Fuller & Thaler Asset Management, Inc. ("FullerThaler") was organized as a California corporation in April 1993. It has been registered with the United States Securities and Exchange Commission as an investment adviser since May 1993. FullerThaler is 100% beneficially owned by employees. Actual control and management of FullerThaler is effected solely through a management group comprised of the senior partners of FullerThaler (the “Management Group”). The Management Group’s primary function is to oversee the business affairs and day-to-day operations of FullerThaler. FullerThaler provides specialized investment management services, primarily on a discretionary basis, that focus on exploiting market inefficiencies drawn from insights from behavioral finance. The firm’s strategies include a variety of U.S. equity strategies. It offers primarily behavioral-based strategies as opposed to quantitative or traditional fundamental strategies. Strategies are managed primarily in a long-only format. FullerThaler works with clients to tailor its investment strategies to meet the individual needs of each client such as by imposing restrictions on investing in certain securities or types of securities or by expanding the universe of securities or types of securities. Clients are encouraged to discuss their specific needs with FullerThaler. FullerThaler provides non-discretionary and discretionary model-delivery portfolio management services to wrap fee programs where FullerThaler provides ongoing investment recommendations in the form of one or more “model” portfolios, and the wrap program

sponsor, rather than FullerThaler, executes trades on behalf of its underlying clients. In a non-discretionary model-delivery arrangement, the wrap program sponsor, and not FullerThaler, is the investment adviser for the accounts in the model-delivery programs. In a discretionary model-delivery arrangement, FullerThaler, is an investment adviser for the accounts of clients in the model-delivery programs. FullerThaler also provides discretionary portfolio management services to traditional wrap fee programs. Such discretionary wrap fee programs are managed similar to the typical FullerThaler separate account whereby FullerThaler is an investment adviser for the account, makes the investment decisions, and executes the trades. However, FullerThaler typically has no contact with the underlying wrap fee program clients and communicates only with the intermediary sponsor. FullerThaler does not serve as a sponsor to any wrap or similar managed account programs and receives a portion of the wrap fee from the sponsor for its services. The wrap programs to which FullerThaler is a portfolio manager are identified under Item 5 of its Form ADV, Part 1A. As of December 31, 2023, FullerThaler managed the following net assets on a discretionary and non-discretionary basis: U.S. Dollar Amount Discretionary $20,397,025,075 Non-Discretionary* $ 1,560,049,026 Total Net Assets $21,957,074,100 *Includes assets not treated as Regulatory Assets Under Management (“RAUM”) in Item 5.F. of its Form ADV Part 1A FullerThaler is a brand name of Fuller & Thaler Asset Management, Inc.