GENERAL INFORMATION CornerCap Investment Counsel, Inc. is a Georgia corporation formed in 1989. CornerCap provides guidance and tailored portfolio management services to high-net-worth individuals, group retirement plans, foundations, endowments, and other types of clients. CornerCap is also investment adviser to CornerCap Small-Cap Value Fund and to CornerCap Fundamentrics® Large Cap ETF, as described below under “Other Financial Industry Activities and Affiliations.” INDIVIDUALIZED ACCOUNT ADVISORY SERVICES At the beginning of a client relationship, CornerCap meets with the client, asks questions, gathers information, and performs research and analysis as necessary to develop the client’s investment objective and strategy. The client’s investment objective and strategy will be updated from time to time when requested by the client, or when determined to be necessary or advisable by CornerCap based on updates to the client’s financial or other circumstances. Discretionary Services For clients selecting CornerCap’s discretionary services, CornerCap will analyze client portfolios and determine an allocation of equity securities (e.g., stocks) and fixed income securities (e.g., bonds) for the portfolio, and will make recommendations regarding specific securities to be purchased, consistent with the client’s investment objective and strategy. CornerCap may invest assets in the client’s portfolio directly into stocks or bonds, or into mutual funds or other investment funds that invest in stocks, bonds, or other securities. The methods used by CornerCap to determine which securities should be purchased for a client portfolio are described below under “Methods of Analysis, Investment Strategies and Risk of Loss”. As a discretionary investment adviser, CornerCap will have the authority to supervise and direct the portfolio without prior consultation with the client. Non-Discretionary Services Clients who choose a non-discretionary arrangement with CornerCap will receive similar portfolio analysis and investment recommendations as described above under “Discretionary Services”, but these clients must be contacted prior to the execution of any trade in the account(s) under management. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. POOLED VEHICLE ADVISORY SERVICES CornerCap serves as investment adviser to CornerCap Small-Cap Value Fund (the “Mutual Fund”) in two share classes (“Advisor class”, ticker: CSCVX; and “Institutional class”, ticker: CSCJX), which is a separate series of Managed Portfolio Series Trust. CornerCap also serves as investment adviser to one actively managed exchange traded fund (“ETF”): CornerCap Fundametrics® Large Cap ETF (Ticker: FUNL) (the “CornerCap ETF”), which is a separate series of Advisor Managed Portfolios Trust. Together the Mutual Fund and the CornerCap ETF may be referred to herein as a “Fund,” and collectively the “Funds”. The CornerCap ETF is listed on Cboe BZX Exchange, Inc. Individual shares of the CornerCap ETF may only be purchased and sold on a national securities exchange through a broker-dealer. AUTOMATED INVESTMENT PROGRAM CornerCap offers an automated investment program, the Digital Wealth Platform (the “Program”). Through the Program, client accounts can be invested pursuant to one of the investment strategies developed and managed by CornerCap and offered through the Program. Each client portfolio in the Program is typically invested in a portfolio consisting of exchange- traded funds (“ETFs”) and a cash allocation. The Platform is generally targeted towards clients seeking wealth accumulation and capital appreciation or wealth maintenance and preservation. To participate in the Program, a client must first establish a brokerage account at Charles Schwab & Co., Inc. (“CS&Co.”) pursuant to a separate agreement between the client and CS&Co. CornerCap uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. CornerCap is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). Clients in a Program do not pay brokerage commissions or any other fees to CS&Co. as part of the Program; however, Schwab does receive other revenues in connection with the

Program. CornerCap has contracted with SPT to provide the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables CornerCap to make the Program available to clients online and includes a system that automates certain key parts of the investment process (the “System”). The System includes an online investor profile questionnaire that helps CornerCap determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio (“IPQ”). Based upon the IPQ, Custodian’s software system will recommend one of CornerCap’s model portfolios offered within the Program as the investment management strategy for the account (the “Strategy”). It shall be the responsibility and obligation of the client to keep CornerCap apprised in a timely manner of any changes to the IPQ or any other changes relevant to the manner in which the portfolio is managed. CornerCap will have no duty or obligation to investigate the accuracy or completeness of the information about the client included in or underlying the IPQ. Clients should be aware that CornerCap may but is not obligated to commence management of the client’s account until such time as the client has discussed the Strategy with CornerCap. Once approved by CornerCap and the Client, the selected Strategy will only be revised to the extent that a client revises the client’s IPQ and such revisions affect the risk profile of the client’s account. However, if a client revises the IPQ such that a new Strategy is recommended for the client, CornerCap is not obligated to make any change to the Strategy until the client has discussed such change with CornerCap. Accordingly, if a client in the Program makes a change to the IPQ, the client must promptly contact CornerCap to discuss such change; otherwise, CornerCap may continue to manage the portfolio in accordance with the existing Strategy. The System includes an automated investment engine through which CornerCap manages the client’s portfolio on an ongoing basis through automatic rebalancing. This process will automatically make periodic trades in the portfolio to rebalance investments in accordance with the portfolio’s Strategy, such as when additional amounts are invested or when the assets in the portfolio become over or underweight due to market movements. Such rebalances may not take into account the tax effect of such trades or the tax situation of the client generally at such time. CornerCap charges clients a fee for the Program as described below under “Item 5 - Fees and Compensation”. CornerCap does not pay CS&Co. for transaction and execution expenses or pay SPT an annual licensing fees for the Platform, provided that CornerCap and its affiliates maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in the Program, and each account enrolled in the Program holds cash equal to at least 4% of the value of the account’s assets. If CornerCap and its affiliates do not meet these conditions, then CornerCap must pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of its clients’ assets in the Program. This fee arrangement gives CornerCap and its affiliates an incentive to recommend or require that clients with accounts not enrolled in a Program be maintained with CS&Co. based on CornerCap’s interest in receiving services that benefit its business rather than based on the client’s interest in receiving the best value in custody services and the most favorable execution of transactions. This is a potential conflict of interest. CornerCap believes, however, that its selection of CS&Co. as custodian and broker for clients in the Program is in the best interests of its clients. It is primarily supported by scope, quality, and price of CS&Co.’s services and not Schwab’s services that benefit only CornerCap. OTHER SERVICES In addition to the foregoing, CornerCap may also advise clients with respect to investments in specific private investment opportunities (e.g., evaluation of limited partnerships in which a client is considering investing). In these situations, CornerCap assists the client to understand and evaluate the opportunities and potential of the investments. PRINCIPAL OWNERS Thomas E. Quinn is the principal owner of CornerCap. TYPE AND VALUE OF ASSETS CURRENTLY MANAGED As of December 31, 2023, CornerCap managed $1,181,507,109 on a discretionary basis, and $0 of assets on a non-discretionary basis.