ZOE Financial, Inc.

• A percentage of assets under your management
• Other

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated August 12, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$283,473,191 as of October 2026, filing dated October 1, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Financial planning services
• Portfolio management for individuals and/or small businesses
• Selection of other advisers (including private fund managers)
• Other

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2019 (6 years)

Employees

Total: 45. Performing investment advisory functions: 2.

Wrap fee program participation

Yes.

Custodians (Schedule D, Section 5.K(3))

Apex Clearing CorporationCharles Schwab & Co., Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

States registered or notice-filed

51 states or jurisdictions

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SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

4 Reports 4 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.C(1) Has the SEC or the CFTC ever found that the firm or an advisory affiliate made a false statement or omission?
• 11.C(2) Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
• 11.C(4) Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.C(5) Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an activity?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Total employees: 31 in October 2021 and 45 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. October 2026
   • Item 11 disclosure answers changed: 4 yes answers, previously 0 (now yes: 11.C(1), 11.C(2), 11.C(4), 11.C(5)).
2. April 2026
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.