Teachers Advisors, LLC (“TAL”) offers or provides investment advisory services to a broad range of primarily institutional clients including investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”) and other pooled investment vehicles (each, a “Fund”, and collectively, “Funds”, and together with Funds advised by advisers under common control with TAL, “Affiliated Funds”). TAL also provides investment advisory services to institutional investors through separate account management under both direct advisory and sub-advisory mandates (“Institutional Separate Accounts”). In addition, TAL may provide investment advisory services to retail separately managed account (“Retail SMA”) clients through managed account programs (wrap fee and dual contract) sponsored by broker-dealers and other financial intermediaries (“Program Sponsors”). Although most services are provided on a discretionary basis, TAL may provide certain services on a non-discretionary and model portfolio basis. Additionally, TAL provides investment allocation advice, portfolio analysis or strategy diligence services for affiliated and unaffiliated clients. TAL is a subsidiary of Nuveen Finance, LLC, which is an indirect subsidiary of Nuveen, LLC (“Nuveen”). Nuveen is a subsidiary and represents the investment management division of Teachers Insurance and Annuity Association of America (“TIAA”), a leading financial services provider. TIAA constitutes the ultimate principal owner of TAL. TAL was incorporated on October 19, 1993 and registered with the SEC as an investment adviser on July 21, 1994. For additional information on the ownership structure, please see Form ADV Part 1, Schedules A and B, and Item 10. Types of Advisory Services General TAL provides investment advisory or sub-advisory services to Funds, Institutional Separate Accounts and, from time to time, Retail SMAs. TAL’s investment advisory services are provided generally based on the strategy selected by the client, subject to agreed-upon account restrictions and guidelines. TAL provides its services in a broad array of fixed income, equity and other investment strategies, including in the broad categories of municipal bonds, taxable fixed income, global and international, value, growth and core equities, asset allocation, quantitative/enhanced, responsible investing, alternative and customized strategies. Depending on the particular strategy, TAL invests in a variety of securities and other investments, including in certain cases derivatives, and employs different investment techniques. Certain strategies include an allocation to Funds, including Funds affiliated with TAL or its affiliates. Certain strategies include elements of other strategies and may be customized to meet the individualized needs of TAL’s clients. For additional information on TAL’s main strategies and principal risk factors, please see Item 8. TAL’s portfolio managers are generally responsible for the investment decisions with respect to the investment strategy selected by a client, including identification and selection of specific securities and investments to be purchased in light of current and anticipated economic and market conditions, in consideration of account guidelines, limitations and information relating to the client, legal restrictions and TAL internal strategy guidelines. TAL provides its services in single strategy accounts, and alone or together with certain affiliated and unaffiliated advisers, in combined and multi-strategy accounts. To the extent permitted by applicable law, TAL also may appoint affiliated and unaffiliated investment sub-advisers (“Subadvisers”) to provide advisory services, including discretionary portfolio management, to all or a portfolio of assets of one or more Funds, Institutional Separate Accounts, or Retail SMAs. Typically, a client or TAL generally may terminate its agreement at any time by providing thirty (30) days written notice. For Institutional Separate Accounts, termination provisions vary by contract and for Retail SMAs, termination provisions vary by wrap fee program. Fees paid in advance are refunded on a pro rata basis if the service is terminated within the payment period. TAL manages multiple accounts with different investment objectives, guidelines and policies, and with different fee structures. For example, certain accounts are long-only while other accounts are long-short. Further, certain accounts may pay performance fees. The management of these accounts gives rise to potential conflicts of interest because TAL has an incentive to favor one account over another. See Item 6. In periods of market volatility, TAL may be unable to invest new money contributed to an account, or proceeds from the sale of securities, as quickly as it might have been able to do under normal market conditions. Similarly, TAL may be unable to sell securities to raise cash, or to accommodate a terminating client’s request to sell securities, as quickly, or at favorable prices, as it might have been able to do under normal market conditions. Depending on market movements, such delays could have an adverse impact on client accounts. In such periods of market volatility, TAL, when deemed advisable, also may deviate from its normal trading practices with respect to sequencing and allocation of transactions. TAL seeks to commence management of an account as soon as practicable after review of the account documentation in good form, acceptance of its appointment as adviser and contribution of assets to the client’s account. The time required to commence management varies depending on the time required to complete these steps, the efficiency of the client or Program Sponsor and/or other third parties, and the time required to establish an appropriate portfolio. The timing required to fully invest an account depends on multiple factors, including the particular strategy and guidelines; market conditions; availability of desirable securities; the amount of cash versus legacy securities used to fund a new account; and if legacy securities are used, the characteristics of such legacy securities, among others. As a result of the foregoing, some accounts may become fully invested more quickly than other accounts, and in some cases a new account may become fully invested more quickly than an older account. Except as otherwise agreed upon by TAL and the client, including during the invest-up period, TAL does not have any responsibility for the selection of the residual cash management investment vehicle utilized by the client. Clients, their consultants, their financial advisors and/or their custodians select the relevant residual cash management investment vehicle. Advisory Services to Funds TAL provides investment management services to a variety of Funds, including 1940 Act registered Funds and non-1940 Act registered Funds. Non-1940 Act registered funds include bank collective investment trusts (“CITs”), private funds (including but not limited to collateralized debt obligation (“CDO”), collateralized loan obligation (“CLO”) funds, and other private funds investing in other varying asset classes), and offshore funds. As discussed further in Item 11, TAL affiliates (including TIAA) may invest (e.g., seed capital) in certain Funds. In connection with its advisory services to a Fund, TAL or its advisory affiliates or any person under common control with TAL (“Related Persons”) providing services to such Fund generally receive advisory, administration, co-administration and/or distribution fees from the Fund and/or from investment advisers to the Fund. Clients should carefully review the Funds’ prospectuses or other offering documents for more detailed information regarding a Fund to which TAL provides investment services. In the absence of a formalized advisory arrangement, investors in Funds advised or subadvised by TAL will not be advisory clients of TAL, with respect to the investment in the respective Fund, and TAL will not provide investment advice or recommendations with respect to the merits and suitability of the particular Fund investment(s) and investment decision(s) for the particular investor. Investors in Funds advised or subadvised by TAL are encouraged to consult their own financial, tax and legal advisors regarding such decisions. Nuveen Fund shares are available through many unaffiliated broker-dealers and other financial services firms. Advisory Services to Institutional Separate Accounts TAL provides advisory services to U.S. and non-U.S. institutional clients including pension funds, profit sharing funds, charitable institutions, banks and thrift institutions, trust accounts, corporations, insurance companies, and public entities, including municipalities, states and related agencies. The fees and services for each such arrangement are individually negotiated, depending on factors such as asset class, pre-existing relationship, portfolio complexity, client type and account size or other special circumstances. See Item 5. TAL provides investment management services for proprietary assets owned by TIAA under an investment management agreement with TIAA, which services include investment selection (subject to and in accordance with investment guidelines provided by TIAA), portfolio monitoring, trading and other investment-related services. The advice and services that TAL provides to TIAA cover a broad variety of publicly traded investments and derivatives activity, including cross- currency, interest rate and other derivatives activity. TAL provides investment management services for proprietary assets owned by TIAA-CREF Life Insurance Company (“TC Life”) under an investment management agreement with TIAA (appointing TAL as a sub-adviser with respect to the management of such TC Life assets), which services include investment selection (subject to, and in accordance with, investment guidelines provided by TIAA), portfolio monitoring, trading and other investment-related services. The advice and services that TAL provides to TIAA on behalf of the TC Life assets cover a broad variety of publicly traded investments. Advisory Services to Retail SMAs TAL from time to time provides investment advisory services to Retail SMAs through wrap fee and dual contract managed account programs. In traditional wrap fee programs, TAL provides its advisory services pursuant to an advisory agreement with the wrap fee Program Sponsor. Wrap fee programs typically include comprehensive custody, financial advisory and certain trading (provided by the Program Sponsor or a broker designated by the Program Sponsor) and investment advisory services (provided by the manager) for a bundled fee payable to the wrap fee Program Sponsor (“Wrap Fee Programs”). In a dual contract Retail SMA program, TAL provides its advisory services pursuant to an advisory agreement directly with the client or the client’s financial advisory firm. A client may separately arrange with one or more third parties for custody, financial advisory and certain trading services to be provided on a partially-bundled or unbundled basis. In a partially-bundled program, certain of such services (typically custody, financial advisory,

and certain trading) are provided for a bundled fee arrangement. In an unbundled arrangement, such services are contracted, provided, and paid for separately. For Retail SMAs, TAL is appointed to act as an investment adviser through a process generally administered or assisted by the Program Sponsor. Clients participating in a managed account program, generally with assistance from the Program Sponsor, may select TAL to provide investment advisory services for their account (or a portion thereof) for a particular strategy. TAL provides investment advisory services based upon the particular needs of the managed account program client as reflected in information provided to TAL by the Program Sponsor and will generally make its representatives available for communication as reasonably requested by clients and/or Program Sponsors. Clients are encouraged to consult their own financial advisors and legal and tax professionals on an initial and continuous basis in connection with selecting and engaging the services of an investment manager for a particular strategy and participating in a wrap, dual contract or other managed account program. In the course of providing services to Retail SMAs who have financial advisors, TAL generally relies on information or directions communicated by the financial advisor acting with apparent authority on behalf of its client. TAL may provide or make available at no charge various reports or materials to certain Program Sponsors and other financial intermediaries who typically use TAL services and products. These reports may analyze a prospective client’s current holdings or show the effect of performance of a TAL composite over a particular time period in a manner directed by the Program Sponsor or intermediary. Such reports are not intended to constitute investment advice, research or recommendations. Certain Retail SMA programs impose policies and restrictions that limit the trading and investment options (such as participating in new issues, investing in certain securities, trading with certain broker-dealers, etc.) that would otherwise be available for Institutional Separate Accounts and Funds. As a result, Retail SMAs may be excluded from potentially attractive trading and investment opportunities. Clients should consult with their financial advisors regarding the terms and features of their Retail SMA program. TAL maintains procedures for executing specific transactions directed by a client or its financial advisor in a client’s account for tax reasons. Under these procedures, TAL will generally follow the directions of a client or its financial advisor regarding harvesting tax losses or gains, subject to certain scope, amount and timing limitations. Generally, the directions entail a repurchase of the sold security after the “wash sale” (thirty (30) day period (e.g., in the case of equities)), or a purchase of another appropriate security (e.g., in the case of bonds). TAL generally relies in good faith on directions communicated by a financial advisor acting with apparent authority on behalf of its client. In providing such directions, the client and its financial advisor are responsible for understanding the merits and consequences of their directions in light of the client’s particular tax situation. Daily market fluctuations may affect the dollar amount of gain or loss with respect to certain investment decisions. The monetary benefit derived from tax loss selling, for example, may not exceed the risk of not being fully invested during that time. Executing tax sales (and repurchases) may adversely affect performance. TAL is not a tax advisor, and therefore clients should consult with their tax specialist to review their particular tax situation. TAL may invest in ETFs or other pooled vehicles, including during the wash sale period. ETFs and other funds have certain imbedded costs, including management fees, of which the client account will bear a proportionate share while it is invested in the ETF or other fund. Other Advisory Services TAL provides limited investment advice as well as portfolio monitoring, trading and other investment-related services for proprietary assets owned by the TIAA Trust, N.A. under an investment services agreement. The advice and services that TAL provides covers a variety of publicly traded investments, including, without limitation, certain types of broadly syndicated commercial and industrial bank loans. Formalization and Scope of Advisory Services TAL formalizes its advisory relationship with a client through certain protocols such as the execution of an investment advisory agreement with the client (e.g., for Retail SMA dual contract and Institutional Separate Accounts) or the acceptance of new account documentation with respect to such client (e.g., for a discretionary Wrap Fee Program client). TAL does not provide advice outside of the confines of a formal advisory arrangement. Communications made in the marketing and sales process (including requests for proposals, requests for information, portfolio reviews, general written materials on products, strategies, and services, educational materials, etc.) are not intended and should not be relied upon as advice or a recommendation. Prior to the formalization of an advisory relationship, prospective clients and existing clients (with respect to new or different services) should make any decisions regarding any specific course of action based on their own needs and circumstances and in consultation with their own independent advisors. For the avoidance of doubt, nothing shall prohibit or impede a client from voluntarily or otherwise communicating directly with or providing information to any governmental or regulatory authority about their accounts, any underlying facts or circumstances, or disputes or concerns. TAL’s services are limited to the scope of a formalized arrangement with respect to specific services (e.g., discretionary investment management to a particular strategy). TAL does not provide any fiduciary services outside of such formalized arrangement. Any TAL communication outside the scope of a formalized arrangement to any prospect, client, financial advisor or other intermediary should not be relied upon as advice or a recommendation. Different products, services and strategies provided by TAL (and those offered or made available through various intermediaries, financial advisors and Program Sponsors) have different features, terms and conditions, risks, and direct and indirect compensation and profitability, among other things. Therefore, TAL (and an adviser) may have differing incentives and interests in marketing, offering, providing or making available different products, services or strategies. Prospects and clients, with the advice of their independent advisors, should carefully determine and select the products, services and strategies that best meet their needs. Investment Restrictions Institutional Separate Accounts and Retail SMAs TAL’s discretionary authority over an account is generally subject to directions, investment guidelines and limitations imposed by the client and, in the case of a Retail SMA, the Program Sponsor. TAL seeks to follow reasonable directions, investment guidelines and limitations. Although TAL seeks to provide individualized investment advice to its discretionary client accounts, TAL will not be able to accommodate investment restrictions that are unduly burdensome or materially incompatible with TAL’s investment approach (including restrictions affecting more than a stated percentage of the account), and reserves the right to decline to accept, or to terminate, client accounts with such restrictions. Funds and Other Pooled Investment Vehicles When TAL exercises discretionary authority with respect to a Fund’s assets, it seeks to do so in a manner that is consistent with the Fund’s investment objectives, strategies and limitations as disclosed in the Fund’s prospectus or other applicable disclosure documents. TAL’s discretion is also subject to the oversight of the Fund’s governing body (e.g., board of directors) and also may be subject to the oversight of another investment adviser. Wrap Fee Programs The services provided by TAL to Retail SMAs may differ from the services provided to its Institutional Separate Accounts and other clients who do not participate in Wrap Fee Programs. The investment strategies TAL uses in managing Wrap Fee Program accounts are similar to those offered to its other clients but may involve fewer securities holdings due to smaller account sizes, and less ability for customization. There may be limitations on the ability of Retail SMAs to invest in equity initial public offerings and non-U.S. ordinary securities. In many cases there are limitations on the ability of TAL in the ordinary course to communicate directly, on its own initiative, with program clients, without going through the Program Sponsor. Also, strategies, restrictions and guidelines may vary among programs. In consideration for providing investment management services to Wrap Fee Program accounts, TAL receives a portion of the wrap fee paid by Wrap Fee Program participants to the Program Sponsor. For dual contract accounts, TAL generally receives its fees directly from the client. When trading equity securities for accounts in Retail SMA programs, TAL will typically trade directly through the Program Sponsor or the Program Sponsor’s broker-dealer affiliate. In Wrap Fee Programs that permit TAL to trade away from the Program Sponsor or its broker-dealer affiliate, for certain investment strategies and asset classes other than equity securities, when TAL believes such Program Sponsor or its affiliate cannot provide best price or execution under the circumstances, TAL will trade away from such parties. Depending upon the level of the wrap fee charged by a Program Sponsor, the amount of portfolio activity in a client’s account, the value of the custodial and other services that are provided under a Wrap Fee Program arrangement and other factors, a wrap fee client should consider whether the wrap fee would exceed the aggregate cost of such services if they were to be provided separately. Similarly, a non-wrap fee program client paying separate fees should consider whether the fees charged by different parties for custody, advisory services, portfolio management services, securities execution and other services would exceed the aggregate cost of such services if they were provided in a wrap fee arrangement. Some broker-dealers serving as custodian charge fees for settling transactions executed through other broker-dealers. Wrap Fee Program clients should review all materials relating to their program (including the program brochure) regarding the program’s terms, conditions and fees, and consider the advantages, disadvantages and overall appropriateness of the program in light of the client’s particular circumstances. Assets Under Management As of December 31, 2023, TAL managed $368.6 billion in discretionary assets under management and $14.0 million in non-discretionary assets under management.