The Company Commerce Brokerage Services, Inc. (“CBSI”) is a registered securities brokerage firm, a federally registered investment advisor, and a licensed insurance agency. Registration as an investment advisor does not imply a certain level of skill or training. CBSI was founded in October 1985 and has been doing business as an investment advisor since January 2002. CBSI is registered with the Securities and Exchange Commission. CBSI is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). CBSI is actively engaged in the securities business and offers a full range of investment products. CBSI is a wholly-owned subsidiary of Commerce Bank, which in turn is wholly owned by Commerce Bancshares, Inc., a publicly held bank holding company. CBSI is an affiliate of Commerce Investment Advisors, Inc. (“CIA”), a Registered Investment Advisor, which serves as the advisor to the Commerce Funds, a Registered Investment Company. Services CBSI provides the following advisory services and analysis to individuals: 1) analysis of current customer non-advisor investment holdings, 2) non-advisor investment account holdings summary 3) research regarding a specific investment account related matter and 4) non-discretionary advisory services. CBSI will act in the capacity as program sponsor and as a sub-advisor for Clients who wish to establish accounts to be managed on a discretionary basis by associated persons of The Commerce Trust Company (“CTC”), a division of Commerce Bank, Envestnet Asset Management, Inc. (“Envestnet”) or other independent asset managers (“Sub- Advisor”). CBSI has entered into an agreement with CTC and Envestnet to provide Clients with both discretionary investment advisory services and operational support services. CBSI may act in more than one capacity, including as the program sponsor, a Client's primary advisor, or a sub-advisor. Envestnet may also act in more than one capacity, including co- advisor to Client along with CBSI, portfolio manager, overlay manager or a sub-advisor. Envestnet has also been retained to provide operational and support services, which includes the use of any systems provided by or through Envestnet. These systems provide asset performance analysis, customer diagnostic reports, and periodic account reports. This support and use of Envestnet’s systems will also be available to non-discretionary accounts. Dollar Cost Averaging (DCA) Automation CBSI utilizes Envestnet’s platform to offer our clients Dollar Cost Averaging (DCA) Automation. Dollar Cost Averaging (DCA) refers to the investment technique of purchasing a fixed dollar amount at regular schedules irrespective of the price of the shares. More shares are purchased when prices are low, and fewer shares are bought when prices are high. The advantage of this strategy is to minimize downside risk and avoid market timing anxiety. Dollar cost averaging is a strategy that is better suited for investors with a lower risk tolerance and a long-term investment horizon. With DCA Automation we can setup your account on an automated investment schedule, the total dollar value to be dollar cost averaged into the account, and the first date funds are to be invested. The Programs CBSI will introduce qualified Clients to the Commerce Horizons program (“Program”). CBSI, in offering the Commerce Horizons program to Clients, provides professionally managed, fee-based advisory programs through an arrangement with CTC, Envestnet and other Sub-Advisors. The Commerce Horizons program consists of three (3) advisory account programs:
•The Fund Manager Account (“FMA”), for which CTC will provide portfolio management on a discretionary basis
•The Portfolio Manager Account (“PMA”), which Envestnet will provide management on a discretionary basis
•The Investment Manager Account (“IMA”), for which CBSI will provide services on a non-discretionary basis, and which will be managed by designated Sub-Advisor(s) on a discretionary basis.
The investments in an FMA will be primarily mutual funds and exchange traded funds (“ETFs”). The investments in a PMA will be primarily stocks, ETFs and mutual funds. The investments in an IMA will be primarily equity securities and equivalents and fixed income securities. Mutual fund investments in a Program account are limited to investment company “no-load” or “load-waived” share classes, or the equivalent. Program accounts are professionally managed fee-based accounts where the Client pays an annual fee (“Advisory Fee”) for investment management and advisory services. CBSI receives a portion of the Client’s Advisory Fee for Program accounts. CBSI also manages accounts on a transaction basis under the broker-dealer where clients are charged a commission and or sales charge for each transaction. Based on the total assets in the Program, each Client is able to establish the cost of the services provided through the Program and compare such costs to the costs of similar services provided by other programs. A Client may invest at a lesser overall fee or cost by investing in the market directly and incurring normal brokerage and transaction charges or by investing in mutual funds with similar objectives as the funds available through this Program. Clients will receive from National Financial Services, LLC (“NFS”) monthly/quarterly statements detailing each Client's securities and cash balances, deposits, withdrawals, transactions, charges or transfers. Clients will also receive a confirmation for transactions cleared through NFS. Clients may elect to receive a quarterly confirmation report in lieu of receiving individual trade-by-trade confirmations. Upon request, Clients may have access to their CBSI account(s) online. Commerce Horizons accounts will receive a quarterly performance report (“Quarterly Report”) prepared by Envestnet at the end of the quarter in which a new account has been brought under management and every quarter thereafter. This report, in conjunction with the statements from NFS, provides a list of the securities in the Client's portfolio, the quantity of the positions, the cash balance, the market prices as of the date of the report, the total portfolio valuation and an Advisory Fee invoice. At least annually, CBSI or the Financial Advisor will contact each Client to determine whether there have been any changes in the Client's financial situation or investment objectives, and whether the Client wishes to impose any reasonable restrictions on the management of the Program account or reasonably modify existing restrictions. In addition, Clients will be notified quarterly to contact the Financial Advisor, in order to confirm whether there have been any changes to the Client’s financial situation, investment objectives or if Client would like to impose or modify investment restrictions on the account. The Program is intended to comply with Rule 3a-4 under the Investment Company Act of 1940. Each Client’s account is managed on the basis of the Client’s financial situation and stated investment objectives, in accordance with any reasonable investment restrictions imposed by the Client on the management of the assets in the account. As of December 31, 2022, CBSI had approximately $650 million in assets under management (AUM) in the Commerce Horizons program. Fees The Advisory Fee is calculated and charged in advance based on the prior quarter’s period ending balance of the Program account. On a quarterly basis Envestnet calculates Program account Advisory Fee and issues instructions to NFS, which is authorized to deduct the Advisory Fee directly from the Client’s Program account. The initial Advisory Fee for the first calendar quarter (or part thereof) in which the Client participates in the Program shall be calculated and debited on the 10th day of the month (or the next business day if the 10th is a non-business day) after Program account’s start date and shall be the Advisory Fee for the first calendar quarter (or part thereof) in which the Client participates in the Program. The initial Advisory Fee for any partial calendar quarter shall be appropriately pro- rated based on the number of calendar days in the partial quarter. Thereafter, the Advisory Fee shall be calculated at the beginning of each calendar quarter based on the value of Program account on the last business day of the prior calendar quarter and debited from the Program account on the 10th of January, April, July, October (or the next business day if the 10th is a non-business day). If a Program account is opened in the last month of a calendar quarter, the Advisory Fee will be calculated and debited for the remaining period in the calendar quarter plus the next calendar quarter on the 10th day of the month (or the next business day if the 10th is a non-business day) after Program account’s start date. For example, an account that opened on 9/15/22 would have fees debited on 10/10/22 for the periods (9/15/22 – 9/30/22) and (10/01/22 – 12/31/22). If a Client invests $10,000 or more in any Program account after the beginning of a calendar quarter, the Advisory Fee for that quarter will be recalculated and pro-rated as of the day of the additional investment. The Advisory Fee will be debited on the 10th day of the month (or the next business day if the 10th is a non-business day) following the month the additional investment is made to the Program account. If a Client withdraws $10,000 or more in any Program account after the beginning of a calendar quarter, the Advisory Fee for that quarter will be recalculated and pro-rated as of the day of the withdrawal. The pro-rated Advisory Fee for that withdrawal will be credited on the 10th day of the month (or the next business day if the 10th is a non-business day) following the month the withdrawal is made from the Program account. If a Client makes a partial withdraw less than $10,000 from the Program account after the beginning of a calendar quarter, the Client will not be credited back any portion of the Advisory Fee previously paid by the Client on the withdrawn Program assets. The Advisory Fee will be based on the fair market value of the Program assets as calculated on the last business day of the previous calendar quarter. Envestnet will determine fair market value for Advisory Fee calculation purposes. CBSI will rebate back to the Client’s Program account, on a quarterly basis, the Client’s pro-rata share of any management fees charged by CIA for any Commerce Funds held in the Program account. CBSI and Envestnet will not charge an Advisory Fee that is more than six months in advance. The Advisory Fee will be charged quarterly unless otherwise agreed by all parties in advance. The Advisory Fee is negotiable and may differ between Client’s holding similar portfolios or having the same size of assets under management, regardless of the type of Program account selected. There are

other factors that may impact the fees charged on an account including, prior or existing client relationships, the anticipated number or volume of trades and anticipated future services. Clients with multiple Commerce Horizons accounts (as owner or for their benefit), and household accounts for their immediate family members (such as, spouse and legal dependents residing at the same address) may request CBSI to link Program accounts (Fund Manager, Portfolio Manager, and Investment Manager) for Advisory Fee calculation purposes. Program accounts may only be linked if the underling Program accounts are subject to the standard Advisory Fee as outlined in each Annual Fee Schedule enclosed. Only accounts in the same program can be linked together for Advisory Fee calculation purposes. For example, Fund Manager Accounts can only be linked together with other Fund Manager Accounts; and Portfolio Manager Accounts can only be linked together with other Portfolio Manager Accounts. A Fund Manager Account and a Portfolio Manager Account may not be linked together for Advisory Fee calculation purposes. By linking Program accounts, a portion of the combined accounts may qualify for the next lower Advisory Fee level, which would in effect reduce the overall account fee compared to the Advisory Fee payable if each account were calculated separately. Program accounts with a negotiated Advisory Fee may not be eligible to be linked for Advisory Fee calculation purposes. A Client may deposit or transfer securities into a Program account and place a restriction on the sale or liquidation of a particular security by requesting CBSI to hold the security in the account, but outside of the Program (“Unsupervised Assets”). Unsupervised Assets are only available in the Fund Manager Account. A limited number of Unsupervised Assets may be held on a temporary basis in a Program account and will not be subject to the Advisory Fee. Unsupervised Assets will be indicated on the Quarterly Report; however, Unsupervised Assets will not be included in the performance of the Program on the Quarterly Report. CBSI, in its sole discretion, reserves the right to require the Client to move the non- managed Unsupervised Assets to a CBSI brokerage account. CBSI may accept accounts below the preferred account opening minimum asset value, as specified in the fee schedules enclosed, based upon a number of factors including the Client's anticipated future additions to the account(s) and total investment relationship with CBSI. Fund Manager Account (“FMA”) The preferred opening minimum account value for each FMA is $35,000 of cash or securities. Each FMA will be required to maintain a balance of at least 3 percent in cash or cash equivalents. FMA Annual Fee Schedule Annualized Fee* 1st $75,000 2.20% Next $175,000 2.10% Next $250,000 1.90% Next $500,000 1.65% Next $1 million 1.45% Over $2 million 1.30% *Annualized Fee column represents the maximum investment management fee CBSI will charge the Client, excluding the fees of the underlying mutual funds and ETFS in the portfolios. Portfolio Manager Account (“PMA”) The preferred opening minimum account value for each PMA is $250,000 of cash or securities. Each PMA will maintain a balance in cash or cash equivalents, typically ranging between 2 and 5 percent. PMA Annual Fee Schedule Annualized Fee* 1st $500,000 2.55% Next $500,000 2.30% Next $1 million 2.10% Over $2 million 1.90% *Annualized Fee column represents the maximum investment management fee CBSI will charge the Client, excluding the fees of the underlying mutual funds and ETFs in the portfolios. Investment Manager Account (“IMA”) The preferred opening minimum account value for an IMA is typically $200,000 of cash or securities for each Sub- Advisor. In addition, the minimum investment required by each individual Sub-Advisor(s) must be met. Each IMA will maintain, based upon the Sub-Advisor's investment style, a balance in cash or cash equivalents, typically ranging between 2 and 5 percent. Each IMA will typically have one account established for each individual Sub-Advisor (“Sub-Account(s)”). In addition, one account will typically be established to act as the conduit for all funds or securities moving in and out of the IMA and between Sub-Advisor(s) (“Master Account”). There are no management fees for assets held in the Master Account. IMA Annual Equity & Balanced Fee Schedule IMA investments held in the equity and balanced Sub-Advisor’s Sub-Account(s) are subject to the IMA Annual Equity & Balanced Fee Schedule: IMA Fee Schedule Annualized Fee* 1st $500,000 2.75% Next $500,000 2.45% Next $4 million 2.15% Over $5 million 1.80% IMA Annual Fixed Income Fee Schedule IMA investments held in the fixed income Sub-Advisor’s Sub-Account(s) are subject to the IMA Annual Fixed Income Fee Schedule: Annualized Fee* 1st $500,000 2.15% Next $500,000 1.80% Next $4 million 1.65% Over $5 million 1.45% *Annualized Fee column represents the maximum investment management fee CBSI will charge the Client on the entire IMA, inclusive of CBSI, Envestnet, and Sub-Advisor fees. Clients with multiple Sub-Accounts will receive a combined weighted average Annualized Fee based on each Sub-Account’s respective Annual Fee Schedule. Termination Client has the right to cancel the Investment Advisory Agreement (“IAA”) within five (5) business days from the date the Financial Advisor, on behalf of CBSI, agrees to and accepts the Program’s IAA. Client must provide written notice of such cancellation to CBSI. In such event, any Advisory Fee paid by the Client shall be refunded to the Client. However, the Client shall be responsible for any transactions executed, market fluctuations, custodial (IRA) fees, or account fees prior to CBSI’s receipt of the written cancellation notice. The IAA may be terminated by either party upon thirty (30) days prior written notice to the other party. If the IAA is terminated and all Program assets are withdrawn from the Program account prior to the end of a quarter, the pro-rata portion of the Advisory Fee will be reimbursed to the Client. Other Fees Clients, who either do not participate in the Commerce Horizons program or who have accounts not part of the Commerce Horizons program (i.e. CBSI brokerage accounts), will be subject to and incur the normal brokerage fees and transaction charges for their non-Commerce Horizons program accounts. CBSI and its agents receive compensation from non-advisory business (brokerage accounts) in the form of commission or sales charges. Due to this, CBSI Financial Advisers may have a conflict of interest in recommending a non-advisory (transaction-based) brokerage account instead of an advisory account based on the amount of compensation agents may receive, rather than on the client’s best interest. CBSI prohibits charging a commission on a transaction for a security that is being managed in a Commerce Horizons account. Transaction fees for Client self-directed investments that are not included in the Commerce Horizons program, such as Unsupervised Assets, are subject to the standard CBSI brokerage fees or charges. Clients opening a qualified account, such as an IRA or other qualified account, are subject to the fees and charges from the account custodian, which is NFS. All applicable fees are detailed for this type of account in the NFS Premiere Select Custodial Agreement and Disclosure Statement. Clients with a self-directed purchase of a specific mutual fund or security not part of the Program account portfolio will be charged either a sales charge (front-end, contingent, or no fee in the case of a no-load fund) established by the fund company and detailed in the fund's prospectus, or a commission, as detailed in CBSI’s commission schedule. Certain charges may be imposed by outside third parties in connection with investments held in the Program account. These include the following types of charges: mutual fund 12b-1 fees, mutual fund management fees, mutual fund short-term redemption fees, issuer administrative servicing fees, certain deferred sales charges on previously purchased mutual funds, other transaction charges and service fees, and IRA and Qualified Retirement Plan fees. Other parties may also receive a portion of these outside third-party fees. Further information regarding charges and fees assessed by an investment company, other securities sponsor, or portfolio manager is available in the appropriate prospectus or disclosure statement. In addition to the fees and charges described above, a Client may incur redemption fees, when the portfolio manager to an investment strategy determines that it is in the Client’s overall interest, in conjunction with the stated goals of the investment strategy, to divest from certain mutual funds prior to the expiration of the minimum holding period of the mutual funds. Some mutual funds also assess redemption fees to investors upon the short-term sale of its funds. Depending on the particular mutual fund, this may include sales for rebalancing purposes. Please see the prospectus for the specific mutual fund for detailed information regarding such fees and charges. The Envestnet Form ADV Part 2A Narrative Brochure, as provided to Horizons Clients at account opening, and the IAA detail the circumstances where CTC, Envestnet, NFS or CBSI may receive additional remuneration, either direct or indirect, for transactions or money market investments. CBSI could indirectly be a beneficiary of Envestnet or NFS remuneration by virtue of it being a fully-disclosed broker-dealer with NFS. CBSI or any of its affiliates may receive additional fees, including management fees, 12b-1 fees or administration fees for services performed in the capacity of an investment advisor, or in any other capacity, for any mutual fund, including the Commerce Funds. In addition, the mutual funds, including the Commerce Funds, may purchase securities from or enter into repurchase agreements with CBSI or its affiliates. Compensation CBSI and its agents will be compensated under a percentage of assets method for the Program. The Advisory Fee for this Program is charged quarterly in advance based on the prior quarter’s period ending balance. The Advisory Fee will vary by the type of Program account and by the value of the Program account. CBSI, its agents, CTC, Envestnet and Sub-Advisor(s) (if applicable) will be compensated based upon the established fee schedules in this document. The amount of compensation received may vary based on the Program selected and may also be more or less than compensation received from a traditional commission based CBSI brokerage account. The portion of compensation received by CBSI which is paid to the Financial Advisor may vary based upon changes to the CBSI Financial Advisor incentive programs, bonus compensation plans or attained production level.