Popular Securities, LLC (hereinafter “Popular Securities” or “firm” or “we”) is an SEC-registered investment adviser with its principal place of business located in Hato Rey, Puerto Rico. Popular Securities began conducting investment advisory business in 2001. Popular Securities is also a registered securities broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA), and the Securities Investor Protection Corporation (SIPC) that has been in business since 1997. Popular, Inc., a financial holding company, is the sole owner of Popular Securities. Popular, Inc. is a public company with no shareholders owning 25% or more of its shares. We offer investment advisory services to clients through Fidelity Managed Account Xchange Program or (“FMAX Program”) sponsored by Fidelity Institutional Wealth Adviser LLC or (“FIWA”), a third-party Registered Investment Advisor. Custody, clearing and other services are provided by National Financial Services LLC or (“NFS”). FIWA is not a corporate affiliate of Popular Securities or NFS. NFS does not provide investment advisory services of any kind in connection with the FMAX Program. The FMAX Program platform utilizes services provided by Envestnet, who operates the technology platform on which FMAX Program functions and renders investment advice to Popular Securities and clients, including recommending an appropriate asset allocation and specific investment managers or investment products with respect to those assets invested in the FMAX Program (the “Program Assets”). As part of Popular Securities investment management services, we will discuss with you your financial situation and offer suggestions for one or more asset allocation portfolios consistent with your investment objectives and risk tolerance. We will periodically, but no less than annually, analyze your portfolio in light of your current financial situation and implement any changes as authorized by you. You are responsible for promptly advising Popular Securities of any significant changes in your financial or personal circumstances. The Firm provides various investment advisory services to clients which include financial planning, fund strategist portfolio, unified managed accounts, separately managed accounts, and advisor directed models. Clients may invest in one or more of the programs available through the FMAX Program. FIWA sponsors the platform used for the FMAX Program and the Firm is the FMAX program sponsor and investment managers available on the platform manage their respective model portfolios. Mutual Fund and ETF Asset Allocation Program Allows Popular Securities to create models by selecting from a variety of mutual funds and/or exchange trades funds (“ETF”) on the FMAX Platform. With access to a universe of managed models composed of funds, models can better align with client risk profiles and investment objectives. Popular Securities designs the model portfolios including the target asset mix using no-load funds or ETFs. The models follow a market-oriented investment philosophy with low holdings turnover. Popular Securities receives historical market analysis, risk/return analysis, research, and continuing education from the providers of the mutual funds and ETFs in the program. The Separately Managed Account Program (“SMA”) Provides investors access within multiple accounts to individual stocks or bonds through professionally managed portfolios and allows advisors to combine SMAs with mutual funds and/or exchange traded funds. Assets invested in separate accounts are managed by investment advisers as sub-managers pursuant to entered agreements. The Unified Managed Account Program (“UMA”) Provides investors access within a single account to multiple investment products including mutual funds, exchange traded funds, other securities, funds strategist programs, and separate managed accounts. Assets invested in a single account for a customized portfolio corresponding to clients’ needs. Popular Securities is responsible for selecting the specific, underlying investment vehicles in the appropriate model to meet your needs. In certain instances, Popular Securities may determine the target asset mix in addition to selecting the underlying investment vehicles. Advisor Directed Model This model allows for assets to be invested in mutual funds, ETFs and/or other securities and investments to be managed by Popular Securities. Specific investment choices and asset allocation will be selected by Popular Securities, who will have full discretionary authority over these types of account granted by the Terms and Conditions agreed upon with the clients. Reporting Only Services Clients have the ability to allow Popular Securities to designate certain holdings as reporting only, meaning they are held within an FMAX account but are not managed or overseen through the FMAX Program. Popular Securities will be responsible for monitoring and managing the designated holdings as reporting only. Popular Securities will be responsible for any fee calculation and billing administration on the reporting only assets. Non-FMAX Program Services Popular Securities also offers investment management services through certain fixed income money managers (“Fixed Income Managers”) outside of the FMAX Program. The Fixed Income Program, held outside of the FMAX Program, will require the client to enter into a separate agreement with the Fixed Income Manager containing separate terms and conditions and important disclosures. A copy of the Fixed Income Manager’s Disclosure statement will be provided.

If the client enters into an advisory agreement with a Fixed Income manager, the client will be appoint the Fixed Income Manager as their investment adviser and will be granting full authority to invest, reinvest and otherwise deal with the assets invested under the Fixed Income Program, including without limitation the authority to select, allocate and reallocate the assets under the Fixed Income Program to different Sub-Managers and to delegate such investment discretion to such Sub-Managers. Such discretionary authority allows the Fixed Income Manager to make all investment decisions with respect to the assets invested under the Fixed Income Program and when it deems appropriate and without prior consultation with you, to buy, sell, exchange, convert and otherwise trade in any bonds, mutual funds, and other securities. In selecting investment vehicles and Sub-Managers for the assets invested under the Fixed Income Program, the Fixed Income Manager will consider factors it deems relevant, including but not limited to, your investment goals and objectives, and any reasonable restrictions imposed by you on the management of such assets, including the designation of particular securities or types of securities that should not be purchased for your accounts, or that should be sold if held in such accounts. You should understand and be willing and able to accept the risk involved in the selection of investments before entering into an advisory agreement. There is no assurance that your investment objective will be achieved. Financial Planning Services Popular offers financial planning services to its advisory clients. For such clients, a financial planning report is created to assist advisory clients in the area of personal financial planning, and can cover or analyze various topics, including, but not limited to, net worth, budgeting and cash flow, retirement planning, asset allocation, college financial planning, and disability planning. Wrap Fee Programs A wrap-fee program is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes administrative fees, management fees, and commissions. If you participate in this program, we will provide you with a copy of FIWA’s disclosure document. You will also be provided with separate disclosure documents for each independent Sub-Manager managing a separate account for you. In addition, if the investment program recommended to you is a wrap fee program, you will also receive the Appendix 1 or equivalent wrap fee brochure provided by the sponsor of the program. If you participate in a wrap fee program, you will pay a single fee, which includes our money management fees, certain transaction costs, and custodial and administrative costs. We would receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in a wrap fee program may be higher or lower than those that you might incur by separately purchasing the types of securities available in the wrap fee program. You are encouraged to review all disclosure document(s) to learn more about the particular characteristics of each of the services offered within the wrap fee program. Types of Investments We primarily offer advice on various types of securities, including, but not limited to, equity securities, corporate debt securities, municipal securities, mutual fund shares and ETFs. ETFs and mutual funds may be invested in real estate, oil and gas. Additionally, we may advise you on other types of investments that we deem appropriate based on your stated goals and objectives. We may also provide advice on other types of investments held in your portfolio at the inception of our advisory relationship. You may request that we, FIWA, the Fixed income Manager and/or Sub-managers refrain from investing in particular securities or certain types of securities. You must provide these restrictions in writing. We will employ our reasonable best efforts to accommodate your request. Assets Under Management As of December 31, 2023, we provide continuous management services for $2,228,633,352 in client regulatory assets. The Firm also provides services to $63,755,213 in client non-regulatory assets, for which Popular Securities provides limited investment advice. Other Investment Advisory Services We provide co-asset management services to the Popular Mezzanine Fund, LLC (the “Mezzanine Fund”) a private equity fund organized as a limited liability company under the laws of the Commonwealth of Puerto Rico that is designed to provide customized financing solutions to privately held companies organized or engaged in a trade or business in Puerto Rico that meet the requirements of the Community Reinvestment Act. Our services to the Mezzanine Fund generally consist of the following: (i) determining the composition of the Mezzanine Fund’s investment portfolio (ii) identifying, evaluating and negotiating the structure of such investments; and (iii) recommending changes to the securities and other assets that may be acquired by the Mezzanine Fund from time to time. The Mezzanine Fund is a subsidiary of our affiliate Banco Popular de Puerto Rico. The other co-asset manager of the Mezzanine Fund is Enhanced Puerto Rico LLC a wholly owned company of Enhanced Asset Management. Enhanced Asset Management is a subsidiary of Enhanced Capital Group. We also provide limited advisory services to retirement plans and/or personal trust accounts held outside the firm and/or held at our affiliate, Banco Popular of Puerto Rico.