Introduction BNY Mellon Securities Corporation (“BNYMSC,” “Firm,” “We,” “Our” or “Us”) is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) and as a broker-dealer under the Securities Exchange Act of 1934 (the “1934 Act”); is a member of the Financial Industry Regulatory Authority (FINRA); and is registered with the National Futures Association (NFA) as an introducing broker. BNYMSC is a corporation organized under the laws of the State of New York. BNYMSC is a wholly owned subsidiary of BNY Mellon Investment Adviser, Inc. (“BNY Mellon Investment Adviser”) and an indirect subsidiary of The Bank of New York Mellon Corporation (“BNY Mellon”). BNYMSC has been providing investment advisory services to individuals and institutions since 2001. We provide investment advisory services to wrap programs sponsored by non-affiliated banks, broker-dealers and other financial intermediaries (“Program Sponsors”) by: (i) sub-advising separate account portfolios (“Traditional Wrap Program(s)”); (ii) providing model portfolios (“Model Delivery Program(s)”); or (iii) directly advising on investors’ separate account portfolios (“Dual-Contract Program(s)”). In Traditional Wrap Programs and Dual-Contract Programs, BNYMSC executes discretionary securities transactions in an account in the name of the wrap program client (“Wrap Client(s)”), subject to any investment restrictions specified by the Wrap Client. With respect to Model Delivery Programs, BNYMSC provides model portfolios to the Program Sponsor, who then executes securities transactions on behalf of the Wrap Clients. Investment advisory services are provided to Model Delivery Programs on a non-discretionary basis. We do not have discretionary investment authority with respect to any Wrap Client accounts in Model Delivery Programs (although we may, depending upon our contractual arrangement with the Program Sponsor, be granted authority over proxy voting, regulatory reporting or similar non- investment functions). For purposes of this Brochure, we will collectively refer to Traditional Wrap Programs, Model Delivery Programs and Dual Contract Programs as “Wrap Programs.” BNYMSC provides portfolio management services to Traditional Wrap Program and Model Delivery Program Wrap Clients pursuant to an agreement with the Program Sponsor and, with respect to Dual-Contract Programs, pursuant to an investment advisory agreement with the Wrap Client. In connection with these Wrap Programs, BNYMSC may engage affiliated or non-affiliated investment managers (each a “Delegated Manager”) to perform certain investment advisory services on BNYMSC’s behalf, including providing investment recommendations to BNYMSC based on a particular investment strategy (the “Strategy(ies)”). The Delegated Manager is responsible for monitoring, evaluating and adjusting the investment recommendations based on the Delegated Manager’s investment research, experience and judgment. Currently, BNY Mellon Advisors, Inc. (“BNYM Advisors”), Newton Investment Management North America LLC (“NIMNA”), Newton Investment Management Limited (“NIM”) and Walter Scott & Partners Limited (“Walter Scott”), all of which are affiliated investment managers, serve as Delegated Managers to BNYMSC. We, BNYM Advisors, NIMNA, NIM and Walter Scott are registered investment advisers and BNY Mellon Investment Management firms. BNY Mellon Investment Management is one of the world’s leading investment management organizations and one of the top U.S. wealth managers, encompassing BNY Mellon’s affiliated investment management and global distribution firms. BNY Mellon is the corporate brand of The Bank of New York Mellon Corporation. BNYMSC may also give advice to a municipal entity or obligated person regarding the investment of proceeds of a municipal security, and this will be done in our investment adviser capacity. Please see Item 7 of this Brochure for more information on these types of clients. As described in more detail below, we also offer advisory services not described in this Brochure, in particular as the sponsor of a wrap fee investment program (the BNY Mellon Managed Asset Program). If you would like more information, please consult our Form ADV Part 2A, Appendix 1 – Wrap Fee Program Brochure, which is available at www.adviserinfo.sec.gov. Third-Party Wrap Programs Traditional Wrap Programs In a Traditional Wrap Program, a Wrap Client enters into an advisory agreement with the Program Sponsor and the Program Sponsor enters into a sub-advisory agreement with BNYMSC. Under a Traditional Wrap Program, BNYMSC is retained by the Program Sponsor, and Wrap Clients select BNYMSC from among the investment advisers that the Program Sponsor presents to them. Upon accepting management of a Wrap Client’s account (“Wrap Account”), BNYMSC provides investment advisory services to the Wrap Account in accordance with the investment guidelines applicable to the investment strategy selected by the Wrap Client; the investment guidelines, if any, specified by the Program Sponsor with respect to the applicable Wrap Program; and the investment restrictions, if any, specified by the Wrap Client. In connection with Traditional Wrap Programs, BNYMSC may perform some or all of the following services: - providing investment advisory services for Wrap Accounts; - facilitating trading for Wrap Accounts with Program Sponsors and other broker-dealers; - managing Wrap Accounts and implementing the Delegated Manager’s investment strategy recommendations; - monitoring the Delegated Manager’s strategy guidelines, the Program Sponsor’s Wrap Program guidelines and the Wrap Clients’ investment guidelines; - participating in consultations with financial advisors of the Program Sponsors regarding administration of Wrap Accounts; - undertaking secondary suitability reviews; - facilitating the instructing of corporate actions; - conducting proxy voting on a Wrap Client’s behalf, if so directed; and - filing certain regulatory reports. Portfolio transactions for Wrap Clients of Traditional Wrap Programs are generally directed by BNYMSC to the Program Sponsor for execution but may also, in certain circumstances, be directed to a non-sponsoring

broker-dealer in an effort to seek best execution. Please see Item 12 of this Brochure for more information about the selection of broker-dealers when executing securities trades on behalf of Wrap Clients. Model Delivery Programs In Model Delivery Programs, BNYMSC is retained by the Wrap Program Sponsor to provide non- discretionary portfolio recommendations, which take the form of a portfolio model related to a particular strategy and not tailored to any specific Wrap Client. The Program Sponsor retains full discretion to accept, modify or reject such recommendations and the Program Sponsor (or a third party retained by the Program Sponsor to perform services for the Wrap Program, such as an overlay manager) is generally responsible for implementing the ultimate investment decisions. BNYMSC does not know the identity of, or any other pertinent information about, the Wrap Clients for whom the Program Sponsor has elected to use BNYMSC’s portfolio model. Unlike Traditional Wrap Programs or Dual-Contract Programs, BNYMSC does not have discretionary investment authority with respect to any Wrap Client accounts in Model Delivery Programs. In connection with Model Delivery Programs, BNYMSC may perform some or all of the following services: - facilitating model delivery to the Program Sponsor; - facilitating the instructing of corporate actions; - conducting proxy voting on a Wrap Client’s behalf, if so directed; and - filing certain regulatory reports. Dual-Contract Programs In Dual-Contract Programs, a Wrap Client enters into an investment advisory agreement directly with BNYMSC and a separate agreement with the Program Sponsor. Upon accepting management of a Wrap Account, BNYMSC directly advises and manages the Wrap Account in accordance with the investment guidelines applicable to the investment strategy selected by the Wrap Client; the investment guidelines, if any, specified by the Program Sponsor with respect to the applicable Wrap Program; and the investment restrictions, if any, specified by the Wrap Client. As of the date of this Brochure, we do not advise any Dual-Contract Program Wrap Accounts but do offer discretionary investment advisory services to Wrap Programs that accept Dual-Contract Program Wrap Clients. In connection with Dual-Contract Programs, BNYMSC may perform some or all of the following services: - providing investment advisory services for Wrap Accounts; - undertaking suitability and Know Your Customer reviews; - facilitating trading with Program Sponsors (where available) and other broker-dealers; - managing Wrap Accounts and implementing the Delegated Manager’s investment strategy recommendations; - monitoring the Delegated Manager’s strategy guidelines, the Program Sponsor’s Wrap Program guidelines and the Wrap Clients’ investment guidelines; - participating in consultations with financial advisors of the Program Sponsors regarding administration of Wrap Accounts; - facilitating the instructing of corporate actions; - facilitating billing of Wrap Accounts; - conducting proxy voting on a Wrap Client’s behalf, if so directed; and - filing certain regulatory reports. Portfolio transactions for Wrap Clients of Dual-Contract Programs are generally directed by BNYMSC to the Program Sponsor for execution (where available) but may also, in certain circumstances, be directed to a non-sponsoring broker-dealer in an effort to seek best execution. Please see Item 12 of this Brochure for more information about the selection of broker-dealers when executing securities trades on behalf of Wrap Clients. BNYMSC has the right, at its discretion, to decline to provide investment advisory services, on a case-by-case basis, to new Wrap Clients of Program Sponsors. In addition to providing investment advisory and related services for Wrap Programs, BNYMSC may be retained by affiliated and non-affiliated investment managers to provide administrative and support services (“Administrative Services”) in connection with the investment advisory services that such managers have agreed to perform for wrap accounts of financial services firms who sponsor wrap fee investment programs. Wrap Clients of these Wrap Programs should also review the Brochures of the Delegated Manager and Program Sponsor, which will contain additional information about each of those firm’s investment advisory services. Other Accounts BNYMSC’s Role as a Program Sponsor to a Wrap Fee Investment Program: BNY Mellon Managed Asset Program BNYMSC also offers a proprietary wrap fee investment program, the BNY Mellon Managed Asset Program (“BNYM MAP”), for which BNYMSC serves as the program sponsor. BNYM MAP clients may invest in (i) mutual funds sponsored or managed by our affiliates (“BNY Mellon Mutual Funds”) or a combination of BNY Mellon Mutual Funds and selected mutual funds from third party mutual fund families, (ii) equity investment strategies through one or more separately managed accounts managed by professional investment advisory firms, including BNYMSC, (iii) municipal bonds through a separately managed account managed by an affiliate, Insight North America LLC, or (iv) a combination of these products. For more detail with respect to BNYM MAP, please refer to BNYMSC’s Form ADV Part 2A, Appendix 1 - Wrap Fee Program Brochure, available at www.adviserinfo.sec.gov. Assets Under Management As of December 31, 2023, we managed $6.124 billion for clients, of which $697.4million was on a discretionary basis and $5.427 billion was on a non-discretionary basis. Class Actions; Litigation: It is our policy that we do not advise, initiate or take any other action on behalf of clients relating to securities held in the client’s account managed by us in any legal proceeding (including, without limitation, class actions, class action settlements and bankruptcies). We do not file proofs of claims relating to securities held in your account and do not notify you or your custodian of class action settlements or bankruptcies relating in any way to such account. Typically, custodians submit filings in connection with class action settlements and may also handle bankruptcy filings. You should consult with your custodian and other service providers to ensure such coverage.