TIM is an investment adviser that provides investment management services on a discretionary basis to a wide variety of clients. TIM became registered as an investment adviser with the SEC in December of 2003. TIM is controlled by each of James T. Evans, Penny M. Hubbard and Jason L. Stephens by virtue of their respective ownership of its voting securities. TIM's services are described in detail below. TIM is not engaged in any other business, other than providing investment advice and does not control any other firm. Discretionary Investment Management Services TIM provides discretionary Investment Management Services to various types of clients, including individual, retirement plan, corporate and foundation clients. It also provides services to registered investment companies. Before services begin, a representative of TIM reviews each client’s financial assets, investment needs, tolerance for risk, and investment objectives. During this process, clients are provided the opportunity to request reasonable restrictions on the management of their accounts. From this initial overview, TIM’s Portfolio Manager and the client develop specific objectives and guidelines for TIM to follow while managing the client’s portfolio. TIM will exercise discretionary trading authority while providing services. This means that TIM Portfolio Managers have the authority to purchase and sell securities of their choice and in the amounts and at the times they believe it is suitable for the client's account to do so. TIM does not act as custodian for any client assets. TIM does, however, instruct each client’s custodian on how to settle securities transaction orders placed for the client’s account by TIM. TIM does not assure or guarantee the results of any of its recommendations; thus, losses can occur from following TIM’s advice pertaining to any investment or investment approach, including using conservative investment strategies. As of December 31, 2023, TIM had $2,135,401,000 in assets under discretionary management. Investment Management of Thompson IM Funds, Inc. TIM is the investment advisor for the Thompson LargeCap, Thompson MidCap, and Thompson Bond Funds (collectively, the "Funds"). TIM provides the Funds with personnel, facilities, and daily supervision of its business affairs, all subject to the oversight of the Fund's Board of Directors. Different portfolio managers are assigned to each Fund as needed to implement investment strategies designed to achieve each Fund's investment objectives. Investment Management for

ERISA Accounts Management Services TIM is available to provide discretionary management and consulting services to ERISA accounts. Under the discretionary service arrangement, TIM agrees to supervise and direct the investment choices made available to retirement plan participants. Typically, TIM will decide, with the plan sponsor, what types of investments to make available to plan participants. Securities recommendations may include stocks, bonds, mutual funds (including the Funds), ETF's and other investments. TIM then supervises and alters the mix of investments available to the plan as it deems necessary. TIM has contracted with various investment management firms for certain 401(k) services, including administrative and marketing support, as well as their services as an ERISA 3(38) Investment Manager with full discretion for investment selection and monitoring. And will use such services when determined to be in the best interest of the client. Retirement Plan Consulting Services TIM provides consulting services to retirement plan sponsors. These services include recommending a menu of funds consistent with the plan's investment objectives and restrictions. Then TIM monitors the investments in the plan and provides reports to the plan sponsor about performance results. TIM also provides recommendations to the plan sponsor about making changes in the investment mix when it deems it appropriate to do so. Participant Education Services TIM also provides participant education services to plan sponsors. These services include conducting group meetings with plan participants to discuss investment options available to them and how participants can select and make investments within the plan, and review investment performance. Services to Other Advisers TIM may provide management for other advisers or advisory service firms (“Program Sponsors”), which have provided TIM’s name to prospective clients as a manager willing to provide management services to the clients. To establish these business relationships, TIM enters into a sub‐adviser or other agreement with an adviser or Program Sponsor. Under the terms of these agreements, TIM agrees to manage clients introduced to it in return for a fee paid by the adviser or Program Sponsor. The adviser or Program Sponsor then presents accounts to TIM and, using discretionary authority granted by the clients, TIM manages the clients’ accounts on a continuous basis. Typically, each client’s primary contact is with the adviser or Program Sponsor, not TIM.