Background BNY Mellon Investor Solutions, LLC (the “Firm”) is a limited liability company organized under the laws of the State of Delaware. We are wholly owned by MBC Investments Corporation, which in turn is a wholly owned subsidiary of The Bank of New York Mellon Corporation (“BNY Mellon”). The Firm was formed in June 2015. Effective January 1, 2020, the Firm was renamed BNY Mellon Investor Solutions, LLC. Advisory Business The Firm is an investment adviser registered as such with the U.S. Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940, as amended (“Advisers Act”). We provide Customized Portfolio Management and Outsourced Chief Investment Officer (“OCIO”) Services to institutional clients, both in the U.S and globally. Our discretionary portfolio management and non-discretionary advisory services include the following capabilities: Portfolio Design (asset allocation and investment policy construction); Manager Research & Selection (investment due diligence and operational due diligence); Investment Analytics (performance & risk reporting and portfolio stress testing and scenario analysis); Economic and Capital Market Research; and Discretionary Portfolio Management. Our advisory services are also available on a standalone basis. We provide advice with respect to a wide variety of asset classes by investing directly in securities or by allocating assets to underlying investment managers (“Managers”). Managers may invest in securities and other instruments, including derivative instruments through the use of separately managed accounts or participation in underlying pooled investment vehicles (“Underlying Funds”) including, but not limited to, collective investment trusts, mutual funds, exchange-traded funds (“ETFs”) and private funds. We make (or recommend) allocations for each asset class and strategy, according to designated investment objectives, outcomes, styles and strategies. We primarily employ a “multi-asset” approach which utilizes non-affiliated and affiliated investment managers. The selection of investment strategies and vehicles is based on a combination of potential returns related to both the strategy as well as the asset class that the strategy is benchmarked to, risk levels, fees, as well as general fit with the objectives of both the client and the overall strategy. Refer to Item 8 for a discussion of the Manager selection process. Investment Guidelines The Firm offers investment advisory services tailored to meet clients’ investment goals. With respect to separate accounts, we work with clients to create investment guidelines mutually acceptable to the client, the Manager(s) and the Firm. When creating investment guidelines, clients may impose investment restrictions in certain individual securities or types of securities. If consistent with the client’s investment objectives, we will invest client assets in collective investment funds for which The Bank of New York Mellon, an affiliated New York State chartered bank (the “Bank”), serves as trustee and account custodian. The collective investment funds are further described in the Schedule A of the applicable bank collective investment fund plan documents. We also manage similar portfolios as separate accounts investing clients’ assets in UCITS funds or mutual funds. We also provide investment management to our affiliates’ seed capital programs. We are responsible for the hedging component of the seed capital program, which is managed using derivatives instruments. Model Delivery In certain circumstances, we act as a nondiscretionary adviser or sub -adviser in programs (“Model Delivery Programs”) in which our services are limited to the creation and maintenance of a model portfolio for an investment adviser or sponsor

providing investment advisory and asset allocation services to its clients in a wrap fee program. In such cases, it is expected that the recommendations of our model portfolio will be implemented, subject only to differences resulting from individual investment guidelines or cash or other needs of the particular Model Delivery Program client. With respect to these accounts, we generally do not know the identity of the underlying clients, do not act as a fiduciary to such clients, do not have access to the underlying clients’ account information, do not trade for underlying clients participating in the account and do not perform brokerage, custody, suitability reviews or any other administrative functions. Additionally, for Model Delivery Programs, we are not responsible for voting proxies that relate to assets held in any underlying client’s account or the account’s compliance with applicable laws and regulations. In certain circumstances, we may also provide Model Delivery Program services to advisers or sub-advisers for clients other than wrap fee accounts. Our relationships with sponsors may create certain conflicts of interest for the sponsors and for us. We provide investment advisory services to certain affiliated sponsors, including BNY Mellon Securities Corporation (“BNYMSC”). If the sponsor is affiliated with us, the sponsor may have an incentive to give us access to the account and to steer clients toward us, based on the affiliation rather than based on our expertise, performance or a client’s needs. Dual Officers Certain of our personnel act as officers or employees of one or more of our affiliates (“dual officers”), including the Bank, BNY Mellon, N.A. and BNY Mellon Investment Adviser, Inc. (“BNYMIA”) an affiliated registered investment adviser, for the purpose of performing investment management and related functions. In their capacities as dual officers, these personnel provide discretionary investment advisory services to certain clients and also to certain collective investment funds of the Bank and we receive a fee for these services. When the Firm’s personnel act as dual officers or employees of the Bank , BNY Mellon Investment Adviser, Inc. or BNY Mellon, N.A. in performing investment management and related functions, the Firm receives compensation. In certain instances, we may enter into revenue sharing arrangements with affiliates where we may receive a portion of the fee or bill the entire fee to the client and reimburse the affiliate for amounts in excess of our revenue share. When we share personnel with our affiliates pursuant to these arrangements, such personnel will be subject to the Firm’s compliance policies and procedures when acting on behalf of the Firm, and subject to the policies and procedures of the affiliate when acting on behalf of that affiliate. Pursuant to investment management agreements between the Firm and certain of our affiliates, we may provide investment advisory services to certain of our affiliates in the form of separately managed accounts. Please see Item 10 for more information regarding our affiliates. As of December 31, 2022, the Firm had total assets under management or advisement of $27,057,147,776. This figure is comprised of: $852,976,346 managed on a discretionary basis; $16,745,882,558 managed on a non-discretionary basis, including accounts for which we provide a model of securities but do not arrange or effect the purchase or sale of the securities, as further described in Item 12 of this Brochure; and $9,458,288,872 managed by certain of our employees in their capacity as dual officers of BNY Mellon Investment Adviser, Inc. and the Bank. The assets under management figures referenced above differ from the regulatory assets under management required to be reported in Form ADV Part 1A.