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Provide research and information on performance and fund management changes Provide personal consultations as necessary upon your request or as needed.You are obligated to notify us promptly when your financial situation, goals, objectives, or needs change.Model Portfolio Management ServicesWe offer one model portfolio strategy:Heights Investment Model Portfolio StrategyThe objective of the Heights Investment Partner’s model portfolio is to compound capital through longterm ownership of a collection of exceptional businesses. These businesses are characterized by attractiveeconomics, strong competitive positioning, capable management teams, and exposure to favorable longterm trends. The model portfolio will usually own between ten and twenty-five equity positions at a timeand exhibit relatively low turnover. We believe this structure and style is conducive to efficient long-termcompounding of capital as it reduces reinvestment risk and lowers frictional taxes. We also can utilizeshort selling when appropriate, but it will not be a core focus of the portfolio.You shall not have the ability to impose restrictions on the management of your account.Under certain conditions, securities from outside accounts may be transferred into your advisory account;however, we may recommend that you sell any security if we believe that it is not suitable for the currentrecommended investment strategy. You are responsible for any taxable events in these instances. Certainassumptions may be made with respect to interest and inflation rates and the use of past trends andperformance of the market and economy. Past performance is not indicative of future results.If you decide to implement our recommendations, we will help you open a custodial account(s). The fundsin your account will generally be held in a separate account, in your name, at an independent custodian,and not with us. We require that you use TD Ameritrade Institutional, Division of TD Ameritrade, Inc.,member FINRA/SPIC (“TD Ameritrade”) as your custodian.You will enter into a separate custodial agreement with the custodian which authorizes the custodian totake instructions from us regarding all investment decisions for your account. We will select the securitiesbought and sold and the amount to be bought and sold, within the parameters of the objectives and risktolerance of your account. You will be notified of any purchases or sales through trade confirmations andstatements that are provided by the custodian. These statements list the total value of the account,itemize all transaction activity, and list the types, amounts, and total value of securities held. You will atall times maintain full and complete ownership rights to all assets held in your account, including the rightto withdraw securities or cash, proxy voting and receiving transaction confirmations.We manage assets on a discretionary basis, which means you have given us the authority to determinethe following with/without your consent: Securities to be bought or sold for your accountHeights Investment PartnersADV Part 2AJanuary 2022Page 5 of 21 2010 – 2017 Red Oak Compliance Solutions LLC

Amount of securities to be bought or sold for your account Broker-dealer to be used for a purchase or sale of securities for your account Commission rates to be paid to a broker or dealer for your securities transaction.Trading may be required to meet initial allocation targets, after substantial cash deposits that requireinvestment allocation, and/or after a request for a withdrawal that requires liquidation of a position.Additionally, your account may be rebalanced or reallocated periodically in order to reestablish thetargeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on theschedule we have determined together. You will be responsible for any and all tax consequences resultingfrom any rebalancing or reallocation of the account. We are not tax professionals and do not give taxadvice.We are available during normal business hours either by telephone, fax, email, or in person byappointment to answer your questions.Tailored Asset Management ServicesIn certain circumstances, we will offer tailored asset management services as part of the active assetmanagement process, we will meet with you to discuss your financial circumstances, investment goalsand objectives, and to determine your risk tolerance. We will ask you to provide statements summarizingcurrent investments, income and other earnings, recent tax returns, retirement plan information, otherassets and liabilities, wills and trusts, insurance policies, and other pertinent information.Based on the information you share with us, we will analyze your situation and tailor a portfolio withappropriate asset allocations and investment strategy[ies]. Our recommendations and ongoingmanagement are based upon your investment goals, objectives and risk tolerance. We will monitor theaccount. We will be reasonably available to help you with questions about your account.* Please note that pursuant to the investment advisory agreement you are obligated to notify us promptlywhen your financial situation, goals, objectives, or needs change. *You shall not have the ability to impose restrictions on the management of your account.ERISA FiduciaryHeights Investment Partners understands and attests that they are an ERISA fiduciary as defined in theFiduciary Rule under the Employee Retirement Income Security Act of 1974 and the Internal RevenueCode of 1986. Heights Investment Partners adheres to the Impartial Conduct Standards (including the“best interest” standard, reasonable compensation, and no misrepresented information), as a conditionfor relying upon the Best Interest Contract Exemption and the Class Exemption for Principal Transactionsin Certain Assets Between Investment Advice Fiduciaries and Employee Benefit Plans and IRA during thetransition period from June 9, 2017, through January 1, 2018. This relates to all ERISA accounts includingIndividual Retirement Accounts (IRAs).Heights Investment PartnersADV Part 2AJanuary 2022Page 6 of 21 2010 – 2017 Red Oak Compliance Solutions LLC

Heights Investment Partners does not act as a discretionary investment manager of any Plan as definedin Section 3(38) of the Employee Retirement Income Security Act of 1974.Heights Investment Partners does not act as a non-discretionary investment manager of any Plan asdefined in Section 3(21) of the Employee Retirement Income Security Act of 1974.Assets Under ManagementAs of our most recent calculation on December 31, 2021, we provided asset management services for 91accounts, managing total assets of 57,624,301.Item 5 – Fees and CompensationWe provide asset management services for a fee.Either party may terminate the relationship with a thirty (30) day written notice. Upon termination of anyaccount, any fees that are due, but have not been paid, will be billed to you and are due immediately.Asset Management Fee ScheduleWe have a minimum account opening balance of 1,000,000, which shall be negotiable depending uponcertain circumstances. The fee charged is based upon the amount of money you invest. Multiple accountsof immediately-related family members, at the same mailing address, may be considered oneconsolidated account for billing purposes. Fees are charged quarterly, in arrears. Payments are due andwill be assessed on the last day of each quarter, based on the ending balance of the account undermanagement as of the end of month for the previous quarter. For qualified clients (clients with a NetWorth of 2,100,000 or with 1,000,000 invested with the Adviser) we will charge as follows:Qualified Clients:PercentagePortfolio Size (AUM)0.70 – 1.00%AllPlease note that qualified clients are subject to a performance fee as outlined in Item 6 below.For non-qualified clients (all other clients no matter their Net Worth or invested asset) we charge asfollows:Non-qualified Clients:PercentagePortfolio Size (AUM)1.00 – 1.20%AllThe fees shown above are annual fees and may be negotiable based upon certain circumstances. Noincrease in the annual fee shall be effective without prior written notification to you. We believe ourHeights Investment PartnersADV Part 2AJanuary 2022Page 7 of 21 2010 – 2017 Red Oak Compliance Solutions LLC

advisory fee is reasonable considering the fees charged by other investment advisers offering similarservices/programs.The fees we charge can be deducted directly from your account at the custodian. We will instruct thecustodian to deduct the fees from your account at the end of the quarter. This fee will show up as adeduction on your following quarter account statement from the custodian.All recommendations developed by us are based upon our professional judgment. We cannot guaranteethe results of any of our recommendations.Third Party FeesOur fees do not include brokerage commissions, transaction fees, and other related costs and expenses.You may incur certain charges imposed by custodians and other third parties. These include fees chargedby managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer andelectronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. We donot receive any compensation from these fees. All of these fees are in addition to the management feeyou pay us. You should review all fees charged to fully understand the total amount of fees you will pay.Services similar to those offered by us may be available elsewhere for more or less than the amounts wecharge. Our brokerage practices are discussed in more detail under Item 12 – Brokerage Practices.Other CompensationOur IARs do not receive additional compensation from sales of securities and/or investment products.Item 6 – Performance Based Fee and Side by Side ManagementWe charge performance-based fees (fees based on a share of capital gains, or capital appreciation of, theassets of a client). The S&P 500 total return (including dividends) is hereinafter referred to as the “hurdlerate.” If the performance of your investment since inception exceeds the hurdle rate (net of managementfees) and performance for the calendar year exceeds the hurdle rate (net of management fees) we willassess a performance fee at the end of the calendar year. The performance fee of 20% shall be negotiabledepending upon certain circumstances and will be assessed on whichever is less: – the percentage returnin excess of the hurdle rate for the calendar year (net of management fees), or the cumulative percentagereturn in excess of the hurdle rate since inception (net of management fees). The resulting fee (20% xpercentage outperformance) will be assessed on the ending account value at time of assessment.We will not assess the performance fee in years where your portfolio experiences a decline in value on anabsolute basis for the calendar year (i.e., negative performance). However, performance in years ofdecline will contribute towards cumulative performance since inception. In years where the S&P isnegative and the portfolio is positive, the charge will only be based on the percentage return above zero.There will be no annual assessment of the performance fee when the performance of your investmentsince inception is below the high-water mark – (i.e., underperforming the total return of the S&P 500 sinceinception, or negative on an absolute basis since inception). We will not charge a performance fee inrespect to any subsequent increases until such increases have caused your investment to exceed theHeights Investment PartnersADV Part 2AJanuary 2022Page 8 of 21 2010 – 2017 Red Oak Compliance Solutions LLC

hurdle rate cumulatively since inception (net of management fees). In the event that you makesubsequent deposits or withdrawals, we will adjust the High Water Mark to reflect those deposits orwithdrawals. This will be based on total average weighted cost (modified dietz method).You may become our client any time throughout the calendar year, and we will assess and charge ourperformance fee, if any, at the end of that calendar year, with a timeframe starting from when you beganthe performance-based fee relationship with us. We will adjust all performance fees payable on a prorata basis to reflect any deposits or withdrawals made within a calendar year. To account for depositsand withdrawals we measure performance using a money weighted return as calculated by the “ModifiedDietz Method.” Methodology available on request. Performance based fee relationship starts the day ofinitial investment. The beginning value used in performance calculations for the account and the S&P 500are based on the respective closing values prior to the day of initial investment. Performance calculationfor fees assessed on withdrawals are based off the most recent previous closing value at time ofnotification.Although performance fees are typically payable at the end of the calendar year, payments can beadvanced in the event that you make a withdrawal during the calendar year. If you decide to terminateyour performance-based fee relationship with us at any time during the calendar year and not at the endof the calendar year, we will assess and charge our performance fee, if any, at that point in time of thecalendar year and not at the end of that calendar year. Though the High Water Mark may increase ordecrease at any time during the remaining calendar year subsequent to such a termination of theperformance-based fee relationship, we will not subsequently recalculate the performance fee at the endof that year and we will not pay any associated refund due to the possibility of the High Water Mark thenincreasing further and negating any such performance fee calculated prior to the end of the year.We offer performance-based fee accounts to qualified clients only. As defined in 17 Code of FederalRegulations §275.205-3, the term qualified client means: (i) A natural person who, or a company that,immediately after entering into the contract has at least 1,000,000 under the management of theinvestment adviser; (ii) A natural person who, or a company that, the investment adviser entering into thecontract (and any person acting on his behalf) reasonably believes, immediately prior to entering into thecontract, either: (A) Has a net worth (together, in the case of a natural person, with assets held jointlywith a spouse) of more than 2,100,000. For purposes of calculating a natural person's net worth: (1) Theperson's primary residence must not be included as an asset; (2) Indebtedness secured by the person'sprimary residence, up to the estimated fair market value of the primary residence at the time theinvestment advisory contract is entered into may not be included as a liability (except that if the amountof such indebtedness outstanding at the time of calculation exceeds the amount outstanding 60 daysbefore such time, other than as a result of the acquisition of the primary residence, the amount of suchexcess must be included as a liability); and (3) Indebtedness that is secured by the person's primaryresidence in excess of the estimated fair market value of the residence must be included as a liability; or(B) Is a qualified purchaser as defined in section 2(a)(51)(A) of the Investment Company Act of 1940 (15U.S.C. 80a-2(a)(51)(A)) at the time the contract is entered into; or (iii) A natural person who immediatelyprior to entering into the contract is: (A) An executive officer, director, trustee, general partner, or personserving in a similar capacity, of the investment adviser; or (B) An employee of the investment adviserHeights Investment PartnersADV Part 2AJanuary 2022Page 9 of 21 2010 – 2017 Red Oak Compliance Solutions LLC

(other than an employee performing solely clerical, secretarial or administrative functions with regard tothe investment adviser) who, in connection with his or her regular functions or duties, participates in theinvestment activities of such investment adviser, provided that such employee has been performing suchfunctions and duties for or on behalf of the investment adviser, or substantially similar functions or dutiesfor or on behalf of another company for at least 12 months.Pursuant to section 205(e) of the Act, the dollar amounts specified in paragraphs (d)(1)(i) and (d)(1)(ii)(A)of 17 Code of Federal Regulations §275.205-3275.205-3 shall be adjusted by order of the Commission, onor about May 1, 2016 and issued approximately every five years thereafter. The adjusted dollar amountsestablished in such orders shall be computed by: (1) Dividing the year-end value of the PersonalConsumption Expenditures Chain-Type Price Index (or any successor index thereto), as published by theUnited States Department of Commerce, for the calendar year preceding the calendar year in which theorder is being issued, by the year-end value of such index (or successor) for the calendar year 1997; (2)For the dollar amount in paragraph (d)(1)(i) of 17 Code of Federal Regulations §275.205-3, multiplying 750,000 times the quotient obtained in paragraph (e)(1) of section 275.205-3 and rounding the productto the nearest multiple of 100,000; and (3) For the dollar amount in paragraph (d)(1)(ii)(A) of section275.205-3 multiplying 1,500,000 times the quotient obtained in paragraph (e)(1) of section 275.205-3and rounding the product to the nearest multiple of 100,000.Performance based fee arrangements may create an incentive for us to recommend investments whichmay be riskier or more speculative than those which would be recommended under a different feearrangement. Such fee arrangements also create an incentive to favor higher fee paying accounts overother accounts in the allocation of investment opportunities. We have procedures designed andimplemented to ensure that all clients are treated fairly and equally, and to prevent this conflict frominfluencing the allocation of investment opportunities among clients.Item 7 – Types of Client(s)We have a minimum account opening balance of 1,000,000, which shall be negotiable upon certaincircumstances.We provide management services to individuals, high net worth individuals, trusts, estates, corporationsand small businesses.Heights Investment PartnersADV Part 2AJanuary 2022Page 10 of 21 2010 – 2017 Red Oak Compliance Solutions LLC

Item 8 – Methods of Analysis, Investment Strategies and Risk of LossMethods of AnalysisWe use Fundamental Analysis as part of our overall investment management discipline; theimplementation of these analyses as part of our investment advisory services to you may include any, allor a combination of the following:Fundamental AnalysisFundamental analysis is a technique that attempts to determine a security’s value by focusing on theunderlying factors that affect a company's actual business and its future prospects. Fundamental analysisis about using real data to eval

Suite 210, Houston, TX 77007, or by phone at (713) 354-4911. Heights Investment Partners ADV Part 2A January 2022 Page 1 of 21 . We require that you use TD Ameritrade Institutional, Division of TD Ameritrade, Inc., member FINRA/SPIC ("TD Ameritrade") as your custodian.