ZOE FINANCIAL, INC.

Zoe Financial, Inc. Wealth Platform Wrap Fee Program Brochure Zoe Financial, Inc. c/o Studio by Tishman Speyer 666 Third Ave, 6th Floor New York, NY, 10017 (646) 680-9244 www.zoefinancial.com April 24, 2026 This wrap fee program brochure (the "Brochure") provides information about the qualifications and business practices of Zoe Financial, Inc. ("Zoe," "we," "us," or "our"). If you have any questions about the contents of the Brochure, please contact us at 646-680-9244 or compliance@zoefin.com . The information in the Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. information about Zoe also is available on the SEC's website at Additional www.adviserinfo.sec.gov . Registration as an investment adviser does not imply a certain level of skill or training.  Item 2: Material Changes This Item discusses material changes to this Brochure since the last annual amendment dated April 20, 2026. Zoe has the following changes to disclose in relation to this Item: ● ● ● ● ● ● ● ● ● ● ● ● ● ● introducing solely Zoe has added a description of its methods of analysis and investment strategies for sub-advisory services, including its process for selecting and reviewing Model Portfolios and third-party providers, in Item 6. Zoe has added risk disclosures specific to Model Portfolios and sub-advisory services in Item 6. Zoe has expanded its disclosure regarding portfolio manager selection and evaluation, including related persons acting as portfolio managers and performance information standards, in Item 6. Zoe has added disclosure regarding the amount of client assets managed on a discretionary and non-discretionary basis in Item 4. Zoe has clarified that no individual entity other than its principal owner holds 25% or more of Zoe in Item 4. Zoe has added a disclosure regarding whether the persons recommending the wrap fee program receive compensation for doing so in Item 4. Zoe has expanded its disclosure of the factors that bear upon the relative cost of the Program compared to purchasing services separately in Item 4. Zoe has added disclosure that it does not accept individual Client investment restrictions in connection with its sub-advisory services in Item 4. Zoe has added an explicit bankruptcy disclosure in Item 9. Zoe has added disclosure regarding differences between the wrap and non-wrap fee structures in Item 6. Zoe has added disclosure regarding a principal's advisory board role at Diversified LLC, an independent financial services firm, and the associated conflict of interest. See item 9. Zoe has updated its proxy voting disclosure to clarify that Zoe does not have authority to vote proxies for securities held in Client Accounts. Clients receive their proxies directly from their Custodian or a transfer agent and are responsible for voting their own proxies in Item 9. Zoe expanded the Platform to support multiple qualified custodians ("Approved Custodians"), currently including Apex Clearing Corporation and Charles Schwab & Co., Inc. Additional custodians may be added. Zoe does not recommend any Approved Custodian; selection is the RIA's responsibility. Client assets are held at the applicable Approved Custodian; Zoe does not have custody of Client funds or securities, and Zoe's authority to instruct Custodians to deduct advisory fees from Client Accounts does not, standing alone, constitute custody under SEC Rule 206(4)-2. See Items 4 and 9. Zoe updated the role of its affiliated broker-dealer, Zoe Securities, LLC, to clarify it acts for accounts at custodians supporting that broker-dealer as relationship (currently Apex). See Items 4 and 9. 2  ● ● Zoe added multi-custodial risk disclosures in Item 6 and multi-custodial conflicts disclosure in Item 9. Zoe has expanded its ownership disclosure in Item 4 and Item 9 to identify Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. as holders of direct minority ownership interests in Zoe. You may request a copy of our current Wrap Fee Program Brochure, free of charge, by contacting us at (646) 680-9244 or compliance@zoefin.com , or by visiting our website at www.zoefinancial.com . Additional information about Zoe is available through the SEC's Investment Adviser Public Disclosure website at https://adviserinfo.sec.gov/. 3  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Services, Fees and Compensation Item 5: Account Requirements and Types of Clients Item 6: Portfolio Manager Selection and Evaluation Item 7: Client Information Provided to Advisors Item 8: Client Contact with the Advisor Item 9: Additional Information 1 2 4 5 12 13 17 18 19 4  Item 4: Services, Fees and Compensation Advisory Services Zoe Financial, Inc. ("Zoe," "we," "us," or "our") is a Corporation organized in the State of Delaware. Zoe was formed in June 2016 and its principal owner is Andres Garcia. No other individual or entity holds 25% or more of Zoe. Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. each hold minority ownership interests in Zoe. Certain registered investment advisers, including Creative Planning, LLC and affiliates of CapFinancial, LLC, Mariner, LLC dba Mariner Wealth Advisors, Sequoia Financial Advisors, LLC, Perigon Wealth Management, LLC, and Falcon Wealth Planning, Inc., hold indirect minority interests in Zoe. These relationships are further described in Item 9. The Brochure describes Zoe Financial, Inc. Wrap Program (the "Platform" or the "Zoe Wealth Platform"), which is Zoe's turnkey asset management program, pursuant to which Zoe provides reporting, administrative, sub-advisory, and other support services to third-party registered investment advisers ("RIAs") on behalf of their underlying advisory Clients ("Clients"). For information about Zoe's online referral program pursuant to which Zoe refers to users of our website at www.zoefinancial.com ("Users") to RIAs that participate in the "Zoe Advisor Network," please refer to Zoe's separate Disclosure Brochure, which is available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . goals and objectives; provide any The Program is a service pursuant to which Zoe provides administrative, management, sub-advisory, and support services relating to the administration of Client Accounts (as defined below) managed by the RIAs that offer investment advice to Clients and manage assets of Clients through the Zoe Wealth Platform. RIAs engage Zoe for the provision of such services on behalf of their Clients through a Turnkey Asset Management Agreement between Zoe and the RIA (each a "TAMP Agreement"). The Services provided to each RIA vary in accordance with their TAMP Agreements with Zoe, however, except with respect to Sub-Advisory Services provided to Clients, as more fully described below, neither Zoe nor Zoe Securities act as an investment adviser to Clients; possess knowledge of any individual Client's information or Client personalized investment advice; investment recommend any securities, transactions, or investment strategies to Clients; solicit orders; make discretionary trades; or provide legal or tax advice. To participate in the Program, a Client will enter into an advisory agreement with his or her RIA that outlines the services to be performed by the RIA, the authority of the RIA and/or the Client over transactions effected for the Client (including the authority for the RIA to engage Zoe on behalf of Client to perform the services pursuant to the TAMP Agreement), the compensation to be paid by the Client to the RIA. A Client will open a custodial account ("Client Account") with one or more qualified custodians supported by the Platform (each, an "Approved Custodian"), as designated by the Client's RIA or the Client. As of the date of this Brochure, the Approved Custodians include Apex Clearing Corporation ("Apex") and Charles Schwab & Co., Inc. ("Schwab"). Zoe may add or remove Approved Custodians from time to time; a current list is 5  maintained on the Platform and available upon request. Zoe is not affiliated with any Approved Custodian and does not recommend, endorse, or evaluate any Approved Custodian for RIAs or their Clients. The selection of the Approved Custodian is the sole responsibility of the RIA or the Client. Except where Clients have a third-party broker, Clients whose accounts are held at Approved Custodians supporting an introducing broker-dealer relationship will generally become customers of Zoe's affiliated introducing broker, Zoe Securities, LLC ("Zoe Securities"), an SEC-registered broker-dealer and member of FINRA. As of the date of this Brochure, Zoe Securities introduces Client Accounts solely to Apex on a fully disclosed basis. Zoe Securities does not introduce accounts to, route trades for, or have any role with respect to Client Accounts held at Schwab or other Approved Custodians. It is the responsibility of the RIA to gather sufficient information from the Client to evaluate the Client's financial situation, investment objectives, financial goals, tolerance for risk, and investment time horizon. Because the management of a Client's investments is based on the Client's financial circumstances, it is important that the Client provides complete and accurate information to the Client's RIA. The RIA is also responsible for determining whether the Client's participation in the Program is appropriate for the Client, and for selecting the appropriate investment strategy. Additional The Program has a wrap structure that provides Clients with advisory and other services with no additional transaction costs pursuant to the Program. Except as set forth below in the section Fees and Expenses, Zoe's fees cover the administration fees, discussing maintenance fees, and trading and custody fees incurred pursuant to the Program. Zoe's fees are not based directly upon the actual transaction or execution costs for the transactions within Client Accounts. Under a typical wrap fee program, a Client will pay a higher advisory fee than had advisory fees and transaction costs been charged separately. Please see below for additional detail regarding Zoe's fees, the RIA's fees, and other fees a Client will be charged in connection with assets managed through the Program. The Program may cost a Client more or less than purchasing advisory, brokerage, custody, and other services separately. The following factors bear upon the relative cost of the Program for a particular Client: ● ● ● ● Trading frequency. Clients whose accounts are traded more frequently may benefit from the wrap structure because transaction costs are included in the Wrap Fee. Clients whose accounts are traded infrequently may pay more under the wrap structure than they would if they paid for each transaction separately. Account size. The Wrap Fee is calculated as a percentage of assets. Clients with larger accounts will pay higher dollar amounts in fees. Types of securities held. Certain securities, such as mutual funds, carry embedded fees (e.g., management fees, 12b-1 fees) regardless of the fee structure. These are in addition to the Wrap Fee. RIA advisory fees. Each Client's RIA charges an advisory fee that is separate from, and in addition to, Zoe's Wrap Fees. The combined cost of the RIA fee and the Wrap Fee should be compared to the cost of obtaining similar services elsewhere. 6  ● Cost of services if purchased separately. A Client may be able to obtain advisory, brokerage, and custody services from other providers at costs that are higher or lower than the combined fees under the Program. Clients are encouraged to evaluate the total cost of the Program relative to their unique circumstances and to discuss such costs with their RIAs. Client Investment Restrictions. Zoe does not accept individual Client investment restrictions in connection with its sub-advisory services. Clients who wish to impose restrictions on investing in certain securities or types of securities should discuss such restrictions with their RIA. The RIA is responsible for determining whether such restrictions can be accommodated within the Program. Managed Account Program RIAs are responsible for assisting Clients in selecting an investment strategy and completing a suitability review. Pursuant to a Client's investment management agreement with a Client's RIA, the RIA has discretionary authority to buy, sell, or otherwise effect transactions in stocks, options, bonds, mutual funds, money market funds, exchange traded funds ("ETFs"), and any other securities in the Client's Client Account. RIAs will submit trade instructions directly to the Custodian for execution. RIAs also may grant Zoe the authority to submit trades per their instructions to the Custodian for implementation. This authorization may also include the ability to rebalance or reallocate the account, in which case Zoe will do so in accordance with the RIA's pre-determined investment criteria for the Client. Except where Zoe has been engaged as sub-advisor, as described more fully below, Zoe is not responsible for providing investment advice to any RIA's Client by virtue of its authority to submit trades and/or rebalance a Client's account in accordance with the RIA's pre-determined investment criteria. A Client's RIA will manage minimum cash in the Client Account and can also define the minimum cash percentage as rebalancing account defaults in the Zoe Wealth Platform. All stock and ETF dividends will be paid to cash unless requested otherwise at the time of onboarding. A Client's RIA will have the ability to select the appropriate setting as part of the onboarding process. Client trades are sent to the Custodian. Each Custodian aggregates Client trades for execution, and allocates securities among Client accounts on a pro-rata basis based on the average price of all securities that were block traded. Although stocks and ETFs may be traded throughout the day at market prices, the last trade instructions are generally sent to Custodian at or before 3pm Eastern Time, subject to exceptions at Zoe's discretion. 7  Clients will receive notification of all transactions in his or her Client Account in the form of a monthly account statement provided by the Custodian each month. Clients will remain the owner of all securities held in their Client Accounts and have all ownership rights associated with such securities. Sub-Advisory Services RIAs may allocate Client Accounts to Zoe for sub-advisory services. Such accounts shall include all Client Accounts for which an RIA utilizes its own custom model ("Custom Model") or a model portfolio made available through the platform and managed by Zoe or a third-party provider (each a "Model Portfolio") that the RIA engages Zoe to maintain on a limited discretionary basis, as well as sub-advised through the Zoe Wealth Platform. Such limited discretionary authority includes authority to: (a) buy and sell securities to maintain a Custom Model or Model Portfolio selected by RIA following receipt of a liquidation or transfer request from a Client (either directly or via RIA); (b) effect any changes to Model Portfolios utilized for a Client Account, based on changes to the Model Portfolio made by Zoe or the relevant third-party provider; (c) rebalance Client Accounts in accordance with Instructions received and accepted by Zoe; (d) otherwise implement instructions from the RIA received and accepted by Zoe. For the avoidance of doubt, Zoe is not recommending any Model Portfolio made available through the Platform for use by RIAs generally, or for any Client specifically. The selection of such Model Portfolios for a Client is the sole and exclusive responsibility of his or her RIA. Zoe Wealth Platform Wrap Fees In connection with their participation in the Program, the following fees (together, the "Wrap Fees") are assessed and, based on the arrangement with the RIA, charged to the Client or the RIA: ● ● a "Sub-Advisory Fee" based on the Fee Schedule below for Client Accounts for which Zoe provides Sub-Advisory Services, as described above; and a "Model Marketplace Fee" based on the Fee Schedule below for Client Accounts for which the RIA utilizes a Model Portfolio. The Sub-Advisory Fee is set forth in Zoe's TAMP Agreement with an RIA, but ranges in accordance with the Fee Schedule below. The Sub-Advisory Fee will be calculated based on the end of quarter balance of assets under management in Client Accounts for which Zoe provides sub-advisory services and billed quarterly, in arrears, unless agreed upon for a different schedule between Zoe and the RIA. Zoe will instruct the Custodian to deduct the applicable Sub-Advisory Fee from each Client Account. The Model Marketplace Fee will be based on the Zoe Financial, Inc. Model Marketplace Fee Schedule (available on our website at www.zoefinancial.com ) and calculated based on the end of quarter balance of assets under management in Client Accounts using Model Portfolios and billed quarterly in arrears unless agreed upon for a different schedule between Zoe and the RIA. Zoe will instruct the Custodian to deduct the applicable Model Marketplace Fee from each Client 8  Account. Any allocation to a Model Portfolio within a Custom Portfolio (as defined in Appendix C) will incur the applicable Model Marketplace Fee. The Model Marketplace Fee with respect to assets under management in a Custom Portfolio allocated to a Model Portfolio within a Client Account will be determined based on the allocation to Model Portfolio as a percentage of the Custom Portfolio as of the end of the quarter. To illustrate the foregoing, for assets in Client Accounts for which Zoe provides Sub-Advisory Services using Model Portfolios, the Advisory Firm will incur both of the foregoing fees, as applicable (Sub-Advisory Fee + Model Marketplace Fee). RIA Advisory Fees. Each Client's RIA will charge an advisory fee for the services it provides to the Client. The RIA's advisory fee is separate from, and in addition to, Zoe's Wrap Fees. The advisory fee charged by each Client's RIA varies and is described in the RIA's Form ADV Part 2A and the Client's investment management agreement with the RIA. Zoe does not set or control the advisory fees charged by RIAs. Where an RIA has agreed to pay Zoe's Wrap Fees on behalf of its Clients, the RIA's advisory fees may include Zoe's Wrap Fee. Clients should review the fees charged by their RIAs, which are outlined in each RIA's Form ADV Part 2A and their investment management agreements with their RIAs. Fee Schedule Type Fee Sub-Advisory Fee 0 – 50 bps (0.00% – 0.50%) Model Marketplace Fee 0 – 50 bps (0.00% – 0.50%) Zoe's Wrap Fees are based on the Client being sub-advised and being managed through Model Portfolios. Accordingly, Zoe receives additional compensation when your RIA recommends its sub-advisory services and the use of Model Portfolios made available through the Zoe Wealth Platform. Further, in addition to the Wrap Fees, Zoe also charges RIAs additional fees pursuant to the TAMP Agreement. These fees generally include asset-based fees based on the amount of the assets under management in Client Accounts of the RIA's Clients on the Zoe Wealth Platform. Accordingly, Zoe receives additional compensation when a Client's RIA recommends the Client contribute more additional funds and securities to his or her account. As set forth above, it is the responsibility of the RIA to gather sufficient information from the Client to evaluate the Client's financial situation, investment objectives, financial goals, tolerance for risk, and investment time horizon. The RIA is responsible for determining whether the Client's participation in the Program is appropriate for the Client, and for selecting the appropriate investment strategy. Certain RIAs may offer some or all of their Clients discounted fees based on the amount of assets an individual Client or the RIA has in the Program, the efficiencies gained by managing multiple Clients for the same RIA, and our relationship with the RIA. 9  The foregoing fees are generally not negotiable, although Zoe reserves the right to offer discounted fees, promotions, or waiver of fees under certain circumstances. Zoe may from time to time waive the service fees charged to the RIA, which may reduce advisory fees charged to a Client's account. Clients should carefully review all fees charged by Zoe, their RIAs, and any funds or ETFs in their Client Accounts to fully understand the total amount of fees that are paid. It is the Client's responsibility to verify the accuracy of the fees charged to your account. The fee Zoe collects will appear on statements Clients receive from the Custodian of their Client Accounts. The Custodian does not determine whether the fee has been properly calculated. For Client Accounts held at Schwab, Zoe's Wrap Fees and, where applicable, the RIA's advisory fees deducted by Zoe on the RIA's behalf, will appear on Schwab account statements as a single line item labeled 'Management Fee.' This amount may include Zoe's Sub-Advisory Fee, the Model Marketplace Fee, and the RIA's advisory fee. Additional Fees and Expenses RIAs may engage Zoe to deduct their advisory fees from Client Accounts on their behalf, in accordance with the terms of their investment management agreements with their Clients. In deducting an RIA's advisory fees, Zoe will rely on the schedule of advisory fees provided to Zoe, and Zoe will calculate and deduct the advisory fees from Client Accounts in accordance with such schedule. additional administrative charges In addition to advisory fees charged by RIAs, Clients may be responsible for additional fees in addition to the Wrap Fees, including but not limited to, fees embedded in the securities purchased on Client's behalf. For example, mutual funds and ETFs held in your account can incur fees or expenses, which may include and/or management and administrative fees, 12b-1 fees and related servicing or marketing expenses, sub-transfer agent fees, deferred sales charges and other fees or expenses. Please consult the applicable prospectus or statement of additional information relating to your investments for more information. When investing in mutual funds, certain Approved Custodians charge Zoe, Zoe Securities, or the Client an asset-based fee when Clients invest in certain funds and share classes. Zoe requires RIAs to select mutual funds that are available on the applicable Approved Custodian's platform. The availability of specific mutual funds and share classes may vary by Approved Custodian. In certain cases, you may incur transaction fees in addition to fees charged by the mutual fund. Clients may also be responsible for certain service fees relating to the Program and certain fees charged by Zoe Securities and the applicable Approved Custodian that are not part of Zoe's Wrap Fee. Zoe Securities' fees are described in the Zoe Securities Fee Schedule, available on Zoe's website at www.zoefinancial.com . In addition, the Wrap Fees do not cover fees associated with certain securities transactions in Clients' accounts, including: (a) dealer markups, markdowns or spreads charged on transactions in over-the-counter securities; (b) costs relating to trading in certain foreign securities; (c) brokerage commissions or other charges imposed by broker-dealers or entities other than the Custodian if and when trades are 10  cleared by another broker-dealer other than the applicable Approved Custodian; and (d) the charge to carry tax lot information on transferred mutual funds or other investment vehicles, postage and handling charges, returned check charges, transfer taxes, stock exchange fees or other fees mandated by law. In addition, the Wrap Fees do not cover certain custodial fees that may be charged for specific Client Account services, such as ACAT transfers, electronic fund and wire transfer charges, and for other optional services elected by Clients. Compensation for Recommending the Program RIAs that recommend the Program to their Clients receive advisory fees from those Clients for the services the RIAs provide. RIAs may earn higher advisory fee revenue by recommending the Program if it results in additional assets being placed on the Zoe Wealth Platform, because many RIAs charge asset-based fees. In addition, certain RIAs participating in the Zoe Advisor Network may receive client referrals from Zoe, which provides an additional financial incentive to participate in the Program. An RIA may therefore have a financial incentive to recommend the Program over other programs or services. Clients should discuss with their RIA whether there are other programs or services available that may be more appropriate for the Client's needs. Assets Under Management As of December 31, 2025, Zoe managed approximately $118,174,160 of discretionary and $165,299,031 of non-discretionary client assets in connection with its sub-advisory services through the Zoe Wealth Platform, across all Approved Custodians 11  Item 5: Account Requirements and Types of Clients Minimum Account Size Zoe currently does not impose any minimum or maximum account size or value requirements. However, Zoe reserves the right to impose a minimum or maximum account size or value in the future at its discretion. Individual Approved Custodians may impose their own minimum account sizes or requirements, which may vary by Custodian. Types of Clients Zoe makes the Program available to RIAs that provide services to individuals and high net-worth individuals, corporations and other business entities, trusts, foundations, and endowments. This Program is not available to qualified retirement plan Clients including 401(k), 457, and 403(b) plans. Funding Your Account Clients may fund their Client Accounts by cash transfers using ACH (Automated Clearing House), checks, or wires sent to the applicable Approved Custodian directly. Funding methods and procedures may vary by Approved Custodian. Clients should consult with their RIAs to fund their Client Accounts. Withdrawal from the Program Clients may terminate their Program at any time by providing written notice to Zoe or by contacting their RIA. We require that you have an RIA to participate in the Program. If your RIA leaves the Program and you are unable to find another RIA participating in the Program, Zoe has the right to terminate your participation in the Program. If an Approved Custodian is removed from the Platform, Zoe will work with affected RIAs to facilitate an orderly transition of Client Accounts to another Approved Custodian. See Item 9 for additional information regarding custodian governance. 12  Item 6: Portfolio Manager Selection and Evaluation Methods of Analysis for Sub-Advisory Services In connection with its sub-advisory services, Zoe conducts initial and ongoing due diligence on Model Portfolios and third-party providers made available through the Zoe Wealth Platform. The diligence process includes, but is not limited to, reviewing that each third-party provider: (1) is registered as an investment adviser or is otherwise appropriately qualified to manage the applicable strategy; (2) has an investment process and philosophy that is clearly defined and consistently applied; and (3) has no material disciplinary or regulatory disclosures. In addition, Zoe reviews available information about each provider and its Model Portfolios, including the provider's Form ADV, historical performance data, investment strategy documentation, fee structure, and the types of securities used within the model. For Model Portfolios managed by Zoe, the investment process is based on a review of factors that may include asset class fundamentals, portfolio diversification, risk characteristics, cost efficiency of underlying securities, and the overall alignment of the model with its stated investment objective. Zoe may also conduct due diligence calls with third-party providers to discuss their investment approach, portfolio construction, and any changes to their strategies. On an ongoing basis, Zoe monitors Model Portfolios available on the platform for material changes, including changes to the provider's investment strategy, key personnel, regulatory status, or fee structure. Zoe may add or remove Model Portfolios from the platform based on these reviews. For sub-advised accounts, Zoe implements trades to maintain the target allocations of the applicable Model Portfolio or Custom Model. This includes buying and selling securities to reflect changes made by Zoe or the relevant third-party provider to a Model Portfolio, rebalancing accounts to bring them back in line with target allocations, and processing liquidation or transfer requests. Zoe monitors sub-advised accounts to help ensure that trades are executed in accordance with the applicable model and that accounts remain aligned with their target allocations. Zoe does not provide individualized investment advice to Clients through its sub-advisory services. Investment recommendations, suitability determinations, and the selection of strategies remain the responsibility of each Client's RIA. Zoe does not recommend any specific Model Portfolio to any RIA or Client. The selection of a Model Portfolio for a Client is the sole and exclusive responsibility of the Client's RIA. Wrap Fee and Non-Wrap Accounts Zoe provides sub-advisory services through both the wrap structure described in this Brochure and a non-wrap structure described in Zoe's separate Wealth Platform Disclosure Brochure. Zoe manages sub-advised accounts in the same manner regardless of whether the account is in the wrap or non-wrap structure. The investment process, model maintenance, rebalancing, 13  and trade execution procedures are the same for both structures. The primary difference between the two structures is the fee arrangement: under the wrap structure, Zoe's Sub-Advisory Fee and Model Marketplace Fee cover certain transaction and custody costs that are charged separately under the non-wrap structure. Zoe receives Sub-Advisory Fees and Model Marketplace Fees for the sub-advisory services it provides under the Program. Portfolio Manager Selection and Review Zoe selects and reviews third-party Model Portfolio providers based on factors including investment philosophy, historical performance, risk characteristics, fee structure, and operational capabilities. Zoe periodically reviews the Model Portfolios available on the platform and may add or remove portfolios based on these factors. Zoe's criteria for removing a Model Portfolio or third-party provider from the platform include material changes to the provider's investment strategy, deterioration in performance relative to the model's stated objective, regulatory or disciplinary issues, or operational concerns. Because the selection of a specific Model Portfolio for a Client is the sole responsibility of the Client's RIA, Zoe does not recommend the replacement of a Model Portfolio for any particular Client. If Zoe removes a Model Portfolio from the platform, it will notify affected RIAs, who are responsible for selecting an alternative strategy for their Clients. Portfolio Manager Performance Zoe does not calculate or publish standardized performance figures for Model Portfolios. Performance information provided by third-party Model Portfolio providers has not been verified by Zoe or any third party and may not be calculated on a uniform and consistent basis. Clients and RIAs should not rely solely on historical performance data when evaluating a Model Portfolio. Related Persons as Portfolio Managers Zoe manages certain Model Portfolios made available on the Zoe Wealth Platform. This creates a conflict of interest because Zoe earns fees from sub-advisory services and has an incentive to make its own Model Portfolios available on the platform. Zoe addresses this conflict by making the selection of any Model Portfolio the sole responsibility of the Client's RIA, and by making both Zoe-managed and third-party-managed Model Portfolios available on the platform. Zoe-managed Model Portfolios are subject to the same ongoing monitoring as third-party Model Portfolios. Risk of Loss The description contained herein is an overview of the risks entailed in our Program and generally trading in, but not limited to, single stock securities, ETFs, mutual funds and/or money market funds. This list is not intended to be complete. All investing involves a risk of loss. 14  Investing in securities is inherently risky. An investment in money market funds, mutual funds, exchange-traded funds, or stocks could lose money. Zoe and the RIAs cannot give any guarantee that they will achieve their investment objectives or that any Client will receive a return of its investment. Although money market funds are considered low risk, they are affected by other types of risk, mainly interest-rate risk and inflation risk. The underlying value of the instruments within the money market fund may change depending on the direction of interest rates. No Guarantees. The value of your investment could decline and be worth less than the principal initially invested. And while a money market fund seeks a stable share price, its yield fluctuates. In addition, mutual funds are not insured or guaranteed by an agency of the U.S. government. Bond funds, unlike purchasing a bond directly, will not repay the principal at a set point in time. Risks Specific to Model Portfolios and Sub-Advisory Services In addition to the general risks described above, Clients whose accounts are managed through Model Portfolios or Custom Models on the Zoe Wealth Platform should be aware of the following risks: Model Portfolio Risk. Model Portfolios are designed to meet general investment objectives and are not tailored to the specific financial situation, risk tolerance, or investment goals of any individual Client. A Model Portfolio that is appropriate for one Client may not be appropriate for another. It is the responsibility of each Client's RIA to determine whether a particular Model Portfolio is suitable for the Client. Rebalancing Risk. Zoe periodically rebalances sub-advised accounts to align with target allocations. Rebalancing involves buying and selling securities, which may result in taxable events. Market conditions at the time of rebalancing may also affect the prices at which securities are bought or sold. Third-Party Provider Risk. Certain Model Portfolios are managed by third-party providers. Zoe does not control the investment decisions made by these providers. A third-party provider may change its investment strategy, experience personnel changes, or encounter operational issues that could affect the performance of its Model Portfolios. Zoe monitors third-party providers but cannot guarantee their continued performance or adherence to their stated strategies. Limited Customization. Sub-advised accounts are managed in accordance with the applicable Model Portfolio or Custom Model. Zoe generally does not make individualized investment decisions for specific Client Accounts within a model. Clients who require a high degree of customization should discuss this need with their RIA. Trading and Execution Risk. Zoe generally submits trade instructions to the Custodian at or before 3:00 p.m. Eastern Time. Securities prices may change between the time a model change is determined and the time trades are executed. In volatile markets, these price changes may be significant. 15  Performance-Based Fees and Side-by-Side Management management agreement for additional information regarding Performance-based fees are based on a share of capital gains on, or capital appreciation of, Client assets. Your RIA may charge performance-based fees. An advisor charging performance fees to some accounts faces a variety of conflicts because the advisor can potentially receive greater fees from its accounts having a performance-based compensation structure than from those accounts it charges a fee unrelated to performance (e.g., an asset-based fee). As a result, the RIA may have an incentive to direct the best investment approach, or to allocate or sequence trades in favor of the account that pays a performance fee. You should consult your investment any performance-based fees your RIA may charge. Risks Specific to Multi-Custodial Operations Data Discrepancies. Client account data is sourced from multiple Approved Custodians and may be processed through third-party aggregation services. Data from different custodians may arrive at different times, in different formats, and may contain errors or delays. Zoe uses commercially reasonable efforts to reconcile data but does not guarantee third-party data accuracy. Execution Differences. Execution quality, settlement cycles, available instruments, and operational procedures may differ by Approved Custodian. The same trade at different custodians may produce different results. Custodian Availability. Zoe does not guarantee the continued availability of any Approved Custodian. Custodians may experience outages or be removed from the Platform. Removal could require account transitions involving temporary disruption, tax consequences, or costs. Zoe provides ninety (90) days' notice before removing an Approved Custodian. Platform Service Provider Risk. Zoe uses third-party providers for data aggregation, rebalancing, and trade routing across custodians. A disruption at a provider could affect data, execution, or reporting across all Approved Custodians. Zoe does not charge performance-based fees. 16  Item 7: Client Information Provided to Advisors The RIAs remain responsible for managing Client accounts in accordance with incorporating your individual information or investment goals and objectives and have a direct relationship with Clients. It remains the responsibility of each Client to advise his or her RIA if there is ever any change in their financial situation or investment objectives. Clients participating in the Program generally grant their RIAs the authority to provide certain non-public information to Zoe in order to administer their accounts. This information is communicated as necessary in order for Zoe to provide Program services. In the multi-custodial environment, Client information may be transmitted to and processed by Zoe, the applicable Approved Custodian, and Platform Service Providers in connection with account administration, trade execution, performance reporting, and billing. See Item 9 for information regarding Zoe's data privacy practices. 17  Item 8: Client Contact with the Advisor Any questions regarding the management of your account should be directed to a Client's RIA. Zoe may answer technical questions regarding your ability to access the Zoe Wealth Platform. There are no restrictions on a Client's ability to contact and consult with their RIA. 18  Item 9: Additional Information Disciplinary Information Zoe has no criminal or civil actions or administrative or self-regulatory organization proceedings to report in connection with this Item. Other Financial Industry Affiliations As discussed above, Zoe's affiliate, Zoe Securities, is an SEC-registered broker-dealer and member of FINRA. Zoe Securities provides introducing brokerage services to Clients whose accounts are held at Approved Custodians supporting an introducing broker-dealer relationship. As of the date of this Brochure, Zoe Securities introduces Client Accounts solely to Apex for clearance, execution and settlement on a fully disclosed basis. Zoe Securities does not introduce accounts to, route trades for, or have any supervisory or compliance role with respect to Client Accounts held at Schwab or other Approved Custodians. Zoe Securities will earn revenue in the form of payment for order flow, interest on fully paid securities lending activities, and may earn a portion of the interest generated on Client cash balances held with Apex. The receipt of revenue directly associated with Client transactions raises a conflict of interest in that Zoe Securities has an incentive to encourage trading. Zoe Securities, and Zoe, address this conflict by servicing managed accounts whereby Zoe Securities does not have discretion with respect to Client transactions. Further, fully paid lending activities are only provided (and thus Zoe Securities only receives earned interest proceeds) when a Client specifically opts into the program. In addition, certain supervised persons of Zoe are registered as representatives of Zoe Securities. Zoe Securities provides certain services to clients of the Zoe Wealth Platform. As discussed above, Zoe operates a referral program pursuant to which it refers Users to RIAs that participate in the Zoe Advisor Network. Certain of such RIAs participate in the Zoe Wealth Platform. For information about Zoe's online referral program, please refer to Zoe's separate Disclosure Brochure, which is available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . Zoe also has a separate solicitor agreement with Ethic, Inc. ("Ethic") pursuant to which Zoe refers RIAs to Ethic for portfolio management of client assets. Zoe is compensated based on a percentage of assets under management for those client accounts managed by Ethic. A conflict of interest exists, because Zoe has financial incentive to promote Ethic to RIAs on the Zoe Wealth Platform. Zoe does not recommend specific third-party providers, including Ethic, to RIAs for their Clients. A principal of Zoe Financial serves as a non-compensated member of the Advisory Board of Diversified LLC, a financial services firm. Zoe Financial has identified this relationship as a conflict of interest given that both firms operate in the financial services industry. Zoe addresses this conflict by ensuring that the advisory board role does not influence Zoe Financial's investment recommendations, client account management, or selection of service providers. 19  Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. each hold direct minority ownership interests in Zoe. Certain registered investment advisers, including Creative Planning, LLC and affiliates of CapFinancial, LLC, Mariner, LLC dba Mariner Wealth Advisors, Sequoia Financial Advisors, LLC, Perigon Wealth Management, LLC, and Falcon Wealth Planning, Inc., hold indirect minority interests in Zoe. These registered investment advisers and their affiliates also participate in the Zoe Advisor Network. Zoe has an incentive to prefer Clients of these entities or their affiliates arising from their indirect ownership in Zoe. Zoe has policies and procedures in place to help ensure Clients of these entities are not given preferential treatment. Code of Ethics, Personal Trading We have adopted a Code of Ethics ("Code") pursuant to Rule 204A-1 under the Investment Advisers Act of 1940. The Code establishes rules of conduct for all of our partners, officers, directors (or other person occupying a similar status or performing similar functions), or employee of Zoe, or other person who provides investment advice on behalf of Zoe and is subject to the supervision and control of Zoe ("Supervised Persons") and is designed to, among other things, govern personal securities trading activities in the accounts of our employees. The Code contains general ethical principles and personal securities reporting provisions for our employees. In summary, the Code prohibits Supervised Persons from taking inappropriate advantage of their positions and the access to information concerning the investments or our investment intentions for our Clients, or our ability to influence such investment intentions, for personal gain or in a manner detrimental to the interests of our Clients. A copy of the Code is available upon request by contacting us at compliance@zoefin.com . We and our Supervised Persons occasionally buy or sell securities identical to those held in Client Accounts. It is our express policy that no person employed by us may profit at the expense of our Clients or compete with our Clients. To address conflicts arising from personal trading, certain Supervised Persons who have access to nonpublic information about Client transactions ("Access Persons") are required to report their personal securities holdings and transactions to Zoe's Chief Compliance Officer on a periodic basis. Access Persons must also obtain pre-approval before acquiring securities in initial public offerings or limited offerings. Each Access Person's initial and annual holdings reports are reviewed by Zoe's Chief Compliance Officer. Any Supervised Person not in observance of the Code will be subject to disciplinary action, and possible termination. Review of Accounts It is you or your RIA's responsibility to review your account. Please review your RIA's Form ADV Part 2A to understand how and when the RIA monitors and reviews your account. For Client Accounts for which Zoe provides sub-advisory services, Zoe monitors those accounts on an ongoing basis to help ensure they remain aligned with the applicable Model Portfolio or Custom Model. This monitoring includes reviewing that trades have been executed in accordance with model instructions, that accounts have been rebalanced as directed, and that 20  any model changes have been properly implemented. Zoe does not conduct individualized reviews of Client Accounts for suitability or performance; those reviews are the responsibility of the Client's RIA. Clients will receive account statements from their Custodian at least monthly, reflecting all transactions and holdings in their Client Accounts. Client Referrals and Other Compensation As discussed above, Zoe operates a referral program pursuant to which it refers Users to RIAs that participate in the Zoe Advisor Network. Certain of such RIAs participate in the Zoe Wealth Platform. For information about Zoe's online referral program, including conflicts of interest associated with referrals made and received in connection with the referral program, please refer to Zoe's separate Disclosure Brochure, which is available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . As discussed above, Zoe also has a separate solicitor agreement with Ethic, Inc. Zoe refers other RIAs to Ethic, Inc. for portfolio management of client assets. Zoe is compensated based on a percentage of assets under management for those client accounts managed by Ethic, Inc. A conflict of interest exists, because Zoe has financial incentive to promote Ethic, Inc., to RIAs on its platform. Zoe does not recommend specific third-party providers, including Ethic, to RIAs for their Clients. and billing. Zoe's operational Multi-Custodial Conflicts. The Platform supports multiple Approved Custodians and uses third-party service providers for data aggregation, rebalancing, trade routing, performance reporting, costs, revenue arrangements, or commercial relationships may differ among Approved Custodians and service providers, creating potential conflicts. To mitigate: (i) the RIA or Client selects the Approved Custodian; (ii) Zoe maintains substantially uniform fee structures across custodians; and (iii) Zoe does not recommend, endorse, or evaluate any Approved Custodian Custody Zoe has authority to instruct Custodians to deduct its fees and, in certain cases, the fees of Client RIAs directly from Client Accounts. Under SEC Rule 206(4)-2, this fee deduction authority alone does not constitute a form of custody. Zoe complies with the conditions of Rule 206(4)-2(b)(3): concurrently with each fee deduction, Zoe provides Clients with an itemized invoice showing the fee amount and the calculation methodology, and each qualified custodian sends account statements to Clients at least quarterly. Client assets are maintained at independent, qualified custodians, which include Apex Clearing Corporation and Charles Schwab & Co., Inc. Clients should carefully review their custodian account statements for accuracy and compare them against the itemized fee invoices provided by Zoe. 21  Proxy Voting Zoe does not have authority to vote proxies for securities held in Client Accounts. Clients will receive their proxies or other solicitations directly from their Custodian or a transfer agent. Clients are responsible for voting their own proxies. Clients who have questions about a particular proxy solicitation should contact their RIA. Financial Information Zoe does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, Zoe is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Zoe has no disclosures pursuant to this Item. Zoe has not been the subject of a bankruptcy petition at any time during the past ten years. 22 

Zoe Financial, Inc. Wealth Platform Disclosure Brochure Zoe Financial, Inc. c/o Studio by Tishman Speyer 666 Third Ave, 6th Floor New York, NY, 10017 (646) 680-9244 www.zoefinancial.com April 24, 2026 This brochure (the "Brochure") provides information about the qualifications and business practices of Zoe Financial, Inc. ("Zoe," "we," "us," or "our"). If you have any questions about the contents of the Brochure, please contact us at 646-680-9244 or compliance@zoefin.com . The information in the Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. information about Zoe also is available on the SEC's website at Additional www.adviserinfo.sec.gov . Registration as an investment adviser does not imply a certain level of skill or training.  Item 2: Material Changes This Item discusses material changes to this Brochure since the last annual amendment dated April 20, 2026. Zoe has the following changes to disclose in relation to this Item: ● ● ● ● ● ● ● ● ● ● ● ● ● introducing solely ● Zoe has added a description of its methods of analysis and investment strategies for sub-advisory services, including its process for selecting and reviewing Model Portfolios and third-party providers, in Item 8. Zoe has added risk disclosures specific to Model Portfolios and sub-advisory services in Item 8. Zoe has added disclosure regarding the amount of client assets managed on a discretionary and non-discretionary basis in Item 4. Zoe has clarified that no individual entity other than its principal owner holds 25% or more of Zoe in Item 4. Zoe has added a statement regarding whether Clients may impose investment restrictions for sub-advised accounts in Item 4. Zoe has expanded its description of account review practices for sub-advised accounts in Item 13. Zoe has added an explicit bankruptcy disclosure in Item 18. Zoe has added disclosure regarding a principal's advisory board role at Diversified LLC, an independent financial services firm, and the associated conflict of interest. See item 10. Zoe has updated its proxy voting disclosure to clarify that Zoe does not have authority to vote proxies for securities held in Client Accounts. Clients receive their proxies directly from their Custodian or a transfer agent and are responsible for voting their own proxies in Item 17. Zoe has expanded its brokerage practices disclosures, including directed brokerage and trade aggregation, in Item 12. Zoe has expanded its disclosure of the scope and limitations of its discretionary authority in Item 16. Zoe expanded the Platform to support multiple qualified custodians ("Approved Custodians"), currently including Apex Clearing Corporation and Charles Schwab & Co., Inc. Additional custodians may be added. Zoe does not recommend any Approved Custodian; selection is the RIA's responsibility. Client assets are held at the applicable Approved Custodian; Zoe does not have custody of Client funds or securities, and Zoe's authority to instruct Custodians to deduct advisory fees from Client Accounts does not, standing alone, constitute custody under SEC Rule 206(4)-2. See Items 4, 12, and 15. Zoe updated the role of its affiliated broker-dealer, Zoe Securities, LLC, to clarify it acts for accounts at custodians supporting that broker-dealer as relationship (currently Apex). See Items 4 and 10. Zoe added multi-custodial risk disclosures in Item 8 and multi-custodial conflicts disclosure in Item 10. 2  ● Zoe has expanded its ownership disclosure in Item 4 and Item 10 to identify Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. as holders of direct minority ownership interests in Zoe. You may request a copy of our current Wealth Platform Disclosure Brochure, free of charge, by contacting us at (646) 680-9244 or compliance@zoefin.com , or by visiting our website at www.zoefinancial.com . Additional information about Zoe is available through the SEC's Investment Adviser Public Disclosure website at https://adviserinfo.sec.gov/. 3  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Item 11: Code of Ethics, Participation or Interest in Client Trans. and Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities (Proxy Voting) Item 18: Financial Information 1 2 4 5 8 12 13 14 18 19 21 22 23 25 26 27 28 29 4  Item 4: Advisory Business Zoe Financial, Inc. ("Zoe," "we," "us," or "our") is a Corporation organized in the State of Delaware. Zoe was formed in June 2016 and its principal owner is Andres Garcia. No other individual or entity holds 25% or more of Zoe. Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. each hold minority ownership interests in Zoe. Certain registered investment advisers, including Creative Planning, LLC and affiliates of CapFinancial, LLC, Mariner, LLC dba Mariner Wealth Advisors, Sequoia Financial Advisors, LLC, Perigon Wealth Management, LLC, and Falcon Wealth Planning, Inc., hold indirect minority interests in Zoe These relationships are further described in Item 10. The Brochure describes Zoe Financial, Inc. Wealth Platform (the "Platform" or the "Zoe Wealth Platform"), which is Zoe's turnkey asset management program, pursuant to which Zoe provides reporting, administrative, sub-advisory, and other support services to third-party registered investment advisers ("RIAs") on behalf of their underlying advisory Clients ("Clients"). For information about Zoe's online referral program pursuant to which Zoe refers to users of our website at www.zoefinancial.com ("Users") to RIAs that participate in the "Zoe Advisor Network," please refer to Zoe's separate Disclosure Brochure for the Zoe Advisor Network, which is available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . goals and objectives; provide any The Platform is a service pursuant to which Zoe provides administrative, management, sub-advisory, and support services relating to the administration of Client Accounts (as defined below) managed by the RIAs that offer investment advice to Clients and manage assets of Clients through the Zoe Wealth Platform. RIAs engage Zoe for the provision of such services on behalf of their Clients through a Turnkey Asset Management Agreement between Zoe and the RIA (each a "TAMP Agreement"). The Services provided to each RIA vary in accordance with their TAMP Agreements with Zoe, however, except with respect to Sub-Advisory Services provided to Clients, as more fully described below, neither Zoe nor Zoe Securities act as an investment adviser to Clients; possess knowledge of any individual Client's information or investment Client personalized investment advice; recommend any securities, transactions, or investment strategies to Clients; solicit orders; make discretionary trades; or provide legal or tax advice. Zoe provides the Platform under a wrap and non-wrap structure. When provided pursuant to a wrap structure, Clients are provided advisory and other services with no additional transaction costs. This Brochure describes the non-wrap structure. For additional information on the wrap structure, please refer to Zoe's separate Wrap Brochure for the Zoe Wealth Platform, which is available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . To receive services through the Platform, a Client will enter into an advisory agreement with his or her RIA that outlines the services to be performed by the RIA, the authority of the RIA and/or the Client over transactions effected for the Client (including the authority for the RIA to engage Zoe on behalf of Client to perform the services pursuant to the TAMP Agreement), the compensation to be paid by the Client to the RIA. A Client will open a custodial account ("Client 5  Account") with one or more qualified custodians supported by the Platform (each, an "Approved Custodian"), as designated by the Client's RIA or the Client. As of the date of this Brochure, the Approved Custodians include Apex Clearing Corporation ("Apex") and Charles Schwab & Co., Inc. ("Schwab"). Zoe may add or remove Approved Custodians from time to time; a current list is maintained on the Platform and available upon request. Zoe is not affiliated with any Approved Custodian and does not recommend, endorse, or evaluate any Approved Custodian for RIAs or their Clients. The selection of the Approved Custodian for each Client Account is the sole responsibility of the RIA or the Client. Account opening procedures, supported account types, available instruments, and custodial fees may vary by Approved Custodian. Except where Clients have a third-party broker, Clients whose accounts are held at Approved Custodians that support an introducing broker-dealer relationship will generally become customers of Zoe's affiliated introducing broker, Zoe Securities, LLC ("Zoe Securities"), an SEC-registered broker-dealer and member of FINRA. As of the date of this Brochure, Zoe Securities introduces Client Accounts solely to Apex on a fully disclosed basis. Zoe Securities does not introduce accounts to, route trades for, or have any role with respect to Client Accounts held at Schwab or other Approved Custodians for which a different execution method is used. It is the responsibility of the RIA to gather sufficient information from the Client to evaluate the Client's financial situation, investment objectives, financial goals, tolerance for risk, and investment time horizon. Because the management of a Client's investments is based on the Client's financial circumstances, it is important that the Client provides complete and accurate information to the Client's RIA. The RIA is also responsible for determining whether the Client's participation in the Platform is appropriate for the Client, and for selecting the appropriate investment strategy. Managed Account Program RIAs are responsible for assisting Clients in selecting an investment strategy and completing a suitability review. Pursuant to a Client's investment management agreement with a Client's RIA, the RIA has discretionary authority to buy, sell, or otherwise effect transactions in stocks, options, bonds, mutual funds, money market funds, exchange traded funds ("ETFs"), and any other securities in the Client's Account. RIAs will submit trade instructions directly to the Custodian for execution. RIAs also may grant Zoe the authority to submit trades per their instructions to the Custodian for implementation. This authorization may also include the ability to rebalance or reallocate the account, in which case Zoe will do so in accordance with the RIA's pre-determined investment criteria for the Client. Except where Zoe has been engaged as sub-advisor, as described more fully below, Zoe is not responsible for providing investment advice to any RIA's Client by virtue of its authority to submit trades and/or rebalance a Client's account in accordance with the RIA's pre-determined investment criteria. A Client's RIA will manage minimum cash in the Client Account and can also define the minimum cash percentage as rebalancing account defaults in the Zoe Wealth Platform. All stock and ETF dividends will be paid to cash unless requested otherwise at the time of onboarding. A 6  Client's RIA will have the ability to select the appropriate setting as part of the onboarding process. Client trades are sent to the Custodian. Each Custodian aggregates Client trades for execution, and allocates securities among Client Accounts on a pro-rata basis based on the average price of all securities that were block traded. Although stocks and ETFs may be traded throughout the day at market prices, the last trade instructions are generally sent to Custodian at or before 3pm Eastern Time, subject to exceptions at Zoe's discretion. Clients will receive notification of all transactions in his or her Client Account in the form of a monthly account statement provided by the Custodian each month. Clients will remain the owner of all securities held in their Client Accounts and have all ownership rights associated with such securities. Sub-Advisory Services RIAs may allocate their Client Accounts to Zoe for sub-advisory services. Such accounts shall include all Client Accounts for which an RIA utilizes its own custom model ("Custom Model") or a model portfolio made available through the platform and managed by Zoe or a third-party provider (each a "Model Portfolio") that the RIA engages Zoe to maintain on a limited discretionary basis, as well as sub-advised through the Zoe Wealth Platform. Such limited discretionary authority includes authority to: (a) buy and sell securities to maintain a Custom Model or Model Portfolio selected by RIA following receipt of a liquidation or transfer request from a Client (either directly or via RIA); (b) effect any changes to Model Portfolios utilized for a Client Account, based on changes to the Model Portfolio made by Zoe or the relevant third-party provider; (c) rebalance Client Accounts in accordance with Instructions received and accepted by Zoe; (d) otherwise implement instructions from the RIA received and accepted by Zoe. For the avoidance of doubt, Zoe is not recommending any Model Portfolio made available through the Platform for use by RIAs generally, or for any Client specifically. The selection of such Model Portfolios for a Client is the sole and exclusive responsibility of his or her RIA. Client Investment Restrictions Zoe does not accept individual Client investment restrictions in connection with its sub-advisory services. Sub-advised accounts are managed in accordance with the applicable Model Portfolio or Custom Model, and Zoe generally does not make individualized investment decisions for specific Client Accounts within a model. Clients who wish to impose restrictions on investing in certain securities or types of securities should discuss such restrictions with their RIA. The Platform permits RIAs to implement certain restrictions within the Platform. The RIA is responsible for determining whether such restrictions can be accommodated within the Platform. Assets Under Management 7  As of December 31, 2025, Zoe managed approximately $0 of discretionary and $0 of non-discretionary client assets in connection with sub-advisory services provided under the non-wrap structure of the Zoe Wealth Platform. Total sub-advisory assets managed by Zoe across the wrap and non-wrap structures were approximately $118,174,160 of discretionary and $165,299,031 of non-discretionary client assets. See Zoe's separate Wrap Brochure for assets managed under the wrap structure. Item 5: Fees and Compensation Zoe Wealth Platform Fees In connection with Zoe's services through the Platform, the following fees are assessed and, based on the arrangement with the RIA, charged to the Client or the RIA: ● ● a "Sub-Advisory Fee" based on the Fee Schedule below for Client Accounts for which Zoe provides Sub-Advisory Services, as described above; and a "Model Marketplace Fee" based on the Fee Schedule below for Client Accounts for which the RIA utilizes a Model Portfolio. The Sub-Advisory Fee is set forth in Zoe's TAMP Agreement with an RIA, but ranges in accordance with the Fee Schedule below. The Sub-Advisory Fee will be calculated based on the end of quarter balance of assets under management in Client Accounts for which Zoe provides sub-advisory services and billed quarterly, in arrears, unless agreed upon for a different schedule between Zoe and the RIA. Zoe will instruct the Custodian to deduct the applicable Sub-Advisory Fee from each Client Account. The Model Marketplace Fee will be based on the Zoe Financial, Inc. Model Marketplace Fee Schedule (available on our website at www.zoefinancial.com ) and calculated based on the end of quarter balance of assets under management in Client Accounts using Model Portfolios and billed quarterly in arrears unless agreed upon for a different schedule between Zoe and the RIA. Zoe will instruct the Custodian to deduct the applicable Model Marketplace Fee from each Client Account. Any allocation to a Model Portfolio within a Custom Portfolio (as defined in Appendix C) will incur the applicable Model Marketplace Fee. The Model Marketplace Fee with respect to assets under management in a Custom Portfolio allocated to a Model Portfolio within a Client Account will be determined based on the allocation to Model Portfolio as a percentage of the Custom Portfolio as of the end of the quarter. To illustrate the foregoing, for assets in Client Accounts for which Zoe provides Sub-Advisory Services using Model Portfolios, the Advisory Firm will incur both of the foregoing fees, as applicable (Sub-Advisory Fee + Model Marketplace Fee). Fee Schedule Type Fee 8  Sub-Advisory Fee 0 – 50 bps (0.00% – 0.50%) Model Marketplace Fee 0 – 50 bps (0.00% – 0.50%) Zoe's Fees are based on the Client being sub-advised and being managed through Model Portfolios. Accordingly, Zoe receives additional compensation when your RIA recommends its sub-advisory services and the use of Model Portfolios made available through the Zoe Wealth Platform. Zoe also charges RIAs additional fees pursuant to the TAMP Agreement. These fees generally include asset-based fees based on the amount of the assets under management in Client Accounts of the RIA's Clients on the Zoe Wealth Platform. Accordingly, Zoe receives additional compensation when a Client's RIA recommends the Client contribute more additional funds and securities to his or her account. As set forth above, it is the responsibility of the RIA to gather sufficient information from the Client to evaluate the Client's financial situation, investment objectives, financial goals, tolerance for risk, and investment time horizon. The RIA is responsible for determining whether the Client's receipt of services through the Platform is appropriate for the Client, and for selecting the appropriate investment strategy. Certain RIAs may offer some or all of their Clients discounted fees based on the amount of assets an individual Client or the RIA has in the Platform, the efficiencies gained by managing multiple Clients for the same RIA, and our relationship with the RIA. The foregoing fees are generally not negotiable, although Zoe reserves the right to offer discounted fees, promotions, or waiver of fees under certain circumstances. Zoe may from time to time waive the service fees charged to the RIA, which may reduce advisory fees charged to a Client's account. For Referred Clients onboarded onto the Platform, certain Platform and Sub-Advisory Fees may be waived in accordance with the applicable referral agreement. Clients should carefully review all fees charged by Zoe, their RIAs, and any funds or ETFs in their Client Accounts to fully understand the total amount of fees that are paid. It is the Client's responsibility to verify the accuracy of the fees charged to your account. The fee Zoe collects will appear on statements Clients receive from the Custodian of their Client Accounts. The Custodian does not determine whether the fee has been properly calculated. For Client Accounts held at Schwab, Zoe's fees and, where applicable, the RIA's advisory fees deducted by Zoe on the RIA's behalf, will appear on Schwab account statements as a single line item labeled 'Management Fee.' This amount may include Zoe's Sub-Advisory Fee, the Model Marketplace Fee, and the RIA's advisory fee. Clients should compare this amount against the itemized fee invoices provided by Zoe to verify that fees have been properly calculated. Additional Fees and Expenses Each Client's RIA will charge an advisory fee for the services it provides to the Client. RIAs may engage Zoe to deduct their advisory fees from Client Accounts on their behalf, in accordance with the terms of their investment management agreements with their Clients. In deducting an 9  RIA's advisory fees, Zoe will rely on the schedule of advisory fees provided to Zoe, and Zoe will calculate and deduct the advisory fees from Client Accounts in accordance with such schedule. Clients should review the fees charged by their RIAs, which are outlined in each RIA's Form ADV Part 2A and their investment management agreements with their RIAs. additional administrative charges In addition to advisory fees charged by RIAs, Clients may be responsible for additional fees in addition to the Platform fees, including but not limited to, fees embedded in the securities purchased on Client's behalf. For example, mutual funds and ETFs held in your account can incur fees or expenses, which may include and/or management and administrative fees, 12b-1 fees and related servicing or marketing expenses, sub-transfer agent fees, deferred sales charges and other fees or expenses. Please consult the applicable prospectus or statement of additional information relating to your investments for more information. When investing in mutual funds, certain Approved Custodians charge Zoe, Zoe Securities, or the Client an asset-based fee when Clients invest in certain funds and share classes. Zoe requires RIAs to select mutual funds that are available on the applicable Approved Custodian's platform. The availability of specific mutual funds and share classes may vary by Approved Custodian. In certain cases, you may incur transaction fees in addition to fees charged by the mutual fund. Clients will also incur brokerage commissions and other transaction costs in connection with the non-wrap structure of the Platform. For additional information about brokerage practices and transaction costs, please see Item 12 of this Brochure. in the Zoe Securities Fee Schedule, available on Zoe's website Clients may also be responsible for certain service fees relating to the Platform and certain fees charged by Zoe Securities and the applicable Approved Custodian that are not part of Zoe's Platform fees. Such custodial fees may vary by Approved Custodian. . Zoe Securities' fees are described at www.zoefinancial.com . Zoe Securities earns revenue in the form of payment for order flow, interest on fully paid securities lending activities, and may earn a portion of the interest generated on Client cash balances held with Apex. The receipt of revenue directly associated with Client transactions raises a conflict of interest in that Zoe Securities has an incentive to encourage trading. For additional information about Zoe Securities and this conflict, please see Item 10 of this Brochure. In addition, the Platform fees do not cover fees associated with certain securities transactions in Clients' accounts, including: (a) transaction fees; (b) dealer markups, markdowns or spreads charged on transactions in over-the-counter securities; (c) costs relating to trading in certain foreign securities; (d) brokerage commissions or other charges imposed by broker-dealers or entities other than the Custodian if and when trades are cleared by another broker-dealer other than the applicable Approved Custodian; and (e) the charge to carry tax lot information on transferred mutual funds or other investment vehicles, postage and handling charges, returned check charges, transfer taxes, stock exchange fees or other fees mandated by law. In addition, the Platform fees do not cover certain custodial fees that may be charged for specific Client Account services, such as ACAT transfers, electronic fund and wire transfer charges, and for other optional services elected by Clients. 10  11  Performance-Based Fees and Side-By-Side 6: Item Management management agreement for additional information regarding Performance-based fees are based on a share of capital gains on, or capital appreciation of, Client assets. Your RIA may charge performance-based fees. An advisor charging performance fees to some accounts faces a variety of conflicts because the advisor can potentially receive greater fees from its accounts having a performance-based compensation structure than from those accounts that charge a fee unrelated to performance (e.g., an asset-based fee). As a result, the RIA may have an incentive to direct the best investment approach, or to allocate or sequence trades in favor of the account that pays a performance fee. You should consult your investment any performance-based fees your RIA may charge. Zoe does not charge performance-based fees. 12  Item 7: Types of Clients Minimum Account Size Zoe currently does not impose any minimum or maximum account size or value requirements. However, Zoe reserves the right to impose a minimum or maximum account size or value in the future at its discretion. Types of Clients Zoe makes the Platform available to RIAs that provide services to individuals and high net-worth individuals, corporations and other business entities, trusts, foundations, and endowments. This Platform is not available to qualified retirement plan Clients including 401(k), 457, and 403(b) plans. Funding Your Account Clients may fund their Client Accounts by cash transfers using ACH (Automated Clearing House), checks, or wires sent to the Custodian directly. Clients should consult with their RIAs to fund their Client Accounts. Withdrawal from the Platform Clients may terminate their relationship with the Platform at any time by providing written notice to Zoe or by contacting their RIA. We require that you have an RIA to participate in the Platform. If your RIA leaves the Platform and you are unable to find another RIA participating in the Platform, Zoe has the right to terminate your participation in the Platform. 13  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss Due Diligence on RIAs Many RIAs that participate in the Zoe Wealth Platform are also members of the Zoe Advisor Network, Zoe's online referral program described in Zoe's separate Disclosure Brochure for the Zoe Advisor Network. In connection with the referral program, Zoe conducts initial and ongoing due diligence on prospective RIAs and their investment adviser representatives ("IARs") participating in the Zoe Advisor Network. The diligence process includes, but is not limited to, reviewing that RIAs are: (1) financial planning centric; (2) have a number of IARs that possess certain advanced designations, such as the chartered financial analyst (CFA), Certified Financial Planner™ (CFP®), certified public accountant (CPA), and/or a graduate degree in business administration; and (3) have no material disciplinary disclosures. In addition, Zoe reviews the RIA's Form ADV Parts 1A and 2A and Form CRS, as well as any other relevant and available data such as websites and general news. Zoe may also conduct due diligence calls with RIAs to discuss any information it collects during its diligence process. Provided the RIA meets Zoe's criteria for participation in the Zoe Advisor Network, Zoe then reviews participating IARs' responses to its questionnaire, their CRD records, Form U4s and Form ADV Part 2Bs. On an annual basis, Zoe collects the annually updated Form ADV Part 2A (Disclosure Brochure) of RIAs participating in the Zoe Advisor Network to review for any disciplinary issues and financial issues. Zoe cannot ensure that those RIAs will perform as desired, and we will have no control over the day-to-day operations of any recommended RIA. Zoe would not be aware of certain activities at its recommended RIAs, including, without limitation, an Adviser engaging in unreported risks, investment "style drift," or even regulatory breaches or fraud, unless identified in the annual due diligence discussed above. Additionally, Zoe cannot guarantee that a User's financial goals will be attained through its recommended RIAs. Past performance of any RIA is not a guarantee of its future returns. Investing in securities and other investments involve a risk of loss that each User should understand and be willing to bear. Users are reminded to discuss these risks with the RIA the User ultimately chooses to work with, if applicable. Users should obtain risk disclosures from any Adviser with which they conduct business and fully understand the risks of investing. Methods of Analysis for Sub-Advisory Services In connection with its sub-advisory services, Zoe conducts initial and ongoing due diligence on Model Portfolios and third-party providers made available through the Zoe Wealth Platform. The diligence process includes, but is not limited to, reviewing that each third-party provider: (1) is registered as an investment adviser or is otherwise appropriately qualified to manage the applicable strategy; (2) has an investment process and philosophy that is clearly defined and 14  consistently applied; and (3) has no material disciplinary or regulatory disclosures. In addition, Zoe reviews available information about each provider and its Model Portfolios, including the provider's Form ADV, historical performance data, investment strategy documentation, fee structure, and the types of securities used within the model. For Model Portfolios managed by Zoe, the investment process is based on a review of factors that may include asset class fundamentals, portfolio diversification, risk characteristics, cost efficiency of underlying securities, and the overall alignment of the model with its stated investment objective. Zoe may also conduct due diligence calls with third-party providers to discuss their investment approach, portfolio construction, and any changes to their strategies. On an ongoing basis, Zoe monitors Model Portfolios available on the platform for material changes, including changes to the provider's investment strategy, key personnel, regulatory status, or fee structure. Zoe may add or remove Model Portfolios from the platform based on these reviews. For sub-advised accounts, Zoe implements trades to maintain the target allocations of the applicable Model Portfolio or Custom Model. This includes buying and selling securities to reflect changes made by Zoe or the relevant third-party provider to a Model Portfolio, rebalancing accounts to bring them back in line with target allocations, and processing liquidation or transfer requests. Zoe monitors sub-advised accounts to help ensure that trades are executed in accordance with the applicable model and that accounts remain aligned with their target allocations. Zoe does not provide individualized investment advice to Clients through its sub-advisory Investment recommendations, suitability determinations, and the selection of services. strategies remain the responsibility of each Client's RIA. Zoe does not recommend any specific Model Portfolio to any RIA or Client. The selection of a Model Portfolio for a Client is the sole and exclusive responsibility of the Client's RIA. Zoe cannot ensure that any Model Portfolio will perform as expected, and past performance of any Model Portfolio is not a guarantee of future results. Risk of Loss The description contained herein is an overview of the risks associated with the Platform and generally trading in, but not limited to, single stock securities, ETFs, mutual funds and/or money market funds. This list is not intended to be complete. All investing involves a risk of loss. Investing in securities is inherently risky. An investment in money market funds, mutual funds, exchange-traded funds, or stocks could lose money. Zoe and the RIAs cannot give any guarantee that they will achieve their investment objectives or that any Client will receive a return of its investment. Although money market funds are considered low risk, they are affected by other types of risk, mainly interest-rate risk and inflation risk. The underlying value of the instruments within the money market fund may change depending on the direction of interest rates. 15  No Guarantees. The value of your investment could decline and be worth less than the principal initially invested. And while a money market fund seeks a stable share price, its yield fluctuates. In addition, mutual funds are not insured or guaranteed by an agency of the U.S. government. Bond funds, unlike purchasing a bond directly, will not repay the principal at a set point in time. Risks Specific to Model Portfolios and Sub-Advisory Services In addition to the general risks described above, Clients whose accounts are managed through Model Portfolios or Custom Models on the Zoe Wealth Platform should be aware of the following risks: Model Portfolio Risk. Model Portfolios are designed to meet general investment objectives and are not tailored to the specific financial situation, risk tolerance, or investment goals of any individual Client. A Model Portfolio that is appropriate for one Client may not be appropriate for another. It is the responsibility of each Client's RIA to determine whether a particular Model Portfolio is suitable for the Client. Rebalancing Risk. Zoe periodically rebalances sub-advised accounts to align with target allocations. Rebalancing involves buying and selling securities, which may result in taxable events. Market conditions at the time of rebalancing may also affect the prices at which securities are bought or sold. Third-Party Provider Risk. Certain Model Portfolios are managed by third-party providers. Zoe does not control the investment decisions made by these providers. A third-party provider may change its investment strategy, experience personnel changes, or encounter operational issues that could affect the performance of its Model Portfolios. Zoe monitors third-party providers but cannot guarantee their continued performance or adherence to their stated strategies. Limited Customization. Sub-advised accounts are managed in accordance with the applicable Model Portfolio or Custom Model. Zoe generally does not make individualized investment decisions for specific Client Accounts within a model. Clients who require a high degree of customization should discuss this need with their RIA. Trading and Execution Risk. Zoe generally submits trade instructions to the Custodian at or before 3:00 p.m. Eastern Time. Securities prices may change between the time a model change is determined and the time trades are executed. In volatile markets, these price changes may be significant. Risks Specific to Multi-Custodial Operations Data Discrepancies. Client account data is sourced from multiple Approved Custodians and may be processed through third-party aggregation services. Data from different custodians may arrive at different times, in different formats, and may contain errors or delays. Zoe uses commercially reasonable efforts to reconcile data but does not guarantee third-party data accuracy. 16  Execution Differences. Execution quality, settlement cycles, available instruments, and operational procedures may differ by Approved Custodian. The same trade at different custodians may produce different results. Custodian Availability. Zoe does not guarantee the continued availability of any Approved Custodian. Custodians may experience outages or be removed from the Platform. Removal could require account transitions involving temporary disruption, tax consequences, or costs. Zoe provides ninety (90) days' notice before removing an Approved Custodian. Platform Service Provider Risk. Zoe uses third-party providers for data aggregation, rebalancing, and trade routing across custodians. A disruption at a provider could affect data, execution, or reporting across all Approved Custodians. 17  Item 9: Disciplinary Information Zoe has no criminal or civil actions or administrative or self-regulatory organization proceedings to report in connection with this Item. 18  10: Other Financial Industry Activities and Item Affiliations As discussed above, Zoe's affiliate, Zoe Securities, is an SEC-registered broker-dealer and member of FINRA. Zoe Securities provides introducing brokerage services to Clients whose accounts are held at Approved Custodians supporting an introducing broker-dealer relationship. As of the date of this Brochure, Zoe Securities introduces Client Accounts solely to Apex for clearance, execution and settlement on a fully disclosed basis. Zoe Securities does not introduce accounts to, route trades for, or have any supervisory or compliance role with respect Zoe Securities will earn to Client Accounts held at Schwab or other Approved Custodians. revenue in the form of payment for order flow, interest on fully paid securities lending activities, and may earn a portion of the interest generated on Client cash balances held with Apex. The receipt of revenue directly associated with Client transactions raises a conflict of interest in that Zoe Securities has an incentive to encourage trading. Zoe Securities, and Zoe, address this conflict by servicing managed accounts whereby Zoe Securities does not have discretion with respect to Client transactions. Further, fully paid lending activities are only provided (and thus Zoe Securities only receives earned interest proceeds) when a Client specifically opts into the program. In addition, certain supervised persons of Zoe are registered as representatives of Zoe Securities. Zoe Securities provides certain services to clients of the Zoe Wealth Platform. Neither Zoe nor its supervised persons are registered as, or have pending applications to become, a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. As discussed above, Zoe operates a referral program pursuant to which it refers Users to RIAs that participate in the Zoe Advisor Network. Certain of such RIAs participate in the Zoe Wealth Platform. For information about Zoe's online referral program, please refer to Zoe's separate Disclosure Brochure, which is available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . Zoe also has a separate solicitor agreement with Ethic, Inc. ("Ethic") pursuant to which Zoe refers RIAs to Ethic for portfolio management of client assets. Zoe is compensated based on a percentage of assets under management for those Client Accounts managed by Ethic. A conflict of interest exists, because Zoe has financial incentive to promote Ethic to RIAs on the Zoe Wealth Platform. Zoe does not recommend specific third-party providers, including Ethic, to RIAs for their Clients. A principal of Zoe Financial serves as a non-compensated member of the Advisory Board of Diversified LLC, a financial services firm. Zoe Financial has identified this relationship as a conflict of interest given that both firms operate in the financial services industry. Zoe addresses this conflict by ensuring that the advisory board role does not influence Zoe Financial's investment recommendations, client account management, or selection of service providers. 19  Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. each hold direct minority ownership interests in Zoe. Certain registered investment advisers, including Creative Planning, LLC and affiliates of CapFinancial, LLC, Mariner, LLC dba Mariner Wealth Advisors, Sequoia Financial Advisors, LLC, Perigon Wealth Management, LLC, and Falcon Wealth Planning, Inc., hold indirect minority interests in Zoe. These registered investment advisers and their affiliates also participate in the Zoe Advisor Network. Zoe has an incentive to prefer Clients of these entities or their affiliates arising from their indirect ownership in Zoe. Zoe has policies and procedures in place to help ensure Clients of these entities are not given preferential treatment. Multi-Custodial Conflicts. The Platform supports multiple Approved Custodians and uses third-party Platform Service Providers for data aggregation, rebalancing, trade routing, performance reporting, and billing. Zoe's operational costs, revenue arrangements, or commercial relationships may differ among Approved Custodians and Platform Service Providers, creating potential conflicts. To mitigate: (i) the RIA or Client selects the Approved Custodian; (ii) Zoe maintains substantially uniform fee structures across custodians; and (iii) Zoe does not recommend, endorse, or evaluate any Approved Custodian. 20  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We have adopted a Code of Ethics ("Code") pursuant to Rule 204A-1 under the Investment Advisers Act of 1940. The Code establishes rules of conduct for all of our partners, officers, directors (or other person occupying a similar status or performing similar functions), or employee of Zoe, or other person who provides investment advice on behalf of Zoe and is subject to the supervision and control of Zoe ("Supervised Persons") and is designed to, among other things, govern personal securities trading activities in the accounts of our employees. The Code contains general ethical principles and personal securities reporting provisions for our employees. In summary, the Code prohibits Supervised Persons from taking inappropriate advantage of their positions and the access to information concerning the investments or our investment intentions for our Clients, or our ability to influence such investment intentions, for personal gain or in a manner detrimental to the interests of our Clients. A copy of the Code is available upon request by contacting us at compliance@zoefin.com . We and our Supervised Persons occasionally buy or sell securities identical to those held in Client Accounts. It is our express policy that any person employed by us is prohibited from profiting at the expense of our Clients and from competing with our Clients. To address conflicts arising from personal trading, certain Supervised Persons who have access to nonpublic information about Client transactions ("Access Persons") are required to report their personal securities holdings and transactions to Zoe's Chief Compliance Officer on a periodic basis. Access Persons must also obtain pre-approval before acquiring securities in initial public offerings or limited offerings. These reporting and pre-clearance requirements are designed to help detect and prevent potential abuses, including front-running and scalping. The Code and other procedures adopted by us contain the following provisions to handle conflicts of interest: 1. All Supervised Persons are required to certify in writing that they have received a copy of Zoe's Code, have read and understand the Code, and agree to comply with the Code. 2. Each Access Person must submit for Zoe's review a report of his or her personal securities transactions and securities holdings periodically. 3. Each of our Access Persons must submit an initial and annual holdings report of the Access Person's current covered securities holdings. 4. Each Access Person's initial and annual holdings reports are reviewed by Zoe's Chief Compliance Officer. 5. Any Supervised Person not in observance of the above will be subject to disciplinary action, and possible termination. 21  Item 12: Brokerage Practices As set forth above, a Client also will open a Client Account with Apex or with another Custodian of the RIA or the Client's choice. Zoe is not affiliated with Apex Clearing Corp or any Custodian. In addition, except where Clients have a third-party broker, Clients will generally become customers of Zoe's affiliated introducing broker, Zoe Securities. Zoe does not recommend any Approved Custodian. The selection of an Approved Custodian is the sole responsibility of the RIA or the Client. Factors that may bear upon custodian selection include financial strength, reputation, execution quality, pricing, available services, and the range of investment products accessible through each custodian. Commissions and transaction fees vary by Approved Custodian and may be higher or lower than those charged by other financial institutions. For Client Accounts held at Schwab, Schwab has discretion under its custodial agreement to determine the market or exchange on which trade orders are executed unless Zoe directs otherwise. Execution venue selection by Schwab may affect the price at which trades are executed. periodically and systematically reviews its policies and procedures regarding its Zoe recommendation of financial institutions in light of its duty to obtain best execution. Zoe does not receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions ("soft dollar benefits"). Zoe does not receive Client referrals from Apex. Zoe does not consider whether it receives client referrals from a broker-dealer or third party as a factor in selecting or recommending broker-dealers for client transactions. Directed Brokerage. Where an RIA or Client selects a Custodian other than Apex, the Client may pay higher brokerage commissions and Zoe may not be able to aggregate orders to reduce transaction costs, or the Client may receive less favorable prices. Not all advisers require their clients to direct brokerage to a particular custodian. In directing brokerage to a particular custodian or broker-dealer, Clients and RIAs should understand that Zoe may not be able to achieve the most favorable execution of client transactions, and that this practice may cost Clients more money. Trade Aggregation. As set forth above, each Custodian aggregates Client trades for execution, and allocates securities among Client accounts on a pro-rata basis based on the average price of all securities that were block traded. No Client Account receives preferential allocation within an aggregated order. Although stocks and ETFs may be traded throughout the day at market prices, the last trade instructions are generally sent to Custodian at or before 3pm Eastern Time, subject to exceptions at Zoe's discretion. Zoe aggregates trades where possible across Client Accounts to seek to obtain more favorable execution and pricing. Where trades cannot be aggregated — for example, where Clients use different custodians — Clients may receive different execution prices for the same security. When trades cannot be aggregated across 22  custodians, Zoe submits trade instructions to each custodian at approximately the same time and does not systematically prioritize any custodian or group of Client Accounts over another. Zoe periodically reviews its trade execution processes to help ensure that no group of Client Accounts is consistently disadvantaged. 23  Item 13: Review of Accounts It is you or your RIA's responsibility to review your account. Please review your RIA's Form ADV Part 2A to understand how and when the RIA monitors and reviews your account. For Client Accounts for which Zoe provides sub-advisory services, Zoe monitors those accounts on an ongoing basis to help ensure they remain aligned with the applicable Model Portfolio or Custom Model. This monitoring includes reviewing that trades have been executed in accordance with model instructions, that accounts have been rebalanced as directed, and that any model changes have been properly implemented. Zoe also monitors third-party Model Portfolio providers for material changes to their strategies or operations as described in Item 8. Zoe does not conduct individualized reviews of Client Accounts for suitability or performance; those reviews are the responsibility of the Client's RIA. Clients will receive account statements from their Custodian at least monthly, reflecting all transactions and holdings in their Client Accounts. In addition, Clients may access account information through the Zoe Wealth Platform. Clients should carefully review the account statements they receive from their Custodian for accuracy. 24  Item 14: Client Referrals and Other Compensation As discussed above, Zoe operates a referral program pursuant to which it refers Users to RIAs that participate in the Zoe Advisor Network. Certain of such RIAs participate in the Zoe Wealth Platform. For information about Zoe's online referral program, including conflicts of interest associated with referrals made and received in connection with the referral program, please refer to Zoe's separate Disclosure Brochure, which is available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . As discussed above, Zoe also has a separate solicitor agreement with Ethic, Inc. Zoe refers other RIAs to Ethic, Inc. for portfolio management of client assets. Zoe is compensated based on a percentage of assets under management for those Client Accounts managed by Ethic, Inc. A conflict of interest exists, because Zoe has financial incentive to promote Ethic, Inc., to RIAs on its platform. Zoe does not recommend specific third-party providers, including Ethic, to RIAs for their Clients. 25  Item 15: Custody Zoe has authority to instruct Custodians to deduct its fees and, in certain cases, the fees of Client RIAs directly from Client Accounts. Under SEC Rule 206(4)-2, this fee deduction authority alone does not constitute a form of custody. Zoe complies with the conditions of Rule 206(4)-2(b)(3): concurrently with each fee deduction, Zoe provides Clients with an itemized invoice showing the fee amount and the calculation methodology, and each qualified custodian sends account statements to Clients at least quarterly. Client assets are maintained at independent, qualified custodians, which currently include Apex Clearing Corporation and Charles Schwab & Co., Inc. Clients will receive account statements from their Custodian at least quarterly. These account statements will reflect all holdings, transactions, and any fees deducted from the account during the statement period. Clients should carefully review their custodian account statements for accuracy. In addition, as described in Item 13, Clients may access account information through the Zoe Wealth Platform. Clients should compare the information available through the Platform with the official account statements they receive from their Custodian. In the event of any discrepancy, the custodian account statements should be considered the official record. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, please contact us at compliance@zoefin.com . 26  Item 16: Investment Discretion To receive services through the Platform, a Client will enter into an advisory agreement with his or her RIA that outlines the services to be performed by the RIA, the authority of the RIA and/or the Client over transactions effected for the Client (including the authority for the RIA to engage Zoe on behalf of Client to perform the services pursuant to the TAMP Agreement). The TAMP Agreement between Zoe and RIAs governs Zoe's authority with respect to Client Accounts. Zoe's discretionary authority is established through the execution of the TAMP Agreement between Zoe and the RIA, and the Client's advisory agreement with the RIA that authorizes the RIA to engage Zoe for sub-advisory services. Except where Zoe has been engaged as sub-advisor, as described above, Zoe implements securities transactions on a non-discretionary basis, whereby it places trades for Clients with the Client or their RIA's prior consent and approval. Where Zoe has been engaged as sub-advisor, Zoe exercises limited discretionary authority, which includes authority to: (a) buy and sell securities to maintain a Custom Model or Model Portfolio selected by RIA following receipt of a liquidation or transfer request from a Client (either directly or via RIA); (b) effect any changes to Model Portfolios utilized for a Client Account, based on changes to the Model Portfolio made by Zoe or the relevant third-party provider; (c) rebalance Client Accounts in accordance with Instructions received and accepted by Zoe; (d) otherwise implement instructions from the RIA received and accepted by Zoe. Zoe's discretionary authority is limited to the scope described above. Zoe does not have discretionary authority to select investment strategies, determine asset allocations, or recommend specific securities for individual Clients. Those responsibilities remain with the Client's RIA. 27  Item 17: Voting Client Securities (Proxy Voting) Zoe does not have authority to vote proxies for securities held in Client Accounts. Clients will receive their proxies or other solicitations directly from their Custodian or a transfer agent. Clients are responsible for voting their own proxies. Clients who have questions about a particular proxy solicitation should contact their RIA. 28  Item 18: Financial Information Zoe does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, Zoe is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Zoe has no disclosures pursuant to this Item. Zoe has not been the subject of a bankruptcy petition at any time during the past ten years. 29 

Zoe Financial, Inc. Advisor Network Disclosure Brochure Zoe Financial, Inc. c/o Studio by Tishman Speyer 666 Third Ave, 6th Floor New York, NY, 10017 (646) 680-9244 www.zoefinancial.com April 24, 2026 This brochure (the "Brochure") provides information about the qualifications and business practices of Zoe Financial, Inc. ("Zoe," "we," "us," or "our"). If you have any questions about the contents of the Brochure, please contact us at 646-680-9244 or compliance@zoefin.com . The information in the Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. information about Zoe also is available on the SEC's website at Additional www.adviserinfo.sec.gov . Registration as an investment adviser does not imply a certain level of skill or training.  Item 2: Material Changes This Item discusses material changes to the Brochure since the last annual amendment dated April 20, 2026. Zoe has the following changes to disclose in relation to this Item: ● ● ● ● ● ● ● ● Zoe has clarified that no individual entity other than its principal owner holds 25% or more of Zoe in Item 4. Zoe has expanded its description of the types of clients and eligibility requirements for the referral program in Item 7. Zoe has added a cross-reference to the Wealth Platform Disclosure Brochure and Wrap Fee Program Brochure for information about Zoe's methods of analysis for sub-advisory services in Item 8. Zoe has added a risk disclosure regarding the limitations of its matching process in Item 8. Zoe has expanded its Code of Ethics disclosure in Item 11. Zoe has added an explicit bankruptcy disclosure in Item 18. Zoe has added disclosure regarding a principal's advisory board role at Diversified LLC, an independent financial services firm, and the associated conflict of interest. See item 10. Zoe has expanded its ownership disclosure in Item 4 and Item 10 to identify Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. as holders of direct minority ownership interests in Zoe. You may request a copy of our current Advisor Network Disclosure Brochure, free of charge, by contacting us at (646) 680-9244 or compliance@zoefin.com , or by visiting our website at www.zoefinancial.com . Additional information about Zoe is available through the SEC's Investment Adviser Public Disclosure website at https://adviserinfo.sec.gov/. 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Item 11: Code of Ethics, Participation or Interest in Client Trans and Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities (Proxy Voting) Item 18: Financial Information 1 2 3 4 6 7 8 9 11 12 14 15 16 17 19 20 21 22 3  Item 4: Advisory Business Zoe Financial, Inc. ("Zoe," "we," "us," or "our") is a Corporation organized in the State of Delaware. Zoe was formed in June 2016 and its principal owner is Andres Garcia. No other individual or entity holds 25% or more of Zoe. Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. each hold minority ownership interests in Zoe. Certain entities, including Creative Planning, LLC, affiliates of CapFinancial, LLC, Mariner, LLC dba Mariner Wealth Advisors, Sequoia Financial Advisors, LLC, Perigon Wealth Management, LLC, and Falcon Wealth Planning, Inc., hold indirect minority interests in Zoe, as further described in Item 10 of this Brochure. Disclosure Brochure, which available on the SEC's website The Brochure describes Zoe's online referral program pursuant to which Zoe refers to users of our website at www.zoefinancial.com ("Users") to third-party registered investment advisers ("RIAs") that participate in the "Zoe Advisor Network." For information about our turnkey asset management program (the "Zoe Wealth Platform"), pursuant to which Zoe provides reporting, administrative, sub-advisory, and other support services to RIAs on behalf of their underlying advisory clients, please refer to Zoe's separate Wrap Fee Program Brochure and Wealth at are Platform www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . analyze information from Users through a digital form on our In providing referrals to one or more RIAs that participate in the Zoe Advisor Network, we collect website, and www.zoefinancial.com . Through the digital form, Zoe collects data about the User, including the following: (1) the User's annual household income, financial goals (which could include retirement, home purchase, family planning, investments, and taxes); (2) whether the User owns any cash, real estate, investment accounts, or retirement accounts; (3) the User's zip code; and (4) in certain cases, whether the User currently has a financial advisor. Data points collected can vary and can change if necessary to enhance the matching service. Based on the information provided by the User through the digital form, Zoe matches the User with RIAs that have been previously vetted and that best align with the User's answers provided in the digital form. Some Users may only receive one recommended RIA based on the answers given by the User through the digital form. In providing referrals to RIAs that participate in the Zoe Advisor Network, we do not consider a User's individual risk profile and individual investment objectives, given the limited nature of the referral program. (Such determinations are the responsibility of the RIA in connection with its implementation of specific investment strategies for the User, in the event the User decides to engage an RIA referred by Zoe.) Users may indicate preferences through the digital form, but may not impose specific restrictions on the types of RIAs to which they are referred beyond the information collected during the onboarding process. The User is ultimately responsible for deciding whether to enter into an advisory relationship with one of the RIAs referred by Zoe. As part of Zoe's due diligence process, we determine whether RIAs are registered as an investment adviser and review their areas of focus and expertise. We do not review the ongoing performance of RIAs, do not affect changes for the 4  User's account with the RIA, and do not recommend particular investment strategies or securities to Users. Users should carefully review recommended RIAs' Form ADV Part 2A (Disclosure Brochures) and should be aware that they can obtain investment advisory services directly from the recommended RIAs or other RIAs of the User's choice, including RIAs that may not participate in the Zoe Advisor Network. Our services are limited to making referrals to other RIAs. The RIA that the User ultimately chooses to work with is responsible for determining and implementing specific investment strategies and recommending particular securities for the User. In addition to matching Users through www.zoefinancial.com , Zoe may also receive Users' information through arrangements with third-party websites. These third-party websites may collect basic information from the Users and submit it to Zoe through other means, such as direct integrations with our platform. For these Users, Zoe may introduce the User directly to one of a limited number of pre-screened RIAs from the Zoe Advisor Network, without using the Zoe digital form or website. Zoe is not a current client of any RIA recommended through the Zoe Advisor Network. Assets Under Management As of December 31, 2025, Zoe managed approximately $118,174,160 of discretionary and $165,299,031 of non-discretionary client assets in connection with its sub-advisory services through the Zoe Wealth Platform. Zoe does not manage client assets in connection with the Zoe Advisor Network referral program. 5  Item 5: Fees and Compensation If a referred User enters into an advisory relationship with an RIA participating in the Zoe Advisor Network, that RIA will pay Zoe a portion of the advisory fees it charges to such User. Alternatively, Zoe receives a one-time referral fee from an RIA. Users will receive a disclosure statement that details the fee arrangement with the RIA prior to entering an advisory agreement with the RIA. Users do not pay a fee for using the referral program or through any third-party websites that may link to the Zoe Advisor Network. Zoe's referral fees are paid directly by the RIA to Zoe. Further, Zoe's referral agreement with each RIA participating in the Zoe Advisor Network requires that no portion of Zoe's referral fee will be charged to the User by the RIA, and that there shall be no difference in the level of advisory fees that Users will be charged by the RIA resulting from its referral arrangement with Zoe. In other words, the referral agreement mandates that Users will not pay higher fees to the RIA because they were referred by Zoe. The referral fees described above are established in Zoe's referral agreement with each RIA and are generally not negotiable. Zoe's receipt of referral compensation from RIAs participating in the Zoe Advisor Network and other business relationships with certain RIAs participating in the Zoe Advisor Network creates material conflicts of interest that are further described in Item 14, below. 6  Performance-Based Fees and Side-By-Side 6: Item Management Zoe does not charge performance-based fees or provide side-by-side management. 7  Item 7: Types of Clients Zoe provides its referral program to Users, who consist of individuals and high-net-worth individuals seeking wealth management guidance. There are no minimum account sizes, income requirements, or other eligibility requirements for Users to access Zoe's referral program. Users are not required to open or maintain an account with Zoe to receive a referral, and there are no requirements for opening or maintaining an account in connection with the referral program. RIAs referred through the Zoe Advisor Network may impose their own minimum account sizes or other requirements. Users should review the Form ADV of any referred RIA for information about that RIA's requirements. 8  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss at www.adviserinfo.sec.gov or upon written request to Zoe The following describes Zoe's methods of analysis in connection with its referral program. For information about Zoe's methods of analysis in connection with its sub-advisory services through the Zoe Wealth Platform, please refer to Zoe's Wealth Platform Disclosure Brochure (specifically Item 8) and Wrap Fee Program Brochure (specifically Item 6), available on the SEC's at website compliance@zoefin.com . Due Diligence on RIAs In connection with the referral program, Zoe conducts initial and ongoing due diligence on prospective RIAs and their investment adviser representatives ("IARs") participating in the Zoe Advisor Network. The diligence process includes, but is not limited to, reviewing that RIAs are: (1) financial planning centric; (2) have a number of IARs that possess certain advanced designations, such as the chartered financial analyst (CFA), Certified Financial Planner™ (CFP®), certified public accountant (CPA), and/or a graduate degree in business administration; and (3) have no material disciplinary disclosures. In addition, Zoe reviews the RIA's Form ADV Parts 1A and 2A and Form CRS, as well as any other relevant and available data such as websites and general news. Zoe may also conduct due diligence calls with RIAs to discuss any information it collects during its diligence process. Provided the RIA meets Zoe's criteria for participation in the Zoe Advisor Network, Zoe then reviews participating IARs' responses to its questionnaire, their CRD records, Form U4s and Form ADV Part 2Bs. On an annual basis, Zoe collects the annually updated Form ADV Part 2A (Disclosure Brochure) of RIAs participating in the Zoe Advisor Network to review for any disciplinary issues and financial issues. Zoe cannot ensure that those RIAs will perform as desired, and we will have no control over the day-to-day operations of any recommended RIA. Zoe would not be aware of certain activities at its recommended RIAs, including, without limitation, an Adviser engaging in unreported risks, investment "style drift," or even regulatory breaches or fraud, unless identified in the annual due diligence discussed above. Additionally, Zoe cannot guarantee that a User's financial goals will be attained through its recommended RIAs. Past performance of any RIA is not a guarantee of its future returns. Investing in securities and other investments involves a risk of loss that each User should understand and be prepared to bear. Users are reminded to discuss these risks with the RIA the User ultimately chooses to work with, if applicable. Users should obtain risk disclosures from any Adviser with which they conduct business and fully understand the risks of investing. Matching Limitations Zoe's referral program collects limited information from Users through a digital form and matches Users to RIAs based on that information. Because Zoe does not assess a User's 9  individual risk profile, investment objectives, or complete financial situation, there is the potential that a referral may not align to the full scope of a User's needs. Users should conduct their own evaluation of any referred RIA, including reviewing the RIA's Form ADV, before entering into an advisory relationship. 10  Item 9: Disciplinary Information Zoe has no criminal or civil actions or administrative or self-regulatory organization proceedings to report in connection with this Item. 11  10: Other Financial Industry Activities and Item Affiliations Zoe's affiliate, Zoe Securities, LLC ("Zoe Securities"), is an SEC-registered broker-dealer and member of the Financial Industry Regulatory Authority ("FINRA"). In addition, certain supervised persons of Zoe are registered as representatives of Zoe Securities. Zoe Securities provides certain services to clients of the Zoe Wealth Platform. These services, as well as associated conflicts of interest, are described in Zoe's Wrap Fee Program Brochure and Wealth Platform Disclosure Brochure, which are available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . Neither Zoe nor its supervised persons are registered as, or have pending applications to become, a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. As discussed in Item 5, above, if a referred User enters into an advisory relationship with one of the recommended RIAs through the Zoe Advisor Network, that RIA will pay Zoe a portion of the fee it charges to its clients or a flat fee. Zoe's receipt of referral compensation from RIAs participating in the Zoe Advisor Network and other business relationships with certain RIAs participating in the Zoe Advisor Network creates material conflicts of interest that are further described in Item 14, below. Open Opportunity Fund, LLC, SageView III (A), L.P., and SageView III (B), L.P. each hold minority ownership interests in Zoe. Creative Planning, LLC and affiliates of CapFinancial, LLC, Mariner, LLC dba Mariner Wealth Advisors, Sequoia Financial Advisors, LLC, Perigon Wealth Management, LLC, and Falcon Wealth Planning, Inc., have an ownership interest in Zoe. These entities and their affiliates are also on the Zoe Advisor Network and may have clients referred to them by Zoe through the referral program. As a result, a conflict of interest exists among these entities, their affiliates and Zoe in the form of increased financial incentives by being referred clients. To mitigate this risk, Zoe continues to refer Users to RIAs solely based on that User's answers to questions during the potential User's onboarding process, and does not give preferential treatment on the number of referrals sent to the foregoing RIAs that have an ownership interest in Zoe or whose affiliates hold indirect interests in Zoe. Further, Zoe has an incentive to prefer Clients and Users of these entities or their affiliates arising from their ownership in Zoe. Zoe has policies and procedures in place to help ensure Clients of these entities are not given preferential treatment, notwithstanding this incentive. A principal of Zoe Financial serves as a non-compensated member of the Advisory Board of Diversified LLC, a financial services firm. Zoe Financial has identified this relationship as a conflict of interest given that both firms operate in the financial services industry. Zoe addresses this conflict by ensuring that the advisory board role does not influence Zoe Financial's investment recommendations, client account management, or selection of service providers. 12  Zoe has a separate solicitor agreement with Ethic, Inc. ("Ethic") pursuant to which Zoe refers RIAs to Ethic for portfolio management of client assets. Zoe is compensated based on a percentage of assets under management for those client accounts managed by Ethic. A conflict of interest exists, because Zoe has financial incentive to promote Ethic to RIAs on the Zoe Wealth Platform. Zoe does not recommend specific third-party providers, including Ethic, to RIAs for their Clients. 13  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Zoe has adopted a Code of Ethics (the "Code") pursuant to Rule 204A-1 under the Investment Advisers Act of 1940. The Code requires all Supervised Persons to act in the best interests of Zoe's clients and to comply with all applicable federal securities laws. The Code includes provisions addressing prohibited activities, conflicts of interest, confidentiality of client information, compliance with laws and regulations, and the reporting of violations. In addition, the Code requires certain Supervised Persons who have access to nonpublic information about client transactions ("Access Persons") to report their personal securities holdings and transactions to Zoe's Chief Compliance Officer on a periodic basis. Access Persons must also obtain pre-approval before acquiring securities in initial public offerings or limited offerings. Each Access Person's initial and annual holdings reports are reviewed by Zoe's Chief Compliance Officer. Any Supervised Person not in observance of the Code will be subject to disciplinary action, and possible termination. Zoe and its Supervised Persons may from time to time buy or sell securities that are the same as securities held in client accounts on the Zoe Wealth Platform. It is Zoe's policy that no Supervised Person may profit at the expense of any client or compete with any client. Zoe addresses these conflicts through the personal trading reporting and review procedures described above. For additional information about Zoe's Code of Ethics and how it applies to the Zoe Wealth Platform, please refer to Zoe's Wealth Platform Disclosure Brochure and Wrap Fee Program Brochure, available on the SEC's website at www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . A copy of Zoe's Code of Ethics is available upon written request to Zoe at compliance@zoefin.com . 14  Item 12: Brokerage Practices This Item is not applicable to Zoe's referral program. 15  Item 13: Review of Accounts The referral service consists of a one-time referral to RIAs. Zoe does not review or provide updated referrals to Users, unless they re-enroll in the referral program, in which case, they would receive updated referrals. 16  Item 14: Client Referrals and Other Compensation As set forth above, if a referred User enters into an advisory relationship with an RIA referred through the Zoe Advisor Network, the RIA will pay Zoe a portion of the advisory fees it charges to such User. Alternatively, Zoe receives a one-time referral fee from an RIA. Users will receive a disclosure statement that details the fee arrangement with the RIA prior to entering an advisory agreement with the RIA. Zoe's receipt of referral fees from RIAs provides it an incentive to recommend the RIAs participating in the Zoe Advisor Network, resulting in a conflict of interest. Disclosure Brochure, which available on the SEC's website In addition to these fees earned in connection with the referral program, Zoe earns fees from RIAs, including RIAs referred through the referral service, related to their use of the Zoe Wealth Platform, which, as described above, provides reporting, administrative, sub-advisory, and other support services to RIAs on behalf of their underlying advisory clients. For additional information about the Zoe Wealth Platform, please refer to Zoe's Wrap Fee Program Brochure and Wealth Platform at are www.adviserinfo.sec.gov or upon written request to Zoe at compliance@zoefin.com . In connection with the Zoe Wealth Platform, Zoe charges RIAs that use the Zoe Wealth Platform fees that vary based on the level of service provided. Accordingly, some RIAs pay a higher rate than others for Zoe's services. In addition, Zoe reserves the right to require RIAs to use the Zoe Wealth Platform, and maintain a cumulative minimum account value at the platform, in order to also be included in the Zoe Advisor Network. This creates a conflict of interest in that Zoe would have an incentive to refer Users to RIAs that utilize the Zoe Wealth Platform, and specifically, those that pay Zoe higher fees. Notwithstanding the foregoing, Zoe's algorithms are designed and intended to act in the best interests of the User, including when determining to which investment advisers to refer a User. Fees that advisors pay Zoe are not integrated into the matching algorithm to mitigate those conflicts of interest. Because Zoe's contractual relationship with RIAs includes compensation from RIAs for their participation on the Zoe Advisor Network, Zoe has a material conflict of interest in referring RIAs to prospective clients. To mitigate this risk, Zoe continues to refer Users to RIAs solely based on that User's answers to questions during the potential User's onboarding process, and does not give preferential treatment on the number of referrals sent to RIAs that participate in the Zoe Advisor Network. Zoe has arrangements in place with certain non-affiliated third-party solicitors, under which such solicitors refer Users to our referral program in exchange for a fixed amount per prospective User referred. Such compensation creates an incentive for the solicitors to refer clients to us, which is a conflict of interest for the solicitors. Rule 206(4)-1 of the Advisers Act addresses this conflict of interest by, among other things, requiring disclosures of whether the solicitor is a client or a non-client of Zoe and a description of the material conflicts of interest and material terms of the compensation arrangement with the solicitor. Accordingly, we require third-party solicitors that introduce potential Users to us to provide the following disclosure to referred Users, in writing: (1) whether the solicitor is a client or a non-client; (2) that the solicitor will be 17  compensation arrangement; and the material compensated for the referral; (3) the material conflicts of interest arising from the relationship and/or terms of the compensation (4) arrangement, including a description of the compensation to be provided for the referral. As discussed in Item 10 above, Zoe also has a separate solicitor agreement with Ethic. Refer to Item 10 for additional information regarding this relationship. In the event Zoe does not match a User to an RIA based on the User's answers provided in the digital form, Zoe provides the User information about non-securities products and/or services offered by third parties other than RIAs. Such non-securities products and/or services include, but are not limited to, high-interest savings accounts provided by third-party banks. Zoe receives compensation from these third parties for marketing their products or services or based on Users purchasing their products or services. Zoe's receipt of such compensation from these third parties creates a conflict of interest for Zoe to provide information about third parties that provide such compensation, rather than third parties that do not provide such compensation. To address this conflict, Zoe provides disclosure of its receipt of compensation through its website, where applicable. Users are advised that Zoe does not filter the third-party products shown to Users based on answers Users give on the website and does not constitute personalized investment or financial advice by Zoe. Users are further advised that products and/or services of third parties that do not compensate Zoe may be more appropriate than the products and/or services for which Zoe provides information through its website. Users are under no obligation to purchase the products and/or services for which Zoe provides information through its website. 18  Item 15: Custody This Item is not applicable to Zoe's referral program. 19  Item 16: Investment Discretion This Item is not applicable to Zoe's referral program. 20  Item 17: Voting Client Securities (Proxy Voting) This Item is not applicable to Zoe's referral program. 21  Item 18: Financial Information Zoe does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, Zoe is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Zoe has no disclosures pursuant to this Item. Zoe has not been the subject of a bankruptcy petition at any time during the past ten years. 22