Alinea Advisory Services LLC

46 Howard Street

New York City, NY 10013

ADV PART 2A, APPENDIX 1: WRAP FEE PROGRAM BROCHURE

www.alinea-invest.com

November 11, 2026

This wrap fee program brochure provides information about the qualifications and business practices of Alinea Advisory Services LLC (“Alinea”). If you have any questions about the contents of this brochure, please contact us at info@alinea-invest.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.

Alinea Advisory Services LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information with which you determine to hire or retain an adviser.

Additional information about Alinea Advisory Services LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Alinea Advisory Services LLC may be searched by name or using our CRD #311782.

Item 2: Material Changes

Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. Generally, Alinea will notify clients of material changes on an annual basis in Alinea’s annual brochure update. However, where we determine that an interim notification is either meaningful or required, we will notify our clients promptly.

Since the last amendment to Alinea’s Form ADV Part 2 brochure on March 6, 2026, we have made material changes to this brochure:

• Item 4: Services, Fees and Compensation: Added descriptions of Alinea’s investment programs (Playlist Pro, Vibe Investing, Automated Investing, and Crypto), IRAs, USVC shares offered through DriveWealth, Alinea’s AI-based assistant, and account onboarding, including a third-party service provider used to link bank accounts. Updated the subscription fee structure (annual, monthly, and one-time options); added account termination fees, regulatory transaction fees and settlement timing, the mandatory cash reserve, DriveWealth’s bank sweep program, IRA and USVC fees and expenses, including the revenue share Alinea receives from AngelList on USVC assets.
• Item 6: Portfolio Manager Selection and Evaluation: Added risk disclosures for artificial intelligence and large language models, cryptocurrency, the cash sweep program, IRAs, and USVC (illiquidity, uncertain share repurchases, and estimated valuations); clarified Alinea’s discretionary trading authority.
• Item 9: Additional Information: Added an affiliate’s registration as an Introducing Broker with the National Futures Association; added Alinea’s client referral program and the USVC revenue share; updated Alinea’s custody disclosure.

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 Portfolio Managers
• Item 8: Client Contact with Portfolio Managers
• Item 9: Additional Information
  
  • A. Disciplinary Information; Other Financial Industry Activities and Affiliations
  • B. Code of Ethics; Review of Accounts; Client Referrals and Other Compensation; Custody; Financial Information

Item 4: Services, Fees and Compensation

Firm Description

Alinea Advisory Services LLC (hereinafter referred to as “Alinea”, the “Firm”, “we”, “us”, “our”) is a Delaware limited liability company with its principal office located in New York City, NY and is registered with the Securities and Exchange Commission (the “SEC”) as an investment adviser. Alinea Advisory Services LLC is a wholly owned subsidiary of Alinea Invest, Inc. Alinea Invest, Inc. was formed in November 2020 and is owned / founded by Anam Lakhani and Eve Halimi. As of October 1, 2026, Alinea had discretionary assets under management of $47,531,727, and non-discretionary assets under management of $19,074,068.

Services

Alinea provides discretionary investment advisory services through a mobile app (computer application) to separately managed accounts of individuals (each a “Client,” and collectively, “Clients”) in a program that bundles or “wraps” services together and charges a single annual subscription fee (the “Program”). The services included in the wrap are advisory, trade execution, clearance, settlement, and custody and reporting for securities held through DriveWealth. Cryptocurrency transactions and USVC Fund shares are not part of the wrap fee (see Fees and Compensation below). Alinea offers these services to individual taxable accounts and individual retirement accounts (“IRAs”).

The Program seeks to assist in managing market risk or volatility in long-term oriented investment portfolios that are primarily invested in what Alinea considers suitable securities and funds for the Client’s selected strategy, offered through several distinct programs described below and enabled via a mobile application.

The Program does not provide comprehensive financial or tax planning or legal advice, and Clients are advised and afforded the opportunity to seek the advice and counsel of the Client’s own tax, financial, and legal advisers.

Alinea acts as both the sponsor of the Program and the sole portfolio manager responsible for investment decisions made on behalf of Program accounts (see Item 6 below). Alinea does not retain unaffiliated portfolio managers, and Clients do not select among portfolio managers. Because Alinea performs both roles, Alinea has an incentive to recommend its own Program over an arrangement that would separate these functions and compensate an unaffiliated manager. Alinea addresses this conflict by charging a single, disclosed subscription fee regardless of trading frequency. Alinea also receives a revenue share from AngelList on USVC Fund assets, which is a separate conflict of interest (see Item 9 and the USVC section below).

Advisory Business: Program Description

Alinea’s Program interacts with its Clients predominantly through a software application that is available through mobile platforms (the “Alinea App”). The advisory services are delivered solely through the Alinea App. Alinea does not provide investment advice in person or over the phone or in any manner other than through the Alinea App. Alinea’s website, www.alinea-invest.com, is for informational purposes only. Account access, portfolios, Allie and all advisory services are available only in the Alinea App.

Alinea offers its Program through six product types: Playlist Pro, Vibe Investing, Automated Investing, Crypto, IRAs, and the USVC Venture Capital Access Fund (offered through DriveWealth, LLC (“DriveWealth”), a broker-dealer). A Client’s onboarding questionnaire responses (employment status, income, investment goals, time horizon, and net assets) inform the Client’s assigned risk profile for Automated Investing and Vibe Investing; Playlist Pro portfolios are standard for all investors and are not matched to a Client’s risk tolerance. The products differ materially in how portfolios are constructed and maintained.

Playlist Pro

Clients may invest in playlists created by Alinea (“Playlist Pro”), which fall into three categories: AI Playlists, Thematic Playlists, and Copy-Traded Playlists. Clients may not modify the target weights of Alinea-created playlists.

AI Playlists are designed and managed entirely by an AI research process, using large language models developed by third parties. The AI determines both an AI Playlist’s initial target weights and any changes to them, based on news, historical market data, and other sources, without human review before changes take effect, and, under the discretionary authority Clients grant Alinea (see Item 6), the changes are applied to Clients’ accounts automatically. Alinea is the adviser and monitors the program for anomalies, but no Alinea employee reviews or approves individual changes. AI Playlists are rebalanced on the first Friday of each month. Each AI Playlist is researched and weighted by its own large language model. The companies that make these models are not affiliated with Alinea and do not endorse it. Each time weights change, Alinea provides Clients a report identifying the specific adjustments, the reasoning and sources relied on, and an overall qualitative assessment of the playlist (described as strong, stable, weakening, or critical).

Thematic Playlists are Playlist Pro offerings built around a theme or scenario (for example, “what would happen if...”). A large language model developed by a third party (currently OpenAI) selects the securities and sets the initial target weights, and an AI research process may adjust them on the first Friday of each month, without review or approval by an Alinea employee. The changes are applied to Client accounts automatically under the discretionary authority Clients grant Alinea (see Item 6). As with other Alinea-created playlists, Clients may not modify the weights, and Alinea provides a report explaining each change. The company that makes the model is not affiliated with Alinea and does not endorse it.

Copy-Traded Playlists are designed to track the estimated holdings of a specified company or individual, using data compiled by a third-party data provider from public regulatory filings. On the first Friday of each month, an AI process reviews the most recently available filing, calculates each reported holding’s weight as a percentage of total reported value, and adjusts the playlist’s target weights to match. The AI weights the playlist to match the reported filing; no Alinea employee reviews or approves the changes.

Vibe Investing

Vibe Investing allows a Client to create a custom thematic portfolio. The Client specifies a theme, any specific securities to include or exclude, and a risk preference (conservative, moderate, or opportunistic). Based on these inputs, an AI large language model developed by a third party (currently OpenAI) selects approximately 8 to 15 securities that fit the theme, each with a stated rationale, and assigns initial weights based on each security’s centrality to the theme. Selected securities are checked against Alinea’s supported-instrument list before the portfolio is presented to the Client. Once a Client invests in a Vibe Investing portfolio, an AI research process reviews and may adjust the portfolio’s target weights on a monthly basis (the first Friday of each month), drawing on financial data, news, and analyst commentary from a defined list of financial data sources. No Alinea employee reviews or approves these weight changes before they take effect. The changes are applied to the Client’s account automatically under the discretionary authority the Client grants Alinea (see Item 6). Each time weights change, Alinea provides the Client a report describing the rationale and underlying sources, with citations. Unlike Alinea-created playlists, Clients may directly edit a Vibe Investing portfolio’s weights, name, description, icon, and constituent securities at any time; however, the AI’s monthly adjustments may overwrite a Client’s edits. Clients may start the creation flow with Allie, Alinea’s AI assistant, which does not select the securities.

Automated Investing

Alinea Automated Investing (“Automated Investing”) assigns each Client to one of four model portfolios (low, moderate, high, or hyper risk) based on the Client’s questionnaire responses at onboarding. Each portfolio is built from a fixed set of funds holding a mix of exchange-traded funds (ETFs) at target weights. The underlying funds and their target weights do not change based on market movements, but Alinea reevaluates the composition of each tier’s portfolio on a quarterly basis to confirm continued suitability. Client accounts are rebalanced monthly to realign actual holdings with the assigned tier’s target weights. Automated Investing’s model portfolios are not tailored to the individual Client beyond the assigned risk level.

Crypto

Alinea offers Clients the ability to purchase individual cryptocurrencies and to invest in Crypto Automated, a diversified basket of cryptocurrencies at fixed target weights (for example, larger allocations to Bitcoin and Ethereum with smaller allocations to other major coins). Coin availability varies by state of residence; for example, certain coins are not available to Clients with a New York address because New York requires coins to be approved before they can be sold in the state. Crypto trading and custody are provided through ZeroHash, LLC, a third-party crypto infrastructure provider, and not through DriveWealth, Alinea’s securities custodian (see Brokerage Practices and Item 9 below). Crypto purchased through Alinea cannot be sold until the ACH transfer used to fund the purchase settles, which can take one to five business days; proceeds from a crypto sale can similarly take one to five business days to return to the Client’s bank account. Crypto Automated does not rebalance on a fixed schedule; instead, each deposit is allocated to bring the most underweight coins toward target first, and each withdrawal is sourced from the most overweight coins, so that ordinary account activity gradually realigns the portfolio without incurring rebalancing trade fees on a schedule.

Individual Retirement Accounts (IRAs)

Alinea offers individual retirement accounts (“IRAs”) under the Program. IRA assets are held at DriveWealth, LLC, as custodian, and are managed by Alinea; Alinea is not the custodian of any IRA. Clients may only establish new IRAs through Alinea; Alinea does not accept ACATS transfers or rollovers of IRAs or assets from existing plans. An IRA is an account type, not an investment, and the investments held in an IRA can lose value. Contribution limits, eligibility requirements, and tax rules, including rules for withdrawals, apply to the Client. When Alinea provides investment advisory services for a Client’s IRA, Alinea acts as a fiduciary under the Advisers Act and the Internal Revenue Code. Alinea does not provide tax advice.

USVC Venture Capital Access Fund

Shares of the USVC Venture Capital Access Fund (the “USVC Fund”) are offered through DriveWealth, a broker-dealer, to eligible Clients in taxable accounts only. Alinea does not advise or manage the USVC Fund. It is a registered, non-diversified, closed-end tender offer fund advised by AngelList Asset Management, LLC (the “USVC Adviser”). It invests mainly in private venture capital funds and private, growth-oriented companies, with at least 25% of its assets in the technology sector. The USVC Fund began operations in November 2025 and has a limited operating history. The minimum initial investment is $500, and shares are available to eligible U.S. investors. To be eligible, a Client must have annual income of at least $50,000 or liquid net worth of at least $250,000, and a moderate or higher risk tolerance.

A Client chooses whether to buy USVC Fund shares. Alinea does not sell the USVC Fund, advise on whether or how much to buy, or monitor, rebalance, or manage a Client’s USVC Fund holding, and USVC Fund shares are not part of the Program’s wrap fee. This is general information and not a recommendation. AngelList pays Alinea a revenue share on USVC Fund assets, which is a conflict of interest (see Fees and Compensation and Item 9). Alinea is not owned by or affiliated with the USVC Fund or AngelList.

Rebalancing

Alinea uses the term “rebalancing” to refer to two distinct processes: (1) changing a portfolio’s target weights, meaning deciding what a strategy should hold and in what proportion, performed by Alinea’s AI research process for Vibe Investing, AI Playlists, and Thematic Playlists, by the filing-based process for Copy-Traded Playlists (each on the first Friday of every month), or by Alinea’s quarterly review for Automated Investing; and (2) realigning a Client’s actual holdings to a strategy’s current target weights, which occurs automatically at each scheduled monthly rebalance for any account whose allocation has drifted more than 3% from target (subject to a minimum trade size to avoid excessive trading), or when idle cash can be deployed toward underweight positions. A change described in a strategy update report (item 1) results in trades to a Client’s own account only through this separate realignment process (item 2), which may not occur immediately.

Alinea utilizes the Alinea App to collect information with respect to each Client and prospective Client and to deliver account notifications and content. Upon account opening (“Client Onboarding”), the Client will be prompted to complete a series of questions that will be used, in combination with other available Client information collected through the Alinea App prior to and/or after account opening, including banking information. These questions are important to the development of any investment suggestions.

Alinea Assistant (“Allie”)

Alinea provides an AI-based conversational assistant (“Allie”) within the Alinea App that Clients can use to look up information, including their own account holdings, balances, and performance, as well as general market data and educational content about investing. Allie’s responses are generated using data retrieved live from Alinea’s systems and third-party market data sources, rather than from the underlying AI model’s general knowledge.

Allie provides research and feedback; it is not an investment adviser. Allie does not provide individualized investment advice or recommendations and does not exercise investment discretion. Allie may help a Client begin a transaction, but no transaction is placed until the Client reviews and confirms it in the Alinea App. Allie is distinct from the AI systems described above that determine investment weights for Vibe Investing, AI Playlists, and Thematic Playlists; Allie plays no role in those investment decisions.

Client Onboarding

A Client is required to enter into an investment advisory agreement with Alinea (“Advisory Account Management Agreement”), which discusses the services the Client will receive, the fees charged to the Client, and the conditions of the Client’s relationship with Alinea. Our advisory relationship begins upon the effective date of the Advisory Account Management Agreement with a Client. Any preliminary information provided to a Client before we accept the Advisory Account Management Agreement does not constitute investment advice under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and should not be relied on as such.

Alinea offers discretionary and non-discretionary advisory services to individual investors. Alinea interacts with advisory Clients, as well as prospective Clients, solely through the Alinea App. Alinea does not offer financial planning services, tax, accounting, or legal advice.

Client Onboarding is only complete once a Client has linked the Client’s bank account (“Funding Account”) to the Firm’s custodian via the Alinea App and has accepted and countersigned Alinea’s investment advisory agreement electronically. The Firm uses a third-party service provider, Stripe, to link the Client’s bank account with their brokerage account. The Firm does not have or maintain access to a Client’s login credentials. During the initial 7 day trial period, Clients will not have access to purchase stocks via the Alinea App.

Clients should consider that Alinea primarily uses electronic (not telephonic) means to provide customer support. To receive customer support, Clients may contact us using email (support@alinea-invest.com) or through the Alinea App. Clients may utilize live chat for service related questions during the hours of 8am - 10pm EST, 7 days a week. Clients and prospective Clients should be comfortable communicating through those channels. Further, Clients should understand that they will not interact directly with an Investment Adviser Representative or other financial adviser.

Alinea reserves the right to deny any prospective Client access to the Alinea App and to terminate Client accounts for reasons related, but not limited, to unsuitability and/or if Clients fail to timely maintain financial and other information previously provided by the Client on the Alinea App or update this information on at least an annual basis. A Client’s failure to timely update their information in the Alinea App could materially impact the quality and applicability of Alinea’s investment advisory services.

During the Client Onboarding process, the Client will also be prompted to simultaneously open a brokerage account held by the designated custodian in order to execute any trades. The independent custodian will hold Client funds and securities.

At any time, Clients may terminate an account or withdraw all or part of an account. See Fees and Compensation below for more information regarding fees, including withdrawal/administrative charges. Withdrawals may be reduced by regulatory transaction fees. When you sell securities, regulatory fees are assessed on the sale and deducted from your proceeds, so the amount available to withdraw may be slightly less than the sale value shown at the time of your order.

Proceeds from a sale are not available immediately. Securities transactions settle on the first business day after the trade date (T+1), and funds can only be withdrawn after settlement. Once you request a withdrawal, it may take additional business days for the funds to reach your bank account. Weekends and market holidays may extend these timeframes.

Alinea may offer promotions which include such things as investment account rewards or additional promotional offers. These promotions are subject to change and are bound by separate terms and conditions located on our website, and may change on a frequent basis.

Brokerage Practices

The custodian is selected based on the transaction fees relative to other custodians and best quality in terms of technology. Additional factors used to choose the custodian are the custodian’s support services, reputation, and cost-benefit compared to other custodians. Alinea requires Clients to use DriveWealth as their custodian.

For cryptocurrency purchased through Alinea, custody and execution are instead provided by ZeroHash, LLC, a separate, unaffiliated third-party crypto infrastructure provider. Clients may not select an alternative custodian for either securities or cryptocurrency.

USVC Fund shares are available to Clients through DriveWealth, a broker-dealer. DriveWealth holds the shares and sends Clients their statements. Alinea does not direct USVC Fund orders to any other broker-dealer.

Alinea does not receive any research, products, or services from its custodian or another third party (known as soft dollars) in connection with Client securities transactions. Alinea does not receive referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.

Not all advisers require their Clients to use a specific broker-dealer or custodian. Because Alinea requires Clients to use DriveWealth as custodian and executing broker for securities (and ZeroHash, LLC for cryptocurrency), Clients may be unable to achieve the most favorable execution of their transactions, and this requirement may result in higher costs than if Clients were able to direct brokerage to a different broker-dealer. Alinea does not allow Clients to direct brokerage.

Fees and Compensation

Alinea charges a single subscription fee for the Program. Clients choose how they would like to pay it: on a recurring basis, or as a one-time payment. Those choices include:

• Recurring payment: $120 per year. In certain instances, Clients may instead be offered a monthly payment option ranging from $5.00 to $12.00 per month. The specific fee structure applicable to each Client will be clearly disclosed prior to account activation.
• One-time payment: A single payment of $300 covers the subscription for the life of the account (“lifetime” fee), in lieu of recurring annual or monthly payments.

For subscribed Clients, investment management and trade execution are included in the subscription fee; Alinea does not charge either separately.

While Alinea charges fixed, subscription-based fees, this fee is not negotiable. Alinea typically bills for its Program services annually in advance; this results in Alinea receiving a larger upfront fee, which could financially benefit the Firm.

All fees are initially paid via secure payment through the Alinea App, using a third-party service provider. Alinea does not have access to, nor maintain, banking information on our Clients. Clients may subsequently elect to renew their subscription. Alinea shall use an ongoing renewal process through the app to process the annual renewal.

While the Program fee described above covers advisory, trade execution, clearing, settlement, and custody services for securities held through DriveWealth, it shall not be considered as an investment management or financial advising fee. Additionally, the fee does not cover cryptocurrency transactions or USVC Fund shares, which are subject to the separate fees described below.

The Program fee may be higher or lower than the total cost of obtaining these services separately, depending on the Client’s account size, how often the Client trades, and the services the Client would otherwise purchase.

Alinea imposes a mandatory cash reserve as part of each investment strategy. Alinea Clients are required to maintain between 1.50% - 2.00% of the value of their investment account (prorated in each strategy) in cash. The cash reserve reduces the need to sell assets to raise cash during rebalancing. The specific reserve percentage applicable to a Client’s account, within this range, is based on the complexity of the Client’s strategy and the total assets in the account. If a Client wishes to withdraw cash beyond what is held in reserve, Alinea will sell other assets in the Client’s account to replenish the reserve to its required level. If a Client is invested entirely in an illiquid strategy, such that the reserve cannot be replenished immediately, the Client will not be able to immediately withdraw the cash portion.

Uninvested cash held in Client accounts, including the cash reserve described above, is automatically deposited through DriveWealth’s Bank Sweep Deposit Program into interest-bearing deposit accounts at one or more FDIC-insured banks (“Program Banks”). Clients may earn interest on swept balances, at a rate set by DriveWealth that may be higher or lower than rates available through other cash management options, including money market funds. DriveWealth and its program administrator, R&T Deposit Solutions, LLC, may earn fees based on the amount of Client cash held in the program. Alinea does not receive any compensation in connection with this program.

A Client may incur certain charges imposed by other third parties, such as DriveWealth, to pay for fees such as account transfer fees. Please refer to the third-party documents for a full description of any additional fees.

You will pay Alinea’s subscription fees whether you make or lose money on your investments. Subscription fees will reduce any amount of money you make on your investments over time. Please make sure you understand what fees you are paying.

A wrap fee program allows Clients to pay a specified fee for investment advisory services and the execution of transactions. The subscription fee described above includes the cost of executing transactions in the Client’s account; Clients do not pay more based on the number, size, or frequency of transactions, other than the regulatory fees described under Client Onboarding above. Crypto transactions and USVC Fund shares carry the separate fees described below.

Additional Client Fees

There are no sales loads, brokerage fees, mark-ups, mark-downs, spreads paid to market makers, brokerage termination or account surrender fees, electronic fund transfer fees, or account termination fees associated with purchasing securities within our programs, other than the administrative fee described under “Termination of Alinea Subscription and Investment Accounts” below. A Client may, however, incur certain taxes on non-retirement brokerage accounts. The Firm does not provide tax advice. Clients are recommended to speak with a qualified tax professional regarding their specific tax situation.

This does not apply to USVC Fund shares, which carry the fees and expenses described under “USVC Fund Fees and Expenses” below.

Individual Retirement Accounts (IRAs) and Rollovers

The Program’s subscription fee applies to IRAs. For IRAs, the subscription fee is billed to the Client’s bank account and is not deducted from the IRA. Alinea does not provide tax or legal advice.

Crypto Fees

Crypto transactions are not covered by the flat Program fee described above and are subject to separate, transaction-based fees. Each crypto purchase or sale is priced with a spread built into the quoted price; the resulting fee is disclosed to the Client before the Client confirms the transaction.

USVC Fund Fees and Expenses

The Program’s subscription fee does not cover the USVC Fund’s fees and expenses, and Alinea charges no advisory fee on USVC Fund shares. A Client who holds USVC Fund shares indirectly bears the USVC Fund’s expenses, which reduce the value of the shares. According to the USVC Fund’s prospectus dated July 28, 2026, total annual expenses are 4.55% of net assets before a fee waiver and 2.50% after it, including a management fee of 1.00%. The waiver is set to run through November 24, 2027 and may end, and the USVC Adviser can recoup waived expenses for up to three years. The private funds in which the USVC Fund invests also charge their own fees, which are in addition to the USVC Fund’s fees and reduce returns.

No commission or sales load applies to Clients. The USVC Fund’s expenses still apply. A 2.00% repurchase fee applies to shares sold back within one year of purchase. The USVC Fund’s board has waived this fee for now and can end the waiver.

AngelList pays Alinea 0.40% of USVC Fund assets each year, out of the USVC Fund’s management fee. Clients do not pay this amount separately. It may give Alinea a reason to make the USVC Fund available to Clients. See Item 9.

Termination of Alinea Subscription and Investment Accounts

A Client’s “subscription” refers to the Client’s access to the Alinea App.

If a Client’s subscription payment does not process, for example due to lack of funds in a Client’s bank account, the Client will continue to have full access to the App. If payment is not resolved within 30 days, the subscription is automatically cancelled.

A subscription is cancelled either automatically, as described above, or when the Client affirmatively elects to cancel. If a Client elects to cancel their subscription, the Client will continue to have access to all of the features of the App and will pay an administrative fee as described more fully below.

In general, fees are paid in advance and are non-refundable. If a Client cancels their subscription, Alinea continues to exercise discretionary authority over the Client’s account and to provide the investment management services described in this brochure.

If a Client does not transfer their assets to another custodian within 30 days after cancellation, an administrative fee applies as described below:

• No fee while the subscription is active.
• No fee if the total investment account balance is $20 or below.
• Above $20 and up to $6,000: a flat $5 per month.
• Above $6,000: .0833% per month. For example, a $10,000 balance is charged $8.33 per month.

The administrative fee is debited from the investment account. If there is not sufficient cash available to cover it, shares may be sold to generate cash solely for that purpose.

Compensation for Recommending This Program

No Alinea employee or representative is compensated for recommending this Program to a particular Client; Clients enroll directly through the Alinea App. Alinea does compensate existing Clients who refer new Clients to the Program under the refer-a-friend arrangement described in Item 9.

Item 5: Account Requirements and Types of Clients

Alinea provides investment advisory services to individuals, including for their IRAs. There is no account size minimum. USVC Fund shares are available only to eligible Clients in taxable accounts, as described in Item 4.

Item 6: Portfolio Manager Selection and Evaluation

Selection and Evaluation of Alinea as Portfolio Manager

Alinea does not engage or evaluate unaffiliated portfolio managers; Alinea itself serves as the sole portfolio manager for all Program accounts. Investment decisions are generated by Alinea’s proprietary systems and, for certain strategies, by an artificial intelligence research process, each described in Item 4 above, based on information collected through the Alinea App. Because Alinea is both sponsor and portfolio manager, Alinea does not evaluate itself against unaffiliated managers, which the Firm addresses through the conflict-of-interest disclosure in Item 4 above.

Tailoring and Client-Imposed Restrictions

Alinea tailors each Client’s Automated Investing tier and initial Vibe Investing portfolio to the risk profile and preferences the Client provides through the Alinea App, as described in Item 4 above. Playlist Pro portfolios are standard for all investors. On a case-by-case basis, Clients can place reasonable restrictions on the types of investments that can be purchased or sold in their account so long as the restrictions are explicitly set forth or included as an attachment to the investment advisory agreement.

Differences From Non-Wrap Accounts

Alinea’s entire advisory business is conducted through this wrap fee Program; Alinea does not offer a separate, non-wrap advisory service. Because Alinea acts as both sponsor and portfolio manager, Alinea receives the entirety of the Program fee described in Item 4 above rather than sharing it with an unaffiliated portfolio manager.

Performance-Based Fees and Side-By-Side Management

Alinea does not accept performance-based fees and does not engage in side-by-side management.

Methods of Analysis, Investment Strategies and Risk of Loss

Clients are advised that investing in securities involves risk of loss that they should be prepared to bear.

Investment Strategies

Alinea monitors Client accounts and its algorithms for anomalies. As described in Item 4 above, the degree of Client involvement in ongoing investment decisions differs by product: for Automated Investing and Alinea-created playlists, a Client selects or is assigned a strategy and Alinea then exercises discretionary authority to implement and rebalance it without further Client consent per transaction; for Vibe Investing, a Client both selects the initial theme and constraints and may directly edit the resulting portfolio at any time. The Client is solely responsible for investment selections as there is no direct investment advice provided by a human.

Clients can also choose to search for other companies within the Alinea App to invest in. Some Client accounts are self-directed, some are managed by Alinea. Alinea’s investment advisory services are only offered through electronic means, e.g., via the Alinea App. Alinea does not interact with Clients in person, over the phone, in live chat or in any other manner regarding investments.

In order to meet its objective of providing Clients user-friendly access to investing, Alinea’s suggestions will be based on information collected by Alinea through the Alinea App, such as a Client’s answers to the Alinea personal financial summary questionnaire, which is part of the sign-up process.

Clients are requested to provide information, which in combination with other available Client information collected through the Alinea App, guides Alinea in making suggestions for that particular investor. Alinea makes use of an algorithm to process a Client’s answers to a series of questions and to make an investment suggestion. The accuracy of the data provided by the Client is important to their investment suggestion. Alinea does not verify the information received from the Client. Alinea is expressly authorized to rely on information provided by the Client when making investment suggestions.

Investment advisory services are limited to account(s) of Clients maintained on the Alinea App and do not take into consideration Client accounts held outside of Alinea. Alinea does not consider a Client’s personal tax situation when making investing suggestions. Clients should consult with their own tax advisor when considering investing for their own account.

We currently offer discretionary and non-discretionary investment management services. Clients can retain full investment discretion over the implementation of investment decisions of each investing suggestion. Clients are also free to purchase other stock offered by Alinea that have not been recommended or offered based on a Client’s interests. Clients are free to accept or reject Alinea’s initial strategy assignment and may choose whether to invest in a playlist. Once a Client invests in Vibe Investing or an Alinea-created playlist, later changes to target weights are made by AI and applied to the Client’s account automatically under the discretionary authority the Client grants Alinea (see Investment Discretion below); a Client may stop investing in a playlist at any time.

Following are some of the risks associated with Alinea’s investment strategy:

Market Risk

The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad.

Domestic Equity Market Risks

Under strategies utilizing equity securities, Clients are subject to the risk that stock prices may fall over short or extended periods of time. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. These factors contribute to price volatility, which is the principal risk of investing in equity securities.

Dollar-Based Transactions and Fractional Shares

A fractional share program allows Clients to purchase securities in dollar amounts rather than share quantities. Trading in fractional shares has unique risks and limitations that Clients should understand prior to participation. Fractional shares may not be liquid. Fractional shares are not transferable. In the event of an account closing or transfer to another firm, the fractional shares will likely need to be liquidated, resulting in potential fees. Fractional shares cannot be put into certificate form and mailed. Holders of fractional shares will not have voting rights for the fraction of a share owned, even if more than .50 shares are in their account.

Investment Strategy and Method of Analysis Material Risks

We cannot guarantee that an investment objective or planning goal will be achieved. As an investor, each Client must be able to bear the risk of loss that is associated with their account, which may include the loss of some, or all principal invested.

Company Risk

When investing in securities, there is always a certain level of company or industry specific risk that is inherent in each company or issuer. For example, there is the risk that a company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification.

Inflation Risk

When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation.

Use of Algorithms

Alinea incorporates computer-based technology to make investment suggestions primarily through the use of algorithms. Clients accept or reject these suggestions, such as the initial strategy assignment, and may stop investing in a playlist at any time. Changes to the algorithmic code could have material effects on a Client’s stock suggestions. Alinea’s algorithms may not perform as intended for a variety of reasons, including but not limited to incorrect assumptions, changes in the market, and/or changes to data inputs. Alinea may periodically modify these algorithms, or a computer system’s code or underlying assumptions, and these changes may have unintended consequences. Additional information regarding relevant considerations for Clients considering an automated digital investment advisory program (sometimes referred to as a “robo adviser”) is contained in the Investor Bulletin from the Securities and Exchange Commission available at https://www.sec.gov/oiea/investor-alertsbulletins/ib_roboadvisers.html.

Artificial Intelligence and Large Language Model Portfolio Management

Certain Alinea strategies, including Vibe Investing, AI Playlists, and Thematic Playlists, are constructed and periodically rebalanced by an artificial intelligence system, including large language models, without review or approval by an Alinea employee before changes take effect, and the changes are applied to Client accounts automatically under the discretionary authority Clients grant Alinea (see Investment Discretion below). This creates risks beyond those of Alinea’s rules-based algorithms described above, including: the AI may generate inaccurate, incomplete, or fabricated information, including in the rationales and reports provided to Clients, and may misinterpret or place undue weight on a news article, data source, or event; the AI’s stock or weighting decisions are drawn from a limited set of internet sources at a point in time and may not reflect the most current, complete, or accurate available information; a thematically selected portfolio (such as Vibe Investing) may be less diversified, and therefore more volatile, than a broadly diversified portfolio, regardless of the Client’s selected risk preference; the AI’s behavior may change over time as the underlying model, prompts, or data sources are updated, in ways that are difficult to predict or fully test in advance; and automated safeguards intended to catch inaccurate or inappropriate AI output may not catch every error. Clients should evaluate AI-managed strategies with these additional risks in mind and should not assume that an AI-generated rationale or report reflects a comprehensive or verified analysis. Alinea relies on large language models developed and operated by third parties, including OpenAI and Anthropic. These companies are not affiliated with Alinea, are not advisers to Clients, and may change, restrict, or discontinue their models or terms of use at any time, which could affect Alinea’s strategies.

Copy-Traded Playlist Data Risk

Copy-Traded Playlists are based on estimated holdings derived from periodically available public filings, which may be reported on a lag and may not reflect a tracked company’s or individual’s current holdings, short positions, or derivatives exposure. A playlist’s own target weights may update more frequently than the underlying filing data itself, meaning several updates in a row may mirror the same, unchanged filing.

Cybersecurity Risk

The information and technology systems of Alinea, as well as of key service providers, including third-party vendors, central agents, exchanges, clearing houses, and other financial institutions (including the custodian), are vulnerable to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Alinea and Client accounts could be adversely impacted if any of the aforementioned parties is the subject of a cyber-attack or other information security event. Although Alinea has implemented various measures designed to seek to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, it may be necessary for Alinea or a service provider to make a significant investment to fix or replace them and to seek to remedy the effect of such issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in Alinea’s ability to transact business on behalf of its Clients and could result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information. While many investment advisers are subject to the same or similar risks in respect of their operations, these risks are particularly acute with respect to Alinea due to Alinea’s fundamental dependence on technology.

Cash Sweep Program Risk

Cash balances swept through DriveWealth’s Bank Sweep Deposit Program are held at third-party banks, not at DriveWealth as broker-dealer, and are not covered by SIPC. FDIC insurance on swept balances is subject to per-bank, per-ownership-category limits and may be reduced if a Client holds other deposits at the same bank outside the program. Interest rates on swept balances fluctuate and may be lower than rates available through other cash alternatives. Program Banks may, though rarely do, impose up to a seven-day delay on withdrawal requests. DriveWealth may modify or terminate the program, or add or remove Program Banks, without Client consent.

Research Data Risk

When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. Therefore, while our firm makes efforts to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the investment management of an account.

Limited Nature of the Suggestions

The use of algorithms carries the risk that changes to the algorithm’s code may not have the desired effect with respect to a Client’s account. While this risk increases if changes to an algorithm are insufficiently tested prior to implementation, even extensively tested changes may not produce the desired effect over time. The Alinea App relies on a limited universe of inputs to generate, from a limited universe of possible outputs, a stock suggestion for each Client to accept or reject. In particular, the Alinea App currently generates suggested stock purchases based on a Client’s response to questions provided by the Client through the Alinea App. Alinea does not verify the completeness or accuracy of such information or consider any information regarding outside assets, concentration, debt, or other accounts a Client may have with any third party. The functionality of the Alinea App is partly dependent upon information provided by the third-party custodian, and other external sources, meaning that performance of the Alinea App could be impacted by issues with the delivery, or the accuracy of the information provided.

Limited Nature and Scope of the Service

We do not provide comprehensive financial or tax planning or legal advice. Clients should seek the advice and counsel of their own tax, financial, and legal advisers. Alinea only provides stock suggestions to individual investors. This includes IRAs. We do not provide investment advice to other tax-exempt investors. We are not responsible for withholding any tax penalties that may apply to our Clients or for any state or federal income tax withholding, except as may otherwise be required by applicable law.

Alinea’s suggestions are limited based on the information Clients provide through the Alinea App, the limitations of which are further discussed above. Clients should take into consideration the limited nature of the service in evaluating the suggestions provided through the Alinea App. Furthermore, the service: (a) is not a complete investment service; (b) does not account for multiple investment goals; (c) does not consider outside assets, concentration, debt, or other accounts a Client may have with any third party; (d) offers a limited number of investments; (e) may not be suitable for all investors; and (f) relies on the information provided by Clients in providing investment services and does not verify the completeness or accuracy of such information.

There could be one or more products available in the investment community that are more appropriate than the investment products made available through the Alinea App. Given the inherent limitations of the service, Clients should carefully consider whether our service is the right investment solution for their savings and investing needs.

Risk of Loss

We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. You need to understand that suggestions made for your account by us are subject to various market, currency, economic, political, and business risks. Despite our best efforts, the investment suggestions we make for you will not always be profitable nor can we guarantee any level of performance. Alinea does not represent, warrant, or imply that the services or methods of analysis used can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from major losses due to market corrections or crashes. No guarantees are offered that Clients’ goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by Alinea will provide a better return than other investment strategies.

Investments in securities and other financial instruments involve risk of loss that investors must be prepared to bear. Below are certain risks associated with the strategies discussed above. This is a summary only. The specific risks applicable to a Client will depend upon a range of factors.

Cryptocurrency Risk

Cryptocurrency is a speculative and highly volatile asset class, is not subject to the same regulatory protections as securities, and its value may decline substantially or become worthless. Crypto assets are held with a third-party custodian, ZeroHash, LLC, separate from the custodian used for securities, and Clients are subject to the operational, cybersecurity, and counterparty risk of that custodian in addition to the risks described elsewhere in this brochure. Because crypto sale proceeds are not available until the underlying ACH transfer settles, Clients may be unable to access invested funds for several business days after initiating a sale, including during periods of market volatility.

USVC Fund Risks

Illiquidity. USVC Fund shares are not listed on an exchange and cannot be sold back to the USVC Fund on demand. The USVC Fund may offer to buy back up to about 5% of its shares in a quarter, at its board’s discretion. Offers are not guaranteed, may be smaller or prorated, and may be priced below net asset value (NAV), so a Client may be unable to sell when wanted. A Client may be unable to access invested money for an extended period, and USVC Fund shares may not be available to satisfy withdrawals or Alinea’s cash reserve requirement. Clients should invest only money they will not need soon.

Valuation. Most USVC Fund holdings are private and valued by the USVC Adviser using estimates, including underlying fund managers’ reported values and recent transactions. Values can change and may not match sale prices. A Client’s purchase price is the next NAV calculated after the order.

Other risks. The USVC Fund is new, is non-diversified, and invests at least 25% of its assets in the technology sector. Private companies and funds are speculative and can lose all of their value. The USVC Fund may borrow after its first year and may buy secondary interests, and holdings may be subject to lock-ups after an IPO. Its fees and the fees of the funds it holds reduce returns (see Item 4). Distributions are taxable, even when reinvested. A Client can lose some or all of the investment. USVC Fund shares are not FDIC insured and are not a bank deposit. This is a summary only; read the prospectus before investing.

Regulatory Changes

It is possible that changes in applicable laws and regulations may affect Alinea’s operations. The consequences of additional regulation on the liquidity of markets and the functioning of the service (and, possibly, on Alinea itself) cannot be predicted and may materially affect the investment advisory services offered by Alinea.

Taxes

You are responsible for all tax liabilities and tax-return filing obligations arising from the transactions in your Alinea account. We do not, and will not, offer tax advice to you and we strongly encourage you to seek the advice of a qualified tax professional. You should also understand that we are not responsible for attempting to obtain any tax credit or similar item or preparing and filing any legal document (including, but not limited to, proof of claim) on your behalf.

Retirement Account (IRA) Considerations

IRAs have rules that apply to the Client, not to Alinea. Clients are responsible for determining whether they are eligible to contribute to their type of IRA and for staying within annual contribution limits across all of their accounts. Excess contributions, early withdrawals, and distributions that do not meet the requirements for the account type can result in taxes and penalties. For example, Roth IRA earnings are generally tax-free only if the distribution is qualified (generally after age 59½ and five years after the first Roth IRA contribution). Required minimum distributions and conversions have their own rules and deadlines. Withdrawing or transferring IRA assets may require selling investments, and the settlement timing described in Item 4 applies. Alinea does not provide tax advice; Clients should consult a tax professional.

Investment Discretion

Discretionary Authority for Trading

If you are participating in our asset management services, upon receiving your written authorization via our executed investment advisory agreement, we will maintain trading authorization over your designated account and can also implement trades on a discretionary basis. When discretionary authority is granted, we will have the limited authority to determine the type of securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or exchanged for your portfolio without obtaining your consent for each transaction.

Playlist Pro (AI Playlists, Thematic Playlists, and Copy-Traded Playlists) is managed on a discretionary basis. Changes to a playlist’s target weights, and the resulting trades in a Client’s account, are made automatically under this authority. Clients may not modify the target weights of these playlists.

Clients who do not grant discretionary authority may instead use the self-directed feature of the Alinea App to create customized portfolios. Alinea does not use telephone contact to obtain non-discretionary approvals; all Client interaction, including any approval requests, occurs through the Alinea App, consistent with the all-electronic service model described throughout this brochure.

Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a response to our request immediately, the timing of trade implementation can lead to an adverse impact where we cannot achieve the optimal trading price.

Clients may directly edit their Vibe Investing portfolios at any time, although the AI’s monthly adjustments may overwrite those edits, and Clients may indicate reasonable restrictions on the management of their account.

Alinea does not exercise discretion over USVC Fund shares. A Client decides whether to buy or sell them, and Alinea does not monitor, rebalance, or manage a Client’s USVC Fund holding.

Voting Client Securities

Alinea does not have, and will not accept, authority to vote (“proxy”) Client securities. Generally, Clients receive their proxies or other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender.

Item 7: Client Information Provided to Portfolio Managers

As sponsor and sole portfolio manager, Alinea has direct access to all Client information collected through the Alinea App, including responses to the onboarding questionnaire and any updates a Client makes to that information. This information is used directly to generate and periodically update each Client’s portfolio suggestions. No information is transmitted to an unaffiliated portfolio manager. Clients are responsible for promptly updating their information through the Alinea App; Alinea does not independently verify this information.

Item 8: Client Contact with Portfolio Managers

Alinea does not make its portfolio management personnel available for direct Client contact. All Client communication regarding portfolio management occurs through the Alinea App or, for account service matters, through Alinea’s electronic customer support channels. Alinea does not restrict a Client’s ability to contact Alinea generally, but Clients should not expect a live consultation with the individual(s) responsible for the Program’s investment decisions.

Item 9: Additional Information

A. Disciplinary Information

There are no criminal or civil actions to report. There are no administrative proceedings to report. There are no self-regulatory organization proceedings to report.

Other Financial Industry Activities and Affiliations

Alinea is not registered as, and does not have a pending application to become, a broker-dealer, a representative of a broker-dealer, a Futures Commission Merchant, a Commodity Pool Operator, or a Commodity Trading Advisor.

Alinea Advisory Services LLC and Alinea Futures, LLC are affiliated entities. Alinea Futures, LLC is registered as an Introducing Broker with the National Futures Association but does not currently conduct any futures-related business, and Alinea does not refer Clients to or receive compensation from Alinea Futures, LLC. Certain officers or employees may serve both entities; all remain subject to Alinea’s Code of Ethics and fiduciary duty to act in Clients’ best interests regardless of any affiliate role. If Alinea Futures, LLC commences business activities, Alinea will evaluate and disclose any resulting conflicts at that time. We do not utilize nor select other advisers or third-party managers.

B. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Alinea’s ethical and legal duty is to act at all times as a fiduciary to its Clients. This means that Alinea puts the interests of its Clients ahead of its own and seeks to manage any perceived or actual conflict of interest that may arise in relation to our advisory services. Alinea has adopted a Code of Ethics (“COE”), which is designed to ensure that it meets its fiduciary obligation to Clients, enhances its culture of compliance within the Firm, and detects and prevents any violations of securities laws.

Alinea’s COE establishes standards of conduct for Alinea’s officers and employees (“Supervised Persons”) and is consistent with the Code of Ethics requirements of Rule 204A-1 under the Investment Advisers Act of 1940, as amended. The COE includes general requirements that all Supervised Persons comply with their fiduciary obligations to Clients and applicable securities laws, and also contains specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of Client information. Alinea’s COE will be provided to any Client or prospective Client upon request.

Alinea and its employees may purchase, sell, or otherwise enter into transactions for their own accounts in securities and other instruments. Prior to, or simultaneously with, or after such transactions, Alinea may, for its Clients, via the Alinea App, provide suggestions for purchasing stock involving any of these same securities or other instruments, and any related securities or instruments (including securities issued by the same issuer, options on such securities or instruments, and instruments convertible into such securities or instruments). Alinea has adopted the Code of Ethics discussed above to address potential conflicts. Subject to certain restrictions, Alinea and each of its employees personally may at any time hold, acquire, increase, decrease, dispose of, or otherwise deal with positions in investments in which a Client may have an interest from time to time. Alinea has no obligation to recommend or acquire for a Client account a position in any security which it acquires or recommends on behalf of another Client, or which an employee acquires for his or her own account.

Transactions effected for all Client accounts are not aggregated or combined with employee’s personal orders but executed according to DriveWealth’s disclosures and are self-directed by the Client. In all instances Alinea will act in the best interests of its Clients.

Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that the Client should be prepared to bear.

Review of Accounts

Alinea provides its Clients with access to their account information via the Alinea App. DriveWealth, the Client’s custodian, is required to send account statements directly to Clients no less frequently than quarterly. These statements and reports will be sent directly by DriveWealth to Clients at their respective addresses of record or delivered electronically.

On a periodic basis, Alinea will contact each Client to request that the profile information previously provided be updated, if appropriate due to changes in circumstance. However, Clients must promptly update the financial and other information they previously inputted through the Alinea App if any of the financial or other information changes. A Client’s failure to timely update this information could materially impact the quality and applicability of the suggestions produced by Alinea.

Client Referrals and Other Compensation

Except for the USVC revenue share described below, Alinea does not receive compensation from other entities for providing advisory services to Clients.

USVC Revenue Share

AngelList, the USVC Adviser, pays Alinea 0.40% of USVC Fund assets held by Clients each year, out of the USVC Fund’s management fee. Clients do not pay it separately, and Alinea charges no advisory fee on USVC Fund shares. This is a conflict of interest: Alinea earns more when Clients hold USVC Fund shares than when they hold other investments, which may give Alinea a reason to make the USVC Fund available. Alinea addresses this by disclosing it here and in Item 4, and by not advising on whether or how much to buy.

Refer-a-Friend Program

Alinea offers a refer-a-friend program under which an existing Client (the “Referrer”) who refers a new Client (the “Referee”) to Alinea, and the Referee, may each receive a $20 cash incentive in connection with the referral.

This compensation is below the de minimis compensation threshold under Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”) ($1,000 or less to a given promoter during the preceding 12 months). Alinea has determined that the Referrer’s compensation therefore is not subject to the Marketing Rule’s written agreement and disqualification-review requirements that apply to larger promoter arrangements. Alinea nonetheless discloses this arrangement here because the Referrer receives compensation in exchange for recommending Alinea to a prospective Client, which creates a conflict of interest: a Referrer has a financial incentive to make the referral regardless of whether Alinea’s Program is suitable for the person being referred, which may make the Referrer’s recommendation less objective than an unpaid recommendation would be. The Referee’s $20 incentive is a related conflict, in that it may cause a prospective Client to open an account in part because of the cash incentive rather than based solely on the Program’s suitability for that person.

Custody

All securities and cash are maintained with DriveWealth as the qualified custodian. You retain ownership of all cash, securities, and other instruments in your account. However, since the Firm has the ability to withdraw, or instruct the withdrawal of funds, for the purpose of paying the subscription fees, the Firm is deemed to have custody. DriveWealth will send you account statements which you should carefully review. The Firm relies on DriveWealth to price and value assets and provide cost basis information for tax reporting of your assets.

Client securities are held by DriveWealth, LLC and Client cryptocurrency is held by ZeroHash, LLC, in each case as an independent, unaffiliated custodian; Clients should expect to receive statements from each custodian applicable to the assets held there.

USVC Fund shares are held through DriveWealth. Alinea is not the custodian of USVC Fund shares. DriveWealth sends Clients their statements.

Cash swept through DriveWealth’s Bank Sweep Deposit Program is held at unaffiliated Program Banks rather than at DriveWealth directly; DriveWealth continues to act as Clients’ agent with respect to these balances.

Financial Information

Alinea does not charge advisory fees. Clients will only incur subscription fees and other investing related fees as described in Item 4. Alinea does not require prepayment of subscription fees by Clients of more than $1,200 and six or more months in advance, and is therefore not required to include a balance sheet for its most recent fiscal year.

Alinea is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to Clients and has not been the subject of a bankruptcy petition at any time during the past ten years.

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