A. Firm Morningstar Research Services LLC is a Delaware limited liability company formed in 2016, and is a wholly owned subsidiary of Morningstar, Inc. (“Morningstar”). Morningstar is a publicly traded company (NASDAQ Ticker: MORN) with Mr. Joseph Mansueto, Executive Chairman of Morningstar, holding more than 35% of Morningstar’s outstanding shares. Because of that ownership, Mr. Mansueto is an indirect owner of Morningstar Research Services. Morningstar Research Services is registered with the United States Securities and Exchange Commission (“SEC”) under Section 203(c) of the Investment Advisers Act of 1940, as amended. Morningstar Research Services consists primarily of investment professionals that were previously part of Morningstar’s U.S.-based manager and equity research teams. Morningstar’s manager and equity research teams have been producing investment research since 1986 and 1999 respectively. B. Services - Overview Investment Research Reports Our core offering is the production of investment research reports on equity securities, mutual funds, exchange-traded funds, separately managed accounts, model portfolios, and other managed investment products (“Investment Research Reports”). Investment Research Reports are prepared without taking into consideration any investor or investor’s specific facts and circumstances and thus are generic/impersonal investment advice intended to be educational in nature and for user’s research purposes. Our Investment Research Reports or excerpts from them are distributed in two primary ways: (1) through Morningstar’s software products (e.g., Morningstar Direct), newsletters, and Morningstar branded websites (e.g., www.morningstar.com) (collectively “Distribution through Morningstar”); and (2) through license agreements directly with non-affiliated financial institutions including broker/dealer firms, banks, insurance companies, investment advisory firms, and media platforms (“License Arrangements”). Our core investment research offerings include the following: 1. Equity Research Reports a. We produce investment research reports with qualitative analysis on primarily North American equity securities. Our equity analysts utilize a proprietary discounted cash flow model as part of their evaluation of a security and their determination of its fair value estimate of the security’s stock. See Item 8 below for details. 2. Manager Research Reports a. We produce investment research reports with qualitative analysis on certain open-end mutual funds, exchange-traded funds (ETFs), separately managed accounts, model portfolios, collective investment trusts (CITs), variable annuity, variable life subaccounts, and other managed investment products (each a “Managed Investment” or collectively, “Managed Investments”). The cornerstone of our investment research is the determination of a Managed Investment’s Morningstar Medalist Rating TM. See Item 8 below for more details. As the process by which equities and Managed Investments can be analyzed is limited by the size of the equity and manager research teams, Morningstar has developed machine-learning models that use the decision-making process of the analysts, their past rating or analysis decisions, and the data used to support those decisions. The machine-learning models are then applied to create quantitative analysis or ratings, which are designed to be analogous to what an analyst might produce if they covered the security. Manager Due Diligence and Selection Services We provide investment consulting services to affiliated registered investment advisers (“Affiliated Clients”) as well as non-affiliated financial institutions including, but not limited to, broker/dealer firms, banks, insurance companies, and investment advisory firms (“Non-Affiliated Clients”). These services are provided on a non-discretionary basis; with the Affiliated and Non-Affiliated Clients (collectively “Institutional Clients”) having final decision-making authority on whether to follow our recommendation(s) or not. Our core manager due diligence and selection services, either on a stand-alone basis or in combination, are the following: 1. Due Diligence a. We apply quantitative screens and qualitative analysis to evaluate investment managers with the end goal of identifying those we believe would be appropriate for an Institutional Client to consider given their stated objective/purpose. See Item 8 below for details. b. In addition to identifying investment managers, we often are required to provide a written analysis on each investment manager including our rationale for recommending them. c. At the Institutional Client’s discretion, we may be engaged to provide ongoing monitoring. This ongoing monitoring typically includes our periodically applying quantitative screens and qualitative analysis and when need be, recommending a change or changes to what we initially recommended to the Institutional Client. This is often supplemented with a written document detailing our rationale for such a change(s). Institutional Clients have the final decision-making authority as to whether to accept our recommendation or not and, if accept, the timing of when the changes are to occur. d. If requested by an Institutional Client and based on their requirements, we use a questionnaire to conduct an operational due diligence review as part of our investment due diligence process. 2. Investment Selection a. We analyze an investment universe as defined by an Institutional Client and create a list of securities that meets the Institutional Client’s specific criteria (e.g., certain performance level over a five-year period, tenure of portfolio manager). The list of securities is typically used by the Institutional Client in providing investment advice to their clients. A given list is typically broken down by asset class and for each asset class, the identification of several securities that have passed our quantitative screens and qualitative analysis. See Item 8 below for details. In engagements with Unaffiliated Clients, the list of securities under each asset class may require that a certain number of them be their proprietary securities. If such requirement is present, the Unaffiliated Client is responsible for communicating such constraint to its clients. b. In addition to identifying securities, we often are requested to provide a written analysis on each security including our rationale for recommending it. c. At the Institutional Client’s discretion, we may also be engaged to perform ongoing monitoring. This ongoing monitoring typically includes periodically applying quantitative screens and qualitative analysis against the defined investment universe and when need be, recommending a change or changes that the Institutional Client may want to consider. In addition to recommending securities we often are required to provide a written analysis on our rationale for making such recommendation. The Institutional Client has the final decision-making authority as to accepting our recommendation or not and, if accepted, the timing of when the changes are to occur. 3. Model Portfolios a. We offer the Morningstar Medalist US Core Portfolios (“Medalist Core Portfolios”) to institutional clients on a non-discretionary basis. The Medalist Core Portfolios are a series of diversified, multi-asset manager portfolios designed to provide investors across a range of risk tolerances access to differentiated portfolios. Ancillary Services 1. Tailored Account Coverage a. The institutional sales team provides research via email distribution to clients based on account holdings and/or investment approach. Additionally, the team organizes client meetings and calls with equity research analysts, fields incoming client inquiries on equity research and answers client questions on thematic research. Custom screens and reports are also provided for client base. 2. Newsletter Content We provide content for two newsletters (1) FundInvestor and (2) ETFInvestor distributed by Morningstar. The purpose of these newsletters is to provide subscribers education/information on an investment topic or topics as well as data, statistics and written analysis on a specific fund(s) and/or ETF(s). 3. Other Commentaries/Reports a. We prepare commentaries such as market outlooks, sector outlooks, industry reports, and thematic research as well as various other types of reports that are a more condensed/ targeted format than what is in our standard investment research reports. Such commentaries and reports are available through Morningstar’s software products, newsletters and Morningstar branded websites. The goal of these commentaries and reports is to provide readers with education/information. Our analysts also participate in videos or podcasts produced by Morningstar and made available through Morningstar’s branded websites and platforms. 4. Analyst Access a. Institutional Clients are given the ability to interact with our analysts about their published investment research (referred to hereafter as “Analyst Access”). During such conversations, the analyst can: i. Answer questions pertaining to the content of their published research; ii. Clarify points made within their published research; iii. Provide insight into the analyst’s research process; iv. Reiterate the analysis/opinions made within the published research; and v. Provide their opinions on a given market sector or sectors. 4. Due Diligence Tools a. To assist with an Institutional Client’s internal research team’s processes and workflows for Managed Investment selection and monitoring, we prepare a custom suite of reports to help teams evaluate Managed Investments and operate more efficiently. Scorecards use objective and data-driven methods to rank Managed Investments based on formulas that aggregate many of the important characteristics that drive a Managed Investment’s performance, as determined by Morningstar’s research analysts. The Scorecards are delivered with updated data each month, using a client’s preferred file type and location. Additional summary reports that assist with the due diligence process include Screens (a report that lists high- quality investments for different strategies and goals, according to Morningstar’s research analysts), Alerts (a report that captures material changes and supports the monitoring workflow for a custom list of investments), and Red Flags (a report that captures warning signs and supports the monitoring workflow for a custom list of investments). C. Customized Services At an Institutional Client’s request, we will take under consideration a request to provide them a customized version of the above services or a different type of advisory service that would utilize our investment research, due diligence, and Managed Investment selection expertise. Given the customized nature, the Institutional Client may impose constraints/restrictions on such things as security types, asset classes, or proprietary Managed Investment requirements and/or wish to collaborate with us on such things as investment methodology and screening criteria. D. Wrap Fee Programs We do not sponsor a wrap fee program, nor do we provide portfolio management services to a wrap fee program. E. Assets Under Management

Given the nature of our services, we do not have assets under management. Item 5. Fees and Compensation A. Fees and Compensation For our Investment Research Reports, our compensation is generally structured in the following way: 1. Equity Research Reports a. With respect to Distribution through Morningstar, we do not charge a separate fee to a subscriber of Morningstar’s software or websites to access our qualitative reports on equity securities. The subscription fee charged to subscribers of Morningstar’s software and/or websites includes access to such reports as well as Morningstar’s data, statistics, tools and general educational materials. That subscription fee is determined, billed and received by Morningstar. We do not receive a fee from Morningstar for subscriber’s access to our qualitative reports. b. With respect to License Arrangements, fees are negotiable, but generally start at $250per authorized user annually. The actual amount charged depends on a range of variables including but not limited to the number of users it wishes to have available to our investment research, the number of securities they wish to receive investment research reports on, the inclusion or exclusion of the analyst access service, the degree of customizations (e.g., translated in other languages), and/or the client’s assets under management. The fee is typically charged quarterly in advance. In other instances, fees are based on the percentage of gross revenue received related to the use of an Equity Research Report. These fees are negotiated. If, in accordance with contractual terms, the institutional client terminates the License Arrangement they have with us prior to the end of the billing period, we may refund any unearned fees on a pro rata basis after the termination of the contract. In addition to the fee, payment terms and payment schedules are negotiable. c. In certain cases, Non-Affiliated Clients may determine what to pay us for our Equity Research Reports by using a ‘broker vote’ process. That process is where we receive remuneration for our investment research and analyst access services based on its perceived value as determined by the institutional investor’s representatives. Actual remuneration is determined by the institutional investor, is typically received in arrears and is paid to us by the institutional investor’s broker(s) at intervals they and/or their broker determine. 2. Manager Research Reports a. With respect to Distribution through Morningstar, we do not charge a separate fee to a subscriber of Morningstar’s software or websites to access our manager research reports. The subscription fee charged to subscribers of Morningstar’s software and/or websites not only includes access to such reports, but access to Morningstar’s data, statistics, tools and general educational materials as well. That subscription fee is determined, billed and received by Morningstar. We do not receive a fee from Morningstar for subscriber’s access to our Manager Research Reports. b. With respect to License Arrangements, fees are negotiable, but generally starts at $250 per authorized user annually. The actual amount charged to the institutional client depends on a range of variables including but not limited to the number of users they wish to have access to our investment research, the type of client they wish to redistribute our research to, the number of Funds they wish to receive investment research reports on, the inclusion or exclusion of the analyst access service, the degree of customizations (e.g., translated in other languages), and the client’s assets under management. The fee is typically charged quarterly in advance. If, in accordance with contractual terms, the institutional client terminates the License Arrangement they have with us prior to the end of the billing period, we may refund any unearned fees on a pro rata basis after the termination of the contract. In addition to the fee, payment terms and payment schedules are negotiable. For Manager Due Diligence and Selection Services, our compensation is the following: 1. Due Diligence a. Fees are negotiable, but typically starts at $5,000 per investment strategy reviewed. The actual amount charged to a Non-Affiliated Client depends on a range of variables including their intended use, the number of investment strategies they wish to have reviewed, the type of reporting they wish to receive from us, the degree of customizations or constraints they wish to place on us, and whether they want us to provide on-going monitoring services. The fee is typically charged quarterly in advance. If, in accordance with contractual terms, the Non-Affiliated Client terminates the License Arrangement prior to the end of the billing period, we may refund any unearned fees on a pro rata basis after the termination of the contract. In addition to the fee, payment terms and payment schedules are negotiable. Fees in connection with services provided to Affiliated Clients are typically governed by an intercompany agreement and is often lower than the above stated amount. 2. Investment Selection a. Fees are negotiable, but typically starts at $50,000 per standard list or $65,000 per custom list annually. The actual amount charged to a Non-Affiliated Client depends on a range of variables including their intended use, the number and type of asset classes they wish the list to cover, the number and type of Managed Investments they wish the list to have, the type of reporting they wish to receive from us, the degree of customizations or constraints they wish to place on us, and whether they want us to provide on-going monitoring services. The fee is typically charged quarterly in advance. In instances where our Investment Selection services are used as an input for an Institutional Client’s financial product, basis point fees are generally charged. Basis point fees are charged quarterly in arrears, and typically start at 15-20 bps annually. If, in accordance with contractual terms, the Non-Affiliated Client terminates the License Arrangement prior to the end of the billing period, we may refund any unearned fees on a pro rata basis after the termination of the contract. In addition to the fee, payment terms and payment schedules are negotiable. Fees in connection with services provided to Affiliated Clients are typically governed by an intercompany agreement and is often lower than the above stated amount. 3. Model Portfolios a. Fees are negotiable but are typically comprised of an annual fee ranging from 10-15 basis points based upon the aggregate value of all accounts participating in the Program, a fixed annual fee starting at $65,000 or a combination of a fixed fee and asset- based fee. For Ancillary Services: 1. Newsletters a. We do not charge a separate fee to the subscribers of Morningstar’s Newsletters to access our written analysis of other commentaries/reports. The subscription fee for the FundInvestor and ETFInvestor newsletters is determined, billed and received by Morningstar. We do not receive a fee from Morningstar for subscriber’s access to our commentaries/reports. 2. Other Commentaries/Reports a. We do not charge a separate fee to Morningstar’s software or websites subscribers to access our other commentaries/ reports. The subscription fee charged to subscribers of Morningstar’s software and/or websites not only includes access to such commentaries/reports, but access to Morningstar’s data, statistics, tools and general educational materials as well. That subscription fee is determined, billed and received by Morningstar. We do not receive a fee from Morningstar for subscriber’s access to our commentaries/reports. 3. Analyst Access a. Equity Analysts i. Licensed Agreements – compensation for granting access to our equity analysts is negotiable and is included in the per user charge as referred to in 1(b) of Section A of Fees and Compensation above. In ‘broker vote’ cases, remuneration paid by the institutional investor includes their perceived value in having access to our equity analysts. b. Manager Research Analysts i. Licensed Agreements – compensation for granting access to our manager research analysts is negotiable and is included in the per user charge as referred to in 2(b) of Section A of Fees and Compensation above. 4. Due Diligence Tools a. With respect to License Arrangements, fees are negotiable, but generally start at $25,000 annually. The actual amount charged depends on a range of variables including the number of users with access, how the tools will be used, and how the reports will be distributed. The fee is typically charged quarterly in advance. If, in accordance with contractual terms, the institutional client terminates the License Arrangement they have with us prior to the end of the billing period, we may refund any unearned fees on a pro rata basis after the termination of the contract. In addition to the fee, payment terms and payment schedules are negotiable. For Customized Services: Fees for a customized version of the above services or a different type of advisory services that would utilize our investment research, due diligence, or investment selection expertise are negotiable. In negotiating with an institutional investor, the actual amount charged depends on a range of variables including the type of service being sought, the type of securities involved (e.g., equities or Managed Investments), the intended purpose for our service, the type of output being sought from us, the intended use of the Morningstar name. In addition to the fee, payment terms and payment schedules are negotiable. B. Payment Payments, payment terms and payment schedules are negotiable and governed by the contractual agreement with the Non-Affiliated Clients. Other than Affiliated Clients, we typically send an invoice on a quarterly basis, although in some instances, we may bill monthly or annually. For our Affiliated Clients, fees are charged through an intercompany charge. C. Other Costs in Connection with our Advisory Services The above noted fees are separate from fees and expenses one may incur if followed our recommendations. For example, investors in an equity security will be subject to brokerage/transaction costs and custodian fees or expenses whereas investors of open-end funds and exchange-traded funds will be subject to fees and expenses as described in their prospectus including management fee, operating expenses, distribution charges including 12b-1 fees and for open-end mutual fund, sales charges (e.g., front-end sales loads), and for exchange-traded funds brokerage/transaction costs. D. Charging Fees in Advance If, in accordance with contractual terms, we agree to terminate a contract with the institutional client prior to the end of the billing period, we generally refund any unearned fees on a pro rata basis after the termination of the contract. E. Compensation from Sales of Securities We do not expect, accept or receive compensation for the sale of securities that are the subject of our Investment Research Reports. F. Revenue Sharing Arrangements We do not have any revenue sharing arrangements with any registered investment advisers or mutual funds.