Registered Investment Advisory Agreement

This Registered Investment Advisory Agreement (“Agreement”) is made between Kenai Investments Inc., a Registered Investment Advisor (“Advisor”), and the client (“Client”). By purchasing or using services at GradeYour401k.com or PilotYour401k.com, Client acknowledges and agrees to the terms of this Agreement.

1. Scope of Services

Advisor provides limited-scope, non-discretionary analysis of Client’s self-directed employer retirement plan using models and public market data. Deliverables may include an indicative grade, a model allocation comparison, and an optional PDF report. Advisor does not take custody of assets, execute trades, or exercise discretion over Client accounts.

2. No Personal Financial Planning

The analysis is educational and model-based. It is not a comprehensive financial plan, tax advice, legal advice, or individualized investment recommendation. Client remains solely responsible for all investment decisions and for verifying plan-specific constraints, fees, and trading limitations before implementing any changes.

3. Fees

Fees are posted at checkout and may include a one-time report fee and/or an annual subscription with scheduled updates. Fees are earned when paid and generally non-refundable once analysis begins or the report is delivered, except as required by applicable law.

4. Data & Third-Party Services

Advisor may use third-party market data providers and payment, email, and hosting platforms. Accuracy and availability of third-party data and services are not guaranteed. Client authorizes Advisor to use Client information as reasonably necessary to provide services and fulfill orders, subject to the Privacy Policy.

5. Client Responsibilities

• Provide accurate, complete inputs (provider, holdings, etc.).
• Review plan rules, fees, and trading limitations before acting.
• Understand that market conditions change and models may be updated.
• Retain copies of any reports and confirmations for records.

6. Limitations & Disclaimers

Investing involves risk, including loss of principal. Past performance does not guarantee future results. The service may include model assumptions and public indicators (e.g., moving averages) that are subject to error. Advisor is not responsible for Client implementation, platform outages, or consequences of Client actions.

7. Regulatory

Kenai Investments Inc. is a Registered Investment Advisor. Registration does not imply a certain level of skill or training. Client may request Advisor’s Form ADV Part 2A and other company documents by visiting www.kenaiinvest.com.

8. Termination

Either party may terminate prior to report delivery. Fees for delivered or commenced work are non-refundable unless otherwise required by law.

9. Governing Law

This Agreement is governed by the laws of the State of Texas, without regard to conflicts of law principles.

10. Acceptance

By checking “I agree” and completing payment, Client acknowledges reading and agreeing to this Agreement.