described in each such ETF’s prospectus). Each client that invests in the Sub-Advisory ETFs bears its pro rata share of the ETF’s fees and expenses, which are in addition to the Asset Management Fees the client pays to the Firm. It is recommended each client carefully review both the Sub-Advisory ETFs prospectus and ShariaPortfolio’s advisory fees to fully understand the total amount of fees clients will pay for their investments managed by the Firm. Advisor Services to ETFs This table describes the fees and expenses that a client may pay if the Firm buys and hold shares of the SP ETFs. This table and the example below do not include the brokerage commissions that investors may pay on their purchases and sales of the SP ETFs. Fee Description SPWO ETF SPTE ETF Management Fees 0.55% 0.45% 0.00% 0.00% Distribution and/or Service (12b-1) Fees Other Expenses 0.00% 0.00% 0.55% 0.45% Total Annual Fund Operating Expenses Plan Services/Corporate Retirement Planning Fees. The annual Fees are based on the market value of the Plan Assets and will not exceed 1% of the value. The Fee is charged in arrears, and the initial Fee will be based on the market value of the Plan Assets as calculated by the custodian or record keeper of the Plan on the first business day of the initial Fee period and will be due on the first business day of the Fee period. For services started any time other than the first day of a billing cycle, the Fee will be prorated based on the number of days remaining in the initial Fee period. Thereafter, the Fee will be based on the market value of the Plan Assets on the last business day of the previous Fee period (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets) and will be due within ten (10) business days. If client’s IAA Agreement is terminated prior to the end of the Fee period, the Firm shall be entitled to a prorated Fee based on the number of days during the Fee period services were provided. Any unearned Fees shall be refunded to the Plan or Plan Sponsor. 9  The Fee the Firm receives for the services it performs is described in detail in Schedule A of each ERISA Plan Agreement in which the Firm provides investment advisory services on behalf of the Plan. The Plan is obligated to pay the Fees; however, the Plan Sponsor may elect to pay the Fees. The Firm does not reasonably expect to receive any additional compensation, directly or indirectly, for providing services to the Plan. If additional compensation is received, the Firm will disclose this compensation, the services rendered, and the payer of compensation. The Firm will offset the compensation against the Fees agreed upon with the Plan Sponsor. Other Fee and Expenses The above fees for all of our portfolio management services are exclusive of any charges imposed by the custodial firm who has custody of your account, including, but not limited to:  Transaction fees.  SEC fees.  Custodial Fees.  Transfer taxes.  Wire transfer and electronic fund processing fees.  Account closing fees.  12b-1 fees from mutual funds There can also be other fees charged to your account that are unaffiliated with our management services. In addition, all fees paid to us for portfolio management services are separate from any fees and expenses charged on mutual fund shares by the Investment Company or by the investment advisor managing the mutual fund portfolios. These expenses generally include management fees and various fund expense, such as administrative fees and 12b-1 fees. Redemption fees, account fees, purchase fees, contingent deferred sales charges, and other sales load charges can occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds/ETFs is contained in each mutual funds or ETF’s prospectus. Client assets invested in Fund is also subject to management fees, performance and/or incentive fees and other expenses as described in the Fund’s offering documents. You are encouraged to carefully read all offering documents and mutual fund prospectus for full details on these fees. For more information on the custodial firm that we will recommend to custody your portfolio accounts, see Item 12, “Brokerage Practices”. Item 6. Performance-Based Fees and Side-by-Side Management Actively Managed – Aggressive Growth Account Minimum: $500,0001 Per each Aggressive Growth Accounts IAA, the Fees are based on how well the account performs over a quarterly period. The Aggressive Growth Account structure is set as follows:  If the account market value, at the close of the current calendar quarter, exceeds the prior high watermark account value by 1.00%, we will earn 25% of the trading profits over the1.00%. 1 The minimum account size of $500,000 is negotiable on a client-to-client basis. However, regardless of the minimum account size, you must still meet either the $1,000,000 or $2,000,000 requirement for performance management (See “Regulatory Restrictions” above for more information.), understand the risks involved in an aggressive investment strategy, and be able to absorb the potential loss that can occur in this type of strategy. 10   Therefore, if the quarterly account value does not achieve a 1.00% return, we do not earn a fee.  The “high watermark” is the Performance Trading portfolio market value at the close of a calendar quarter adjusted for deposits, withdrawals, and our performance fee earned from the prior quarter, if any.  The “hurdle rate” is the high watermark plus 1.00%. We must achieve the hurdle-rate in order to charge a performance fee. If the market value of the Performance Trading portfolio at the close of a calendar quarter exceeds the hurdle rate, that market value becomes the new high watermark. The high watermark resets January 1st of each calendar year. The first 1.00% in trading profits is not charged a fee.  The “market value” is the value of the Aggressive Growth Account as shown on the account statement at the close of each calendar quarter provided by the custodial firm. For example, if the high watermark is $1,000,000, and the net account value at the end of the quarter is $1,020,000, the account during the quarter had a 2% trading profit return. Our fee will be calculated as follows:  $1,020,000 - $1,010,000 = $10,000 x 25% = $2,500. This strategy is designed for clients who can tolerate above average risks in order to seek unusually high returns. This account can utilize various aggressive tools including margin, market timing, sector fund selection, concentrated equity positions, and specialized securities designed to magnify (and in some cases produce inverse of) the performance of various market indexes. This strategy may not be tax efficient and is best implemented in qualified accounts such as IRA’s. a) Withdrawing Assets from Your Performance Trading Account Should you withdraw assets from your Performance Trading account during the quarterly effectively lowering your quarterly account value to a level that could cause us to not earn a performance fee, we reserve the right to reduce the high watermark set on your account equal to the amount of your withdrawal. b) Termination of Performance Trading Services A Performance Trading account can be terminated at any time at the end of a calendar quarter. Upon termination, if your Performance Trading account exceeds the quarterly high watermark, we will bill your account our performance fee. Fees from the Private Fund As discussed in response to Item 5 above, the Firm or one of its affiliates receives a performance-based fee, i.e., incentive fee or incentive allocation from investors in the Fund, as described in the applicable Offering Documents.. Performance-based compensation are fees or allocations based on a share of capital gains on or capital appreciation of the assets of the Fund. Such compensation related to Fund is generally subject to a high-water mark, such that if an Investor’s capital account has any previously unrecouped net losses charged to it, the Firm and/or the Funds General Partners are not entitled to compensation until such time as the net losses have been recouped. This fee arrangement creates a potential conflict of interest. The performance-based fee may be an incentive for the Firm to make investments that are riskier or more speculative than would be the case absent a performance-based fee arrangement. In addition, because performance-based compensation is calculated on a basis that includes unrealized appreciation of assets, it may be greater than if such compensation were based solely on realized gains. Generally, the performance-based compensation is not negotiable. However, the Firm or the Fund’s 11  Manager may, in their sole discretion, reduce, waive or calculate differently the performance-based compensation at any time with respect to certain investors, including, without limitation, investors who are affiliated with or employed by the Firm and/or the Manager, family members of such persons and trusts or other entities created for the benefit of such investors. A performance-based compensation arrangement may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement in an effort to receive a greater performance-based compensation. Generally, the Firm maintains written policies and procedures intended to identify and mitigate conflicts. Item 7. Types of Clients ShariaPortfolio provides investment advice to individuals, high net-worth individuals, families, pension and profit-sharing plans, businesses, ERFs and Private Funds. For clients that receive Services, the minimum initial account size is generally $100,000 and at least $500,000 for clients who elect to have their assets managed in an Aggressive Growth Account. The Firm reserves the right, in its sole discretion, to waive the minimum initial investment threshold referenced above. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Our portfolio management and investment consulting services are designed to build long- term wealth while maintaining risk tolerance levels acceptable to you. We combine your financial needs and investment objectives, time horizon, and risk tolerance to yield an effective investment strategy. Your portfolio is then tailored to these unique investment parameters using a mix of equity (“stock”) positions, Investment Company (“mutual funds”) products, and Exchange-Traded Funds (“ETFs”) to achieve the best return on your investment capital. In addition, depending on your risk tolerance, we may also recommend using the following investment vehicles to achieve your desired investment objective: closed-end funds, hedge funds, private placements and other publicly traded securities. These investment vehicles bring on a whole different risk dynamic. If we recommend investment in one of these securities, we will discuss with you the limitations of such security and the potential risk factors to your portfolio. In addition, the Firm currently provides investment advisory services to the Fund which are the Firm’s client(s), subject to the direction and control of the Manager of the Fund, and not individually to the members of the Fund. The risks detailed below are not a complete list of all risks. Investing in securities involves risk of loss that clients should be prepared to bear. Clients may experience loss in the value of their account due to market fluctuations. There is no guarantee prior to investing, clients should carefully read a copy of the current prospectus for each security, where a prospectus is available. The prospectus contains information regarding the fees, expenses, investment objectives, investment techniques, and risks of these securities. The investment returns on a client account will vary and there is no guarantee of positive results or protection against loss. No warranties or representations are made by the Firm concerning the benefits of participating in the programs described in this brochure. The Firm and its employees do not provide legal or tax advice. Clients with tax or legal questions should seek a qualified independent expert. In addition, the methods of analysis, investment strategies and material risks applicable to the Firm’s advisory services are set forth in detail in the offering documents provided to each investor in the Funds and ETFs in which the Firm’s provides advisory services. Investments in the Funds/ETFs are speculative 12  and are suitable only for investors who can tolerate substantial risks. An investor may lose some or all of its investment. There is no assurance that the Funds/ETFs will be successful and will achieve their investment objectives. An investment should be considered only by sophisticated investors who understand the risks involved. The risks of investing in the Funds/ETFs and in separately managed accounts include, without limitation, those set forth below. General The transactions in which the Company will engage involve substantial risks. Growing competition may limit the Company’s abilities to take advantage of trading opportunities in rapidly changing markets or to access investment opportunities believed to be attractive. No assurance can be given that investors will realize a profit on their investments. Moreover, investors may lose all or some of their investments. Methods of Analysis Based on the client’s needs, investment objectives and time horizon, the Firm may use one of the following analyses when analyzing investment plans on behalf of its clients.  Fundamental analysis involves analyzing a company’s financial statements and health, its management and competitive advantages, and its competitors and markets. Fundamental analysis is performed on historical and present data but with the goal of making financial forecasts. There are several possible objectives: to conduct a company stock valuation and predict its probable price evolution; to make a projection on its business performance; to evaluate its management and make internal business decisions; and to calculate its credit risk. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the issuer.  Technical analysis is a method of evaluating securities by relying on the assumption that market data, such as charts of price, volume and open interest can help predict future (usually short-term) market trends. Technical analysis assumes that market psychology influences trading in a way that enables predicting when a stock will rise or fall. The technical indicators that the Firm may consider include, but are not limited to, price, volume, momentum, relative strength, sector/group strength and moving averages. Technical analysis does not consider the underlying financial condition of a company. This presents a risk that a poorly managed or financially unsound company may underperform regardless of market movement.  Quantitative Analysis. seeks to understand the behavior of a security using mathematical and statistical modeling to measure certain unique characteristics such as, for example, revenues, earnings, margins, and market share. Mathematical and statistical modeling helps us to ascertain security price and risk to ultimately help identify profitable opportunities. The key benefit of quantitative analysis is its ability to reduce complex figures to a single piece of data that is easy to grasp, discuss, and support decision-making and investment recommendations. However, using quantitative analysis alone with no further evaluation is often too narrow and sometime misleading since focus is on financial data while neglecting other details such as management experience, employee attitudes, and brand recognition.  Cyclical Analysis. Market cycles provide historic tried and true timing mechanisms to indicate turning points in future market prices. By tracking historic data through charts and graphs we can improve entry and exit strategies. Cyclical data reveals regular intervals of repeated events that can be forecasted into the future to time the market on when to buy/sell a security. The risk with cyclical analysis is attempting to buy/sell a security based on a future price prediction and missing beneficial movements in price due to an error in timing. This 13  causes harm to the value of the security being bought too high or sold too low. Analysis consists of identifying an investment area or macro-opportunity where a market dislocation has occurred and/or where an extraordinary risk/reward potential exists, identifying prospective best of breed emerging managers in the identified investment area, and analyzing quantitative measurements to determine a potential fit for the Company’s needs and expectations. Investment Strategies The Company always strives to meet the individual investment objectives of each of our clients. During an interview with a new client, will seek to understand the client’s goals and time horizon while also evaluating the client’s risk tolerance through discussion and feedback. The specific methods used to meet client investment objectives will vary but, in general will construct well-diversified investment portfolios that are comprised of low expense ratio, institutional share class mutual funds, ETFs, individual stocks, fixed income, speculative strategies, insurance products including life insurance, disability insurance and other securities that are deemed to be appropriate, given the investment profile of a particular client. Risks Associated with Compliance of Islamic Principles: The Company intends to operate in a manner consistent with the Islamic principles as they pertain to financial investing. In particular:  No Interest-Based Investments: The Company will not engage in transactions that generate or rely on interest (riba). Any financing must be structured in an Islamically-compliant form (e.g. murabaha, musharaka, ijara) approved by the Islamic advisor.  No Prohibited Sectors: The Company will not invest in businesses that derive material revenues from activities considered impermissible under Islamic principles, including but not limited to alcohol, pork products, gambling, adult entertainment, conventional financial services, or weapons.  Screening and Oversight: The Company may engage qualified Islamic advisors or firms to review investment opportunities, provide ongoing oversight, and confirm compliance with Sharia Law. The Company will use its best efforts to ensure that all investments and operations adhere to these guidelines. However, you should note that interpretations of Islamic principles may vary, and no assurance can be given that all investors will agree with the Company’s application of these principles. Islamic Compliance Oversight. The Company intends to maintain adherence to Islamic principles by implementing oversight mechanisms designed to monitor and guide investment activity. Company may engage Islamic scholars or Islamic advisory firms, who will review proposed investments, provide ongoing consultation, and issue opinions regarding the Company’s compliance with Islamic principles. The Company will endeavor to follow the guidance of such Islamic scholars or Islamic advisory firms in good faith; however, ultimate responsibility for investment decisions rests with the Company. The Company may also conduct periodic audits of compliance with Islamic principles and will implement a purification process, whereby any incidental income determined to be non-compliant (such as bank interest) will be donated to charity. These oversight practices are intended to reinforce the Company’s commitment to compliance of Islamic principles and to provide investors with additional assurance regarding the Company’s operations. Engagement of Islamic scholars or Islamic advisory firms are intended to support the Company’s compliance with generally accepted Islamic principles. However, such engagement does not constitute a certification or guarantee of compliance, and interpretations of Islamic principles and rulings may differ among scholars and investors. 14  a) Potential Risk Factors in Islamically-Compliant Investing: i. Interpretation Risk Islamic principles are not codified in a single universal standard.   Different scholars, schools of thought, and jurisdictions may apply different interpretations.  An investment deemed compliant by one Islamic scholar, or advisory firms may be rejected by another. ii. Islamic Principles Oversight and Advisory Risk  Reliance on Islamic scholars or advisory firms or supervisory boards may create costs and delays in decision-making.  Advisors may disagree among themselves or change their opinions, requiring restructuring or divestment. Investors may not accept the qualifications or authority of the Fund’s chosen Islamic advisors.  iii. Investment Opportunity Limitation  Excluding prohibited sectors (alcohol, gambling, conventional finance, etc.) narrows the investable universe.  Certain high-yield sectors or strategies may be unavailable, limiting diversification or returns. iv. Liquidity Risk  Many Islamically-compliant structures (e.g., Murabaha, Ijara, Musharakah) are less liquid than conventional debt or equity.  Exit strategies may be more complex and time-consuming, especially in private markets. v. Transaction Structure and Complexity  Costs of compliance of Islamic principles can be higher than conventional investing.  Mis-structuring could inadvertently create prohibited elements such as interest (riba) or impermissible uncertainty (gharar). vi. Operational and Administrative Risk  Purification requirements (donating non-compliant income to charity) reduce distributable profits.  Ongoing audits and reviews create administrative burdens.  Errors in screening or monitoring could result in accidental non-compliance. vii. Market and Competitive Risk  Islamically-compliant products may face limited secondary markets and investor bases compared to conventional funds.  Competition among Islamically-compliant funds for a smaller pool of permissible assets may affect pricing and returns. viii. Regulatory and Jurisdictional Risk Islamic Law is not uniform across countries (e.g., Malaysia vs. GCC vs. Western jurisdictions).   A fund deemed compliant in one jurisdiction may not be recognized as such in another.  Changes in local regulations may affect compliance or fund operations. 15  ix. Reputational Risk  Even a perception of non-compliance may damage trust among Muslim investors.  Public scrutiny of Islamic boards, advisors, or investment decisions can create reputational exposure. x. Performance Risk  By excluding interest-bearing instruments and speculative strategies, the Company may underperform conventional funds in certain market environments.  Members must accept the trade-off between compliance and potentially lower or less stable returns. b) Performance. Because the Company will operate in accordance with Islamic principles, its investment universe will be more limited than that of conventional private equity funds. This restriction may affect diversification, liquidity, and overall returns. While the Investment Manager will seek to achieve attractive risk-adjusted performance, investors should recognize that adherence to Islamic principles may result in lower or less predictable returns compared to non-Islamically-compliant funds. While the Company will seek to identify and execute attractive Islamically-compliant investments, there can be no assurance that the Fund’s performance will equal or exceed that of comparable conventional funds. Investors must be prepared for the possibility that returns could be lower, less predictable, or realized over a longer time horizon as a result of the Fund’s commitment to Sharia compliance. c) Legislation. Recently, the Florida legislature proposed and approved a bill in which certain religious law, namely Islamic/Sharia law, may not be enforced by a court, administrative law judge, hearing officer, agency, arbitration panel, or any other authority or tribunal established by law or agreement that would result in violations of one’s rights guaranteed by the United States Constitution or the Florida constitution. While the bill has not been challenged, in the event that this legislation is enforced in a manner that restricts or limits the Company’s Islamically-compliant investment principles, the ability of the Company to provide Islamically-compliant Services may be materially impaired. Furthermore, similar legislation has been introduced in other states across the United States. If such legislation is enacted and enforced in a manner that restricts or limits the Company’s Islamically- compliant investment principles, the Company’s ability to offer Islamically-compliant Services on those states may also be impaired. Risk of Loss The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the clients advised by the Firm. As a general matter, investing in securities involves a risk of loss that investors should be prepared to bear. No guarantee or representation is made that the investment strategies offered by the Firm will be successful. Clients should be able to withstand the loss of their entire investment. Subject to each client’s stated investment objective, examples of such risks include, but are not limited to: 16  a) Risks Pertaining to Certain Investment Types  Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature.  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.  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, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and 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 also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below.  Exchange Traded Funds (“ETFs”): An ETF is an investment fund traded on stock exchanges, like stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance.  Real Estate Funds: (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. a) General Risks:  Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.   Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar will be worth more today than a dollar next year, because purchasing power is eroding at the rate of inflation.  Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. 17   Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.  Leveraged Risk: As the Company is committed to complying with Sharia Law, it will not utilize traditional leverage. b) Digital Commodity Risk: To the extent strategies have exposure to digital commodities through its investments in Blockchain Funds, investment companies or ETFs, the value of those investments is subject to fluctuations in the value of the underlying digital commodity. The value of digital commodities is determined by the supply of and demand for the commodity in the global market for the trading of digital commodities, which consists of transactions on electronic digital commodity exchanges. Pricing on digital commodity exchanges and other venues can be volatile and can adversely affect the value of an investment strategy. Currently, there is relatively small use of digital commodities in the retail and commercial marketplace in comparison to speculators in the asset, thus contributing to price volatility that could adversely affect the investment. Digital commodity transactions are irrevocable and stolen or incorrectly transferred digital commodities may be irretrievable. As a result, any incorrectly executed transactions could adversely affect the value of the investment. c) Fund Performance Risk: The performance of each client’s account will depend in part upon the performance of the investment adviser to each underlying investment vehicle selected for the client’s account (Underlying Fund), the strategies and instruments used by the Underlying Funds, and ShariaPortfolio’s ability to select Underlying Funds and effectively allocate client assets among them. The Underlying Funds each have their own unique investment objective, strategies, and risks. There is no guarantee that the Underlying Funds will achieve their investment objectives and a client account will have exposure to the investment risks of the Underlying Funds indirect proportion to the allocation of assets among the Underlying Funds. The investment policies of the Underlying Funds may differ from strategy used for the client’s account. Although ShariaPortfolio will regularly evaluate each Underlying Fund to determine whether its investment program is consistent with the relevant ShariaPortfolio investment strategy, ShariaPortfolio will not have any control over the investments made by an Underlying Fund. The investment adviser to each Underlying Fund may change aspects of its investment strategies at any time. ShariaPortfolio will not have the ability to control or otherwise influence the composition of the investment portfolio of an Underlying Fund. d) Acts of God and Geopolitical Risks The performance of an Account could be impacted by Acts of God or other unforeseen including, but not limited to, natural disasters, public health emergencies (including any outbreak or threat of COVID-19, SARS, H1N1/09 flu, avian flu, other coronavirus, Ebola, or other existing or new pandemic or epidemic 18  diseases), terrorism, social and political discord, geopolitical events, national and international political circumstances, and other unforeseen and/or uncontrollable events with widespread impact. These disruptions may affect the level and volatility of security prices and liquidity of any investments. There is risk that unexpected volatility or lack of liquidity will impair an investment’s profitability or result in it suffering losses. Economics and financial markets throughout the world are becoming increasingly interconnected, which increases the likelihood that events or conditions in one country or region will adversely impact markets or securities industry participants in other countries or regions. The extent of the impact of any such disruption on the Firm, clients, Accounts, and any underlying portfolio disruption, the extent of any related travel advisories and restrictions implemented, the impact of such disruption on overall supply and demand, goods and services, investor liquidity, consumer confidence and levels of economic activity and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. A disruption may materially and adversely impact the value and performance of any investment, ultimately resulting in significant losses to the Account. In addition, there is a risk that a disruption will significantly impact, or companies. e) Reliance on Technology; Cybersecurity Risk; Back-up Measures The Firm operation is dependent on various computer and telecommunications technologies, many of which are provided by or are dependent upon third parties such as data feed, data center, telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities, could be severely compromised by system or component failure, telecommunications failure, power loss, a software-related “system crash”, unauthorized system access or use (such as “hacking”), computer viruses and similar programs, fire or water damages, human errors in using and accessing relevant systems, or various other events or circumstances. It is not possible to provide comprehensive and foolproof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunications systems or operations could have a material adverse effect on clients, including by preventing the Firm or its affiliates from trading, modifying, liquidating, and/or monitoring its clients’ investments. In addition, clients should be aware of the risk of attempted cyber-attacks, including denial-of-service attacks, and harm to technology infrastructure and data from misappropriation of corruption. Due to the Firm’s interconnectivity with third-party vendors, central agents, exchanges, clearing houses, and other financial institutions, ShariaPortfolio could be adversely impacted if any of them is subject to a cyber-attack or other information security event. Although the Firm takes protective measures and endeavors to modify its operations as circumstances warrant, computer systems, software, and networks may be vulnerable to unauthorized access, issues, computer viruses or other malicious code, and other events that could have a security impact. ShariaPortfolio has certain backup measures in place for such disruptions, but no assurance can be given that these plans will be realized, or that the Firm’s would be able to resume operations following a business disruption. While this information provides a synopsis of the events that may affect a client’s investments, this list is not exhaustive each client shall understand that there are inherent risks associated with investing and depending on the risk occurrence, a client may suffer a loss of all or part of its’ principal investment. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client should be prepared to bear. Item 9. Disciplinary Information Neither ShariaPortfolio nor any of its supervised persons have been the subject of any legal or 19  disciplinary events that would be material to an evaluation of ShariaPortfolio or the integrity of ShariaPortfolio’s management. Item 10. Other Financial Industry Activities and Affiliations Broker-Dealer, Futures or Commodity Registration Our Firm is not a registered broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor and does not have an application pending to register in any of those capacities. The Firm does not have an application pending to register, as a futures commission merchant, commodity pool operator, or commodity trading advisor. Affiliation with ShariaPortfolio ShariaPortfolio has a controlling interest in SP Funds Management, LLC (“SP FM”), which SP FM acts as the Manager to the Fund. In acting as the Manager of the Fund along with other Private Funds, ShariaPortfolio may receive distributions from SP FM. Although the Firm does not provide investment advisory services to certain of these private funds, it may recommend that eligible clients invest in such funds from time to time. Due to the Firm’s ownership interest in SP FM and the involvement of shared personnel, the Firm may have indirect economic interests in these affiliated entities. These relationships create conflicts of interest, including an incentive for the Firm to recommend its clients to invest in these affiliated private funds. The Firm has adopted policies and procedures designed to address these conflicts and to ensure that recommendations are made in the best interest of clients. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ShariaPortfolio has adopted a Code of Ethics for all its supervised persons, which describes its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes a prohibition on insider trading, provisions requiring all of ShariaPortfolio’s supervised persons to comply with applicable federal securities laws, provisions requiring ShariaPortfolio’s supervised persons to report their personal securities transactions, and provisions requiring ShariaPortfolio’s supervised persons to promptly report any violations of its Code of Ethics. All supervised persons must also acknowledge the terms of the Code of Ethics annually and as it is amended from time to time. A copy of ShariaPortfolio’s Code of Ethics is available for review by clients and prospective clients upon request. On occasion, ShariaPortfolio or its supervised persons may invest in the same securities as those recommended to clients. This may create potential conflicts of interest because (1) ShariaPortfolio or its supervised persons may have an incentive not to recommend the sale of those securities to clients in order to protect the value of their personal investment, and (2) ShariaPortfolio or its supervised persons may have an incentive to place their orders before those of clients in order to obtain a better price. All ShariaPortfolio’s employees review and acknowledge the Code of Ethics. ShariaPortfolio’s Code of Ethics addresses these potential conflicts of interest by instituting a standard of business conduct for all supervised persons, by prohibiting supervised persons from effecting certain securities transactions without obtaining pre-clearance from ShariaPortfolio’s Chief Compliance Officer and by reviewing personal securities transactions reports filed by supervised persons for potential conflicts of interest. 20  Item 12. Brokerage Practices Selection and Recommendation ShariaPortfolio generally recommends broker-dealers or custodians with whom it has established arrangements or agreements. ShariaPortfolio recommends its clients towards Charles Schwab & Co Institutional. (“Charles Schwab”), which is a an independent and unaffiliated FINRA registered broker- dealer and SIPC/NFA member. Charles Schwab offers independent investment Advisors services which include custody of securities, trade execution, clearance, and settlement of transactions. Broker‐dealers such as Schwab charge brokerage commissions and/or transaction fees for effecting certain securities transactions (i.e. transaction fees are charged for certain no‐load mutual funds, commissions are charged for individual equity and fixed income securities transactions). In addition to the Firm’s investment management fee, brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom the Firm and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade away” fee charged by the Schwab and/or Fidelity. Schwab offers independent investment advisor services which include custody of securities, trade execution, clearance, and settlement of transactions. ShariaPortfolio may receive some of these services from Schwab through its arrangement with them. (Please see the disclosures under Item 14 below.) As stated above, the Firm is separate and unaffiliated with Schwab. This arrangement is designed to maximize efficiency, enhance the ability to monitor positions, and to be cost effective for clients. By recommending that clients use the specified custodian, we seek to achieve the most favorable execution of client transactions. Factors considered by the Firm in making a recommendation of a brokerage firm include the size and reputation of the Firm, its capital position, commission rates in comparison to other firms, and reporting procedures on client accounts. ShariaPortfolio will not accept custody of client funds or securities. Directed Brokerage In circumstances where a client directs ShariaPortfolio to use a certain broker-dealer, ShariaPortfolio still has a fiduciary duty to its clients. The following may apply with Directed Brokerage: ShariaPortfolio' inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among clients and conflicts of interest arising from brokerage firm referrals. Best Execution Investment advisors who manage or supervise client portfolios on a discretionary basis have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves several considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker- dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. ShariaPortfolio does not receive any portion of the trading fees. 21  Trade Errors Trade errors occasionally happen in client accounts. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner that is in the best interest of our clients. In cases where the error was caused by the client, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated because of the error correction. In all situations where the client does not cause the trade error, the client will be made whole, and the Firm will absorb any loss. If the trade error is caused by the broker-dealer, the broker-dealer will cover all trade error costs. If an investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit or profit from trade errors. Soft Dollar Arrangements The Securities and Exchange Commission defines soft dollar practices as arrangements under which products or services other than execution services can be obtained by ShariaPortfolio from or through a broker-dealer in exchange for directing client transactions to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, ShariaPortfolio may receive economic benefit because of commissions generated from securities transactions by the broker-dealer from the accounts of ShariaPortfolio. These benefits can include both proprietary research from the broker and other research written by third parties. A conflict of interest exists when ShariaPortfolio receives soft dollars. This conflict is mitigated by the fact that ShariaPortfolio has a fiduciary responsibility to act in the best interest of its clients and the services received are beneficial to all clients. ShariaPortfolio does not participate in any soft dollar arrangements. Principal Transactions Section 206(3)-1 under the Advisers Act regulates principal transactions among an investment adviser and its affiliates, on the one hand, and the clients thereof, on the other hand. Very generally, if an investment adviser or an affiliate thereof proposes to purchase a security from, or sell a security to, a client (what is commonly referred to as a “principal transaction”). To comply with this Rule, the Firm must make certain disclosures to its client(s) of the terms of the proposed transaction and obtain the client’s consent to the transaction. ShariaPortfolio does not participate in any Principal Transactions. f) Cross Trades Section 206(3)-2 under the Advisers Act regulates agency cross transactions among an investment adviser and its affiliates, on the one hand, and the clients thereof, on the other hand. Very generally, an Agency cross transaction occurs when an Adviser, or any person controlling, controlled by, or under common control with such Adviser, acts as a broker for a person who is not the Firm’s client and affects a sale or purchase of a security for the account of a client, (what is commonly referred to as a “cross transaction”). To comply with this Rule, the Firm must make certain disclosures to its client(s) of the terms of the proposed transaction and obtain the client’s consent to the transaction. ShariaPortfolio does not participate in any Cross Trades. Balancing the Interests of Multiple Client Accounts. The Firm may manage numerous accounts with similar or identical investment objectives or may manage accounts with different objectives that may trade in the same securities. Despite such similarities, portfolio decisions relating to a client’s investments and the performance resulting from such decisions may differ from client to client. 22  Aggregating (Block) Trading For Multiple Client Accounts. The Firm will not necessarily purchase or sell the same securities at the same time or in the same proportionate amounts for all eligible clients, particularly if different clients have materially different amounts of capital under management by the Firm or different amounts of investable cash available. Therefore, not all clients will necessarily participate in the same investment opportunities or participate on the same basis. The Firm may allocate investment and trading opportunities among various clients in a manner believed by the Firm to be fair and equitable to each client over time. The Firm may place a Block Trade to purchase or sell the same security for multiple accounts if the Firm believes it will result in a more consistent execution among clients. The Firm will not include a client in a Block Trade unless the transaction is consistent with the client’s investment objectives and/or restrictions. In determining whether to include or exclude a client’s account in a Block Trade, the Firm will consider the following factors:  The client’s investment objectives and strategies  The composition, size, and characteristics of an account  The cash flows and amount of investment funds available to each client  The amount already committed by each client to a specific investment.  Each client’s risk tolerance and the relative risk of the investment  The marketability of the security being considered.  Whether the Advisor has trading discretion over the account. Valuation The Firm will rely on the custodians and/or independent 3rd Party pricing services to value securities in each client’s accounts that are listed on a national securities exchange or on NASDAQ at the last quoted sales price on the principal market where the securities are traded. Item 13. Review of Accounts Schedule for Periodic Review of Client Accounts Account reviews are performed at least annually by the Firm’s IA-Reps. Account reviews are performed more frequently when market conditions dictate or when the client or IA-Rep deems appropriate. Clients should review their account statements provided by the custodians and if they have any questions, please contact the Firm. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Content of Client Provided Reports and Frequency You will receive statements, at least quarterly, from Schwab or wherever your account(s) are held in custody. You are encouraged to review the trading activities disclosed on your account statements which summarizes your portfolio account value, current holdings, and all account transactions made during the quarter. It is important for you to review these documents for accurate reporting and to determine whether we are meeting your investment expectations Daily Reviews Generally, the portfolio managers of the Fund review the Fund’s account(s)s quarterly. These reviews will 23  focus on appropriateness of the Fund’s investments for the Fund’s portfolio and the performance of the Fund. Investors in the Fund generally receive, among other things, a copy of audited financial statements of the Fund within 120 days after the fiscal year end of the Fund. In addition, investors in each Fund may receive unaudited summary financial information regarding the Funds following the end of each financial quarter. Investors in the Funds also receive regular reporting updates through letters and investor meetings. Item 14. Client Referrals and Other Compensation We do have arrangements in place where we compensate persons for client referrals provided such persons are qualified and have entered a solicitation agreement with us as required by Rule 206(4)-1 of the Investment Adviser Act of 1940, as amended. Under such arrangements, if a solicitor referred you, the solicitor would provide you complete information on our relationship – the relationship between the solicitor and us – and the compensation the solicitor will receive should you choose to open an account. This compensation will be paid solely from our fee and will not result in any additional charge to you. In addition, we will adhere to each state’s rules and regulations where the solicitor resides prior to entering into any solicitation agreement with that person. The solicitor is not licensed to give you any investment advice and therefore cannot advise you on the management of your account. A solicitor simply makes an introduction and is compensated only if you were to open a management account with us under these arrangements. The Company receives an indirect economic benefit from Schwab (See “Custodial Services” above under Item 12, “Brokerage Practices” for more detailed information on these services and products could be.). Item 15. Custody Custody of Non-Fund Assets. All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to the performance report statements prepared by SIS. ShariaPortfolio is deemed to have constructive custody solely because advisory fees are directly deducted from client’s account(s) by the custodian on behalf of SIS. Custody of Fund Assets. The Firm may be deemed to have constructive custody of certain client assets pursuant to Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (the “Custody Rule”), as a result of fee payments or the service of its affiliates as Manager to the Fund. Actual custody of funds and other client assets, however, is at a qualified custodian, not at the Firm. Notwithstanding the foregoing and on occasion, some assets or certificates will not be accepted by the qualified custodians, and such assets or certificates will be custodied by the Firm in accordance with applicable SEC guidance. Currently, the qualified custodians utilized by the Firm is Schwab and BitGo, as otherwise disclosed in the disclosure documents for the Fund. On occasion, some assets or certificates will not be accepted by the qualified custodians, and such assets or certificates will be custodied by the Firm in accordance with applicable SEC guidance. To ensure compliance with the Custody Rule, the Firm reasonably believes that all investors in the Fund will be provided with audited financial statements for the Fund, prepared by an independent public accountant that is registered with, and subject to regular inspection by the Public Company Accounting 24  Oversight Board, in accordance with International Financial Reporting Standards, within 120 days of the end of the Fund’s fiscal years. In addition, investors receive capital account statements on a quarterly basis, directly from the Firm’s manager, SP Fund Management. or an affiliate thereof. Investors should carefully review such audited financial statements and capital account statements. Item 16. Investment Discretion We have you complete our IAA which sets forth our authority to buy and sell securities in whatever amounts are determined to be appropriate for your account and whether such transactions are with, or without, your prior approval. You may, at any time, impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of leverage, etc.). In addition, the Firm has discretionary authority to determine the investments to be bought or sold and the amounts to invest for each client, including the Fund under the governing In addition, the Firm has discretionary authority to determine the investments to be bought or sold and the amounts to invest for each client, including the Fund under the governing documents of the Fund and other agreements. Item 17. Voting Client Securities Voting of Voting Client Securities - Non-Fund Assets. For clients assets which are custodied at Charles Schwab or another custodian and not invested in the Fund, the Firm does do not vote client proxies. You understand and agree that you retain the right to vote all proxies solicited for securities held in your managed accounts. The custodian of your managed accounts will mail you all proxy solicitations. Any proxy solicitations inadvertently received by us will be immediately forwarded to you for your evaluation and decision. However, if you have specific questions regarding an action being solicited by the proxy that you do not understand or you want clarification, you may contact us and we will explain the particulars. Keep in mind we will not advise you in a direction to vote; the ultimate decision on how you vote is your responsibility and left to you to decide. Voting of Fund Securities The Firm has adopted proxy voting policies and procedures, to guide the Firm’s exercise of this responsibility on behalf of the Fund. Information on the proxy voting record of the Firm is available upon request. The portfolio manager reviews the specific issue and votes in accordance with what he believes to be the best interests of the Fund. Usually, this vote is with management. With respect to shareholder governance, covenants, social issues and other votes, it is the policy of Firm to discuss each of these votes and issues internally in order to determine its position on a case-by-case basis. Firm can, upon occasion, delegate, pursuant to its approved voting procedures, the right to vote on particular issues to the individual monitoring that investment. The Firm has in place procedures to identify conflicts it could develop in voting proxies. In the event of a conflict, Firm has the option to abstain from voting if the vote is not likely to be affected; retain a disinterested third-party adviser to advise on the vote; vote the shares in proportion to other “yes” and “no” votes received by the issuer; or take such other actions, as will be appropriate in the particular context. Investors can obtain a copy of Firm’s proxy voting policies and proxy voting records by contacting the 25  Firm’s Chief Compliance Officer. Item 18. Financial Information Under this disclosure item, the SEC requires advisers to disclose certain financial information if, among other things, the adviser requires pre-payment of advisory fees of more than $1,200 per client, six months or more in advance, or the adviser’s financial condition is reasonably likely to impair its ability to meet its contractual commitments to clients. Because ShariaPortfolio does not require such pre-payments and its financial condition is not impaired, this disclosure item is not applicable. 26 

WRAP FEE PROGRAM BROCHURE Form ADV Part 2A Appendix 1 March 31, 2026 ShariaPortfolio, Inc. 1331 S. International Parkway, Suite 2291 Lake Mary, Florida 32746 Phone: (321) 275-5125 Fax: (321) 275-5126 www.shariaportfolio.com This wrap fee program brochure provides information about the qualifications and business practice of ShariaPortfolio, Inc. If you have any questions about the contents of this brochure, please contact us at 321-275-5125 or info@shariaportfolio.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state security authority. Additional information about ShariaPortfolio, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. ShariaPortfolio, Inc. is a registered investment adviser with the United States Securities and Exchange Commission (“SEC”). Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of ShariaPortfolio, Inc. provides you with information about which you may use to determine to hire or retain ShariaPortfolio, Inc.  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ITEM 2: MATERIAL CHANGES SEC Rule 204-3(b)(2) allows us to provide you with a summary page of Material Changes in lieu of sending out our entire Wrap Fee Program Brochure. If you are being offered this Material Change page as a separate piece from our Wrap Fee Program Brochure and you have questions about these summary disclosures or would like a current copy of our Wrap Fee Program Brochure to review, you may contact us and a current, complete Wrap Fee Program Brochure will be sent free of charge. Since our last update of this brochure in March 2025, the following material updates were made: • Enhanced disclosure of wrap fee program conflicts of interest • Clarification of fee structure and comparison to non-wrap services • Addition of digital platform and third-party technology risk disclosures • Clarification of the Firm’s proxy voting practices with respect to the private fund managed by the Firm • Clarification of the Firm’s role with respect to certain private funds that are operated by affiliated entities and/or their principals. The structure and allocation of responsibilities among these entities may vary and the Firm’s affiliates may participate in the investment and operational activities of such funds. Pursuant to State and SEC Rules, ShariaPortfolio, Inc. (“ShariaPortfolio” or the “Firm”) will ensure that clients receive a summary of any materials changes to this Brochure within 120 days of the close of ShariaPortfolio’s fiscal year. Additionally, as the firm experiences material changes in the future, we will send you a summary of our “Material Changes” under separate cover. For more information about the firm, please visit www.shariaportfolio.com. 2  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ITEM 3: TABLE OF CONTENTS ITEM 4: SERVICES, FEES AND COMPENSATION ....................................................................................................................... 4 ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................................................................ 6 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ....................................................................................... 6 ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ....................................................................... 8 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................................. 8 ITEM 9: ADDITIONAL INFORMATION .......................................................................................................................................... 8 3  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ITEM 4: SERVICES, FEES AND COMPENSATION Wrap Fee Program Overview ShariaPortfolio sponsors a wrap fee program (the “Express Program” or “Program”), through which clients pay a single asset-based fee for bundled advisory, brokerage, custody, and administrative services. The Program is offered through an online platform and provides discretionary portfolio management using model portfolios. The Firm determines suitability for participation based on client information. Services Provided Services include: • Portfolio management on a discretionary basis • Asset allocation and rebalancing • Ongoing monitoring of client accounts • Access to client service support via electronic and telephone communication Client Onboarding and Portfolio Selection As part of the onboarding process, the Firm collects information regarding a client’s financial situation, investment objectives, risk tolerance, time horizon, and other relevant factors through an online assessment and/or discussions with the client. This information is used to recommend an appropriate investment strategy and model portfolio. Clients are responsible for notifying the Firm of any material changes to their financial circumstances or investment objectives so that the Firm can update its recommendations and portfolio management approach as necessary. Charles Schwab & Co., Inc. (“Schwab”) serves as the qualified custodian and executes transactions. Fees Clients pay a single asset-based fee, billed quarterly in advance, which covers advisory services, custody, and most transaction costs. In addition to the wrap fee, clients will incur indirect expenses associated with investments held in their account, including ETF and mutual fund expense ratios and other investment-related costs. These expenses are in addition to the wrap fee and will reduce overall returns. The wrap fee does not include: • ETF and mutual fund expense ratios Internal fund fees and expenses • • Certain transaction costs (e.g., trades executed away from the custodian) • Wire fees, taxes, or other account-related expenses Wrap Fee vs. Non-Wrap Programs The wrap fee program may cost more than purchasing advisory and brokerage services separately, particularly in accounts with low trading activity or buy-and-hold strategies. Conversely, accounts 4  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 with higher trading activity may benefit from bundled pricing. Clients should consider expected trading frequency and account activity when evaluating whether the Program is appropriate. Conflicts of Interest – Wrap Fee Structure Because the Firm bears certain transaction costs associated with client accounts, the Firm has a financial incentive to reduce trading activity, select investments with lower transaction costs, or otherwise manage accounts in a manner that minimizes such costs. This may create a conflict of interest, as it could influence the Firm’s trading decisions. The Firm addresses this conflict by maintaining policies and procedures designed to ensure that investment decisions are made in the client’s best interest. Affiliated Investment Products The Firm may recommend or allocate client assets within the Program to ETFs or other investment products for which the Firm or its affiliates serve as investment adviser, sub-adviser, or otherwise receive economic benefits. The Firm also manages a private fund outside of the Program. The Firm is affiliated with SP Funds Management, LLC (“SP FM”), an entity involved in the operation of certain private funds. Although the Firm does not provide investment advisory services to certain of these funds, it may recommend that eligible clients invest in such funds from time to time. Due to the Firm’s ownership interest in SP FM and the involvement of shared personnel, the Firm may have indirect economic interests in these affiliated entities. These relationships create conflicts of interest, including an incentive to recommend investments in affiliated private funds. The Firm charges an asset-based fee for accounts in the Express Program, billed quarterly in advance, based on assets under management as follows: Assets Under Management 0 to $500,000 $500,000 to $1,000,000 $1,000,001 to $5,000,000 > $5,000,000 Mutual Fund/ETF Portfolios Annual Advisory .75% .60% .50% .40% .50% The wrap fee includes portfolio management, administration, and Schwab’s custody, trade execution, and related brokerage services. Clients should be aware that the wrap fee does not include certain costs, including ETF and mutual fund expense ratios, internal fund expenses, and other account-related fees, which will reduce overall returns. Additional Fee Considerations Clients funding Program accounts through the liquidation of investments outside the Program may incur tax consequences, redemption fees, or other costs. The total cost of the Program may be higher or lower than purchasing advisory and brokerage services separately. In particular: 5  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 • Accounts with low trading activity or buy-and-hold strategies may pay more in a wrap program • Accounts with higher trading activity may benefit from bundled pricing Because the Firm bears certain transaction costs in wrap accounts, the Firm has an incentive to reduce trading activity, which creates a conflict of interest. Lower fees for comparable services may be available from other providers. Fees may be negotiated at the Firm’s discretion. Billing and Termination Fees are billed quarterly in advance and are prorated for accounts opened or terminated during a billing period. Either party may terminate the advisory agreement upon written notice. Upon termination: • Fees are prorated through the termination date • Unearned fees are refunded • Any earned but unpaid fees are due Following termination, the Firm will cease management of the account, and clients will be responsible for investment decisions. The custodian may require additional time to transfer or liquidate assets. Asset Allocation Models The Program utilizes model portfolios with target allocation ranges across asset classes, including equity, Sukuk (income), cash, and real estate. Allocations may vary based on market conditions, and portfolios may temporarily deviate from target ranges when deemed appropriate. Wrap Fee Considerations The wrap fee is not based on the number of transactions in the account. The relative cost of the Program depends on factors such as account size, investment strategy, and trading activity. As a result, the Program may cost more or less than paying for advisory and brokerage services separately. The Program utilizes model portfolios with target allocations across asset classes, including equities, income (Sukuk), cash, and real estate. Allocations vary based on the selected investment strategy and may change over time. Under certain market conditions, portfolios may deviate from target allocations. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS The Program is available to individuals, IRAs, and certain trusts. The Program is generally not available to ERISA plans or institutional clients. While there is no strict minimum account size, the Firm may establish operational thresholds and investment limitations based on account size. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION Selection and Review of Portfolio Manager 6  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ShariaPortfolio serves as the portfolio manager for Program accounts. Investment Adviser Representatives manage client accounts using model portfolios and are subject to internal oversight and review. The Firm conducts ongoing internal reviews of portfolio performance, consistency with model strategies, and adherence to client objectives. Performance-Based Fees The Program does not include performance-based fees. However, the Firm offers performance-based fee arrangements in other advisory programs, which may create differences in incentives across accounts. Investment Strategies and Risks Investment strategies are primarily based on diversified model portfolios utilizing ETFs and other securities. Risks include: Interest rate risk • Market risk • Liquidity risk • • Allocation risk Wrap Program-Specific Risks Additional risks include: • Reduced trading activity due to cost considerations • Higher overall costs for low-activity accounts • Reliance on model portfolios Digital Platform Risk The Program relies on third-party technology providers and digital platforms. Risks include system outages, cybersecurity incidents, data inaccuracies, vendor dependency, and service interruptions, any of which could impact account access, trading, or reporting. Voting Client Securities The Firm does not vote proxies for wrap program client accounts. Clients retain the responsibility for voting proxies for securities held in their accounts, and proxy materials are sent directly to clients by the custodian. The Firm may vote proxies with respect to certain private fund investments where it has been delegated such authority. 7  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 If the Firm receives proxy materials on behalf of a client, such materials will be promptly forwarded to the client. Upon request, the Firm may provide information to help clients understand proxy matters; however, the Firm does not provide advice or recommendations on how to vote. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Investment Adviser Representatives (“IARs”) manage client accounts within the Program. In connection with account onboarding, the Firm collects information regarding a client’s financial situation, investment objectives, and risk tolerance, which is used to determine an appropriate investment strategy and model portfolio. Ongoing account management is based on this information and any updates provided by the client. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS Clients may contact the Firm through electronic communication or telephone. There are no restrictions on client access. ITEM 9: ADDITIONAL INFORMATION Brokerage and Custodial Conflicts The Firm recommends Schwab as custodian and receives certain economic benefits from this relationship. These benefits create a conflict of interest, as they provide an incentive to recommend Schwab. Code of Ethics and Personal Trading The Firm maintains policies to address conflicts related to employee trading and client transactions. Review of Accounts Accounts are monitored on an ongoing basis and reviewed periodically to ensure consistency with client objectives. Client Referrals The Firm may compensate solicitors in accordance with applicable regulations. Financial Information The Firm does not require prepayment of fees exceeding regulatory thresholds and has no financial condition impairments. Disciplinary History Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the Firm or the integrity of its management. The Firm has no such disciplinary events to disclose. 8  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 Other Financial Industry Activities and Affiliations Naushad Virji, a principal and majority shareholder of the Firm serves as Chief Executive Officer of SP Funds Management, LLC (“SPFM”), an affiliated entity involved in certain private funds. Mr. Virji also serves as Chief Executive Officer of Virji Investments, Inc., an investment adviser registered in the State of Florida. Mr. Virji’s involvement with these entities may create potential conflicts of interest, including the allocation of time and resources among multiple business activities. In addition, due to the Firm’s affiliation with SPFM, the Firm may have an incentive to recommend that eligible clients invest in certain affiliated private funds. The Firm has adopted policies and procedures designed to address these conflicts and to ensure that advisory services are provided in the best interest of clients. . 9