Prudent Management Associates (also referred to as “PMA” or the “firm”) is a registered investment adviser formed in 1982. For over forty years, PMA has endeavored to make available to smaller investors the same sophisticated manager selection and asset allocation process used by the largest and most sophisticated institutional investors. Our coherent and intellectually sound investment process rooted in the principles of modern portfolio theory, coupled with a rigorous process of evaluating, selecting, and monitoring the funds we use to construct portfolios, have created a track record we are proud of. Prudent Management Associates invests primarily through low-cost, low-turnover, no-load mutual funds that have a proven track record, management stability, deep experience, and a consistent investment philosophy. PMA uses these mutual funds to carefully construct risk- controlled portfolios, designed to provide downside protection during bear markets while still participating in up markets. In using no-load mutual funds, the firm is completely independent of the funds it chooses, and is compensated only by the client. PMA may also use ETFs (“Exchange-Traded Funds”) in limited circumstances – for example, if certain exposures are not available through no-load mutual funds – and, in such circumstances, PMA will remain completely independent of the ETFs it uses and will continue to be compensated only by the client. The direct owners of the firm are Keystone Development Services, Inc., Marshall Blume Associates, Inc., and Kantwell Partners, LLC. ("Kantwell"). As a result of the passing of Marshall Blume in 2019, the indirect owner of Marshall Blume Associates, Inc. is Loretta Blume. Keystone Development Services, Inc. is owned by Andrew, Paul and Fred Snitzer and Barbara Snitzer Solit. Kantwell is owned by David Wellborn, and (indirectly) David Kantor. Although investment risk can never be eliminated entirely, we are conservative and risk- averse investors. We do not chase trends. We do not invest directly in individual stocks or bonds, derivatives, currencies, commodities, real estate, hedge funds, private equity, or any type of alternative

investment. We invest primarily in low-cost, no-load mutual funds, across a broad range of categories: small, mid, large, value, growth, and blend. We generally do not invest in sector funds. Within the bond portion of our clients’ portfolios, we primarily invest in short-term and intermediate-term bond funds. We also may invest a small percentage of our bond portfolio in high-yield bond funds when market conditions warrant. PMA combines the role of the consultant and the money manager into one firm, evaluating mutual funds and constructing highly-diversified portfolios from the funds that pass the firm's screen. PMA carefully monitors the volatility of the financial markets for excessive exuberance or pessimism, tracks the changing correlations between asset categories, and adjusts the client's portfolios accordingly. With PMA, clients have to make only one fundamental decision: what level of risk they are comfortable taking. After clients have decided, the firm will invest client assets in one of PMA’s carefully constructed investment portfolios. Clients are provided with a monthly market value statement that shows the breakdown of their portfolio by fund. On a quarterly basis, clients are given a performance report and transaction report. PMA offers four basic portfolios to its clients: a Small, a Moderate, a Substantial and an All- Equity Risk Portfolio (see Item 8 for a fuller explanation of the construction of these four portfolios). Each portfolio’s risk is a function of its asset allocation – the percentage of the portfolio invested in stock funds and the percentage invested in bond funds. However, PMA knows that every investor is unique and is willing to tailor its four portfolios to meet the needs of a specific client. We work closely with each client to help define current needs and long- term goals. We guide both individual and institutional clients as they make their key decision: the level of risk they need to assume in order to achieve their financial objectives. Although we do not recommend it, clients may, if they wish, request that PMA not use specific mutual funds. As of January 31, 2024, PMA manages $1,052,758,169.