Fiduciary Counselling, Inc. (“FCI”), founded in 1941, provides discretionary and non-discretionary investment advisory services consistent with the individual needs and objectives of each client account. FCI provides accounting, trust and tax services, financial and investment advisory services and estate planning in consultation with the client’s legal counsel. Services are provided pursuant to each client’s respective Client Services Agreement. FCI is a wholly owned subsidiary of Cassiopeia Holdings Company (“Cassiopeia”), a Delaware corporation wholly owned by Ties That Bind Purpose Trust. Cassiopeia also owns Fiduciary Services Company, LLC (“FSC”), a private trust company that serves as trustee for Ties That Bind Purpose Trust as well as certain of FCI’s client accounts. FCI’s investment advisory services include asset allocation services, recommendations regarding the purchases and sales of securities and rebalancing recommendations. For certain clients, FCI provides investment advisory services on a non-discretionary basis. FCI exercises discretion if specifically authorized by the client in the Client Services Agreement. See Item 16. After consultation with the client, FCI will establish guidelines and policies for the account, which generally include a written investment policy statement (“IPS”). FCI provides clients investment advisory services consistent with a formulated plan of investment through the use of model portfolios to be implemented by FCI for the client’s account. These model portfolios are based on FCI’s asset allocation methodology and each client’s desired exposure to certain stocks traditionally owned by FCI clients. From this base, FCI uses concepts of modern portfolio theory to build the model portfolio using registered and unregistered investment companies and other securities, including private investments where appropriate for certain clients. FCI generally offers advice on investments in equity securities, fixed income securities, ETFs, mutual funds, certain private funds, private equity investments and other securities issued in private placements. FCI does not limit its investment advice or recommendations to certain types of investments. Clients can impose restrictions on owning certain securities or types of securities in the Client Services Agreement or IPS. From time to time, FCI clients seek to invest in strategies or investments for which FCI does not offer as an FCI investment strategy, such as environmental, social or governance (ESG) strategies or digital assets. If requested, FCI may help facilitate a client’s investment in such assets and provide reporting or administrative services to the client. FCI may also provide general education about such strategies and investments. Upon client request, FCI may render advisory services to clients relative to the initial retention, ongoing monitoring and review of the performance of third-party separate account managers (“Managers”). Factors which FCI considers when reviewing a Manager include the client’s stated investment objectives and the Manager’s management style, performance,

reputation, financial strength, reporting, pricing and research. The terms and conditions under which the client engages a Manager are set forth in separate written agreements between the client and the Manager. As part of FCI’s advisory services, FCI may provide recommendations concerning a client’s employer retirement plan or other qualified retirement account. FCI may recommend that a client consider withdrawing assets from their retirement account and rolling the assets over to an individual retirement account (“IRA”). FCI provides investment advisory services to assets rolled over into an IRA or another account for which FCI receives compensation. If a client rolls retirement account assets into an IRA that FCI advises, FCI will charge an asset-based fee as described below in Item 5. Please see Item 19 for additional disclosures regarding retirement account rollovers. FCI’s services also include financial planning, accounting, estate planning, estate administration and trust and charitable administration. FCI also provides clerical, record-keeping and other administrative services as directed by individual clients which include, but may not be limited to, facilitating the gifting and re-registration of securities, insurance policy administration, bill-paying services and the preparation of state and federal tax returns and other reports. In addition, FCI provides support in the processing of corporate actions (mergers, buyouts, bankruptcy claims), stock gifts and proxy materials. Upon request, FCI assists clients in obtaining mortgages and other loans and opening and administering bank accounts. Certain clients may elect not to receive the full suite of services offered by FCI. Clients may also request special projects and other specialized services (“Extraordinary Services”) as described in Item 5, below. Pursuant to a Servicing Agreement between FCI and Clearwater Management Co., Inc. (“CMC”), FCI has been engaged by CMC to provide various services to CMC on behalf of its clients, the Clearwater Investment Trust (the “Trust”), a registered investment company, as well as certain private investment funds (the “Private Funds”). CMC is a registered investment adviser that provides investment management and administrative services to the Trust and its mutual fund portfolios and to the Private Funds. CMC serves as general partner or manager to the Private Funds. FCI may recommend that clients invest in the Trust and the Private Funds. Pursuant to a subadvisory agreement between FCI, CMC and the Trust, FCI provides certain investment advisory services to CMC and the Trust, including investment strategy advice and manager recommendations. Pursuant to the Servicing Agreement, FCI provides compliance and administrative services to CMC with respect to the Trust and the Private Funds and provides asset allocation advice, due diligence and investment recommendations to CMC with respect to the Private Funds. As of December 31, 2023, FCI managed approximately $3.7 billion in assets on a discretionary basis and $5.8 billion in assets on a non-discretionary basis