Ingham/Russell Investment Advisors, Inc. is a SEC-registered investment adviser with its principal place of business located in Florida. Ingham/Russell Investment Advisors, Inc. began conducting business in 1991. Ingham/Russell Investment Advisors, Inc. is a wholly owned subsidiary of Ingham & Company. Listed below are Ingham & Company’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).  USRP Holdings, Inc.  KUSRP Acquisition, Inc.  KUSRP Holdings, Inc.  Kohlberg TE Investors VIII, L.P. Ingham & Company and Ingham Russell Investment Advisors, Inc. both do business as Ingham Retirement Group. Ingham Retirement Group offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop an investment policy and create and manage a portfolio based on that policy. During our data- gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. At least annually we will review target allocations and compare them to the current portfolio holdings and if necessary, the holdings will be modified. Accounts will be rebalanced annually unless the advisor and/or the client determine it is not appropriate. Investment professionals may also schedule client meetings on a periodic basis to review a client's portfolio, performance, market conditions, financial circumstances and investment objectives. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Corporate debt securities (other than commercial paper)  Certificates of deposit  Municipal securities  Variable life insurance  Variable annuities  Mutual fund shares  United States governmental securities  Interests in partnerships in various investment opportunities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. INVESTMENT SUPERVISORY SERVICES ("ISS") MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. Most Aggressive Strategy: Seeks to provide high long-term capital appreciation. Aggressive Strategy: Seeks to provide high long-term capital appreciation with low current income. Balanced Strategy: Seeks to provide above average capital appreciation and a moderate level of current income. Moderate Strategy: Seeks to provide high current income and moderate long-term capital appreciation. Conservative Strategy: Seeks to provide high current income and low long-term capital appreciation. We manage the advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop an investment policy in which the client's goals and objectives are established and we determine if the model portfolio is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Mutual fund shares Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. at least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 2. be reasonably available to consult with the client; and 3. maintain client suitability information in each client's file. INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides non-continuous asset management of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on the client's particular circumstances are established, we develop the client's investment policy statement. We create and manage a portfolio based on that policy. During our data- gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Once the client's portfolio has been established, we review the portfolio as frequently as quarterly, but not less than annually, and if necessary, rebalance the portfolio on an annual basis, based on the client's individual needs or to the client's initial target allocations. Investment professionals may also schedule client meetings on a periodic basis in order to review the client's portfolio, performance, market conditions, financial circumstances and/or investment objectives. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Corporate debt securities (other than commercial paper)  Certificates of deposit  Municipal securities  Variable life insurance  Variable annuities  Mutual fund shares  United States governmental securities  Interests in partnerships investing in various opportunities Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. MODEL PORTFOLIO MANAGEMENT Our firm provides non-continuous portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. Most Aggressive Strategy: Seeks to provide high long-term capital appreciation. Aggressive Strategy: Seeks to provide high long-term capital appreciation with low current income. Balanced Strategy: Seeks to provide above average capital appreciation and a moderate level of current income. Moderate Strategy: Seeks to provide high current income and moderate long-term capital appreciation. Conservative Strategy: Seeks to provide high current income and low long-term capital appreciation. Through personal discussions with the client in which the client's goals and objectives are established, we initially determine whether the model portfolio is suitable to the client's circumstances. Once we confirm suitability, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Once the client's portfolio has been established, we review the portfolio as frequently as quarterly, but not less than annually, and if necessary, rebalance the portfolio on an annual basis, based on the client's individual needs or to the client's initial target allocations. Through personal discussions with the client in which the client's goals and objectives are established, we determine if the model portfolio is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients

retain individual ownership of all securities. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Mutual fund shares Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. at least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 2. be reasonably available to consult with the client; and 3. maintain client suitability information in each client's file. PENSION CONSULTING SERVICES We also provide several advisory services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Consulting Services are comprised of four distinct services. Clients may choose to use any or all of these services but are usually offered together as part of the overall Ingham Retirement Group retirement plan service offering. Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We will meet with the client (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS. The IPS lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. IPS is reviewed annually and revised if necessary. Selection of Investment Vehicles: We assist plan sponsors in selecting investment options based on the IPS criteria. We will then review various mutual funds and ETFs (both index and managed) to determine which investments are appropriate to implement the client's IPS. In addition, we will create several asset allocation strategies based on various risk/return profiles ranging from most aggressive to most conservative and rebalancing the strategies at least annually to their target allocations. The number of investments to be recommended will be determined by the client. Monitoring of Investment Performance: We monitor client investments based on the procedures and timing intervals delineated in the Investment Policy Statement. We supervise the client's portfolio and will make recommendations to the client as market factors and the client's needs dictate. In addition, we will provide each client quarterly monitoring reports that evaluate each investment option relative to the IPS criteria and compared to their individual peer groups as well as make recommendations for the watch list, replacement or additions of investment options. Plan Sponsor or Trustee Meetings: We will conduct meetings at least annually and as frequently as quarterly based on client preference in order to review plan investment options, investment performance, market conditions, investment objectives and asset allocation. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we also provide quarterly educational support and investment workshops designed for the plan participants when the plan sponsor engages our firm to provide these services. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. SELECTION AND MONITORING OF THIRD-PARTY MONEY MANAGERS We also offer advisory management services to our clients through our Selection and Monitoring of Third-Party Money Managers programs (hereinafter, "Programs"). Our firm provides the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Investment Policy Statement ("IPS"). Based on the client's individual circumstances and needs we will then perform manager searches of various unaffiliated registered investment advisers to identify which registered investment adviser's portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected registered investment adviser. Clients should refer to the selected registered investment adviser's Firm Brochure or other disclosure document for a full description of the services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. Once we determine the most suitable investment adviser(s) for the client, we provide the selected adviser(s) with the client's IPS. The adviser(s) then create(s) and manages the client's portfolio based on the client's individual needs as exhibited in the IPS. We monitor the performance of the selected registered investment adviser(s). If we determine that a particular selected registered investment adviser(s) is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's IPS, we may suggest that the client contract with a different registered investment adviser and/or program sponsor. Under this scenario, our firm assists the client in selecting a new registered investment adviser and/or program. However, any move to a new registered investment adviser and/or program is solely at the discretion of the client. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. Services may include, but not be limited to, the following:  Retirement Planning  General, Segmented and Comprehensive Financial Planning  Educational Planning  Cash Flow Analysis  Estate Planning  Budget Planning  Tax Planning  Insurance Needs Analysis  Business Continuity, Succession and Exit Planning  Asset Allocation Services  Executive Planning  Corporate Benefit Consulting  Other planning and consulting services as requested by client Ingham Retirement Group will gather information and history from clients, which may include among other things, retirement and financial goals, investment objectives, investment horizon, financial needs, cash flow analysis, cost of living needs, educational needs, savings tendencies and other applicable financial information required by Ingham Retirement Group in order to provide the financial planning services requested. As stated above, the level and type of services will depend on the needs of the client. Depending on the services requested, clients may receive a written analysis, summary or plan. One or more meetings may be necessary with the client and may involve other professionals, as invited and agreed to by client, such as attorneys and/or certified public accountants. Planning and consultative services are based on the client's financial situation at the time and on financial information disclosed by the client to Ingham Retirement Group. Clients are advised that plans may contain certain assumptions that may be made with respect to interest and inflation rates, use of past trends and performance of the market and the economy. However, past performance is in no way an indication of future performance. Ingham Retirement can not provide any guarantees or promises that client's financial goals and objectives will be met. Further, clients must continue to review any plan or analysis and update the plan based upon changes in the client's financial situation, goals, or objectives or changes in the economy. Should the clients' financial situation change or investment goals or objectives change, clients must notify Ingham Retirement Group promptly of the changes. Clients are advised that fees for planning and/or consultative services are strictly for planning services. Therefore, clients may pay fees and/or commissions for additional services obtained, such as asset management or products purchased such as securities or insurance. A conflict of interest may exist between the interests of Ingham Retirement Group and/or its Advisory Representatives and the interests of the client. Ingham Retirement Group and Advisory Representative offer financial planning and investment advisory services for a fee and also offer various securities products for which they may be paid a commission. The Ingham Retirement Plan Code of Ethics requires Advisory Representatives to put their clients' interest first, and the Ingham Retirement Group Compliance Department monitors for inappropriate account activity. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. AMOUNT OF MANAGED ASSETS As of December 31, 2022, total assets under management are $2,001,384,434.04. We were actively managing $606,322,687.94 of clients' assets on a discretionary basis and $1,395,061,746.11 of clients' assets on a non-discretionary basis.