Description of the Firm BC Advisors, LLC (the “Firm”) is a federally registered investment adviser that provides services to its clients (each, a “Client” and together “Clients”) in the form of investment advisory services, as further described below. The Firm is a Pennsylvania limited liability company which has been in business since February 2005. The Firm’s principal owner is Theodore A. Beringer. Types of Services Offered The investment advisory services (the “Services”) consist of the ongoing and continuous review of each Client’s investment assets and consolidated performance reporting. The Firm compiles information on, reports on, values and analyzes Client assets. The Firm does not hold itself out as specializing in a particular type of advisory service. The Services are tailored to the individual needs of each Client, primarily through the analysis performed for each Client and each security recommended. The Firm reviews the investment objectives as well as the potential tax implications of an investment when choosing what security to recommend and how long each Client should hold such security. Holding periods for an investment will vary depending on the type of product, its sales commission, and its purpose in the overall portfolio structure for each Client. Securities which are considered include long term purchases which are generally held for at least one year, short term purchases which are generally sold within one year, trading securities which are generally sold within thirty (30) days of purchase and short sales. The Firm may recommend the use of certain third party money managers to direct the investment of Client assets. In such cases, the Client appoints the third party manager to invest the Client assets in accordance with the recommendations of the Firm’s asset allocation plan. The Client appoints the third party manager(s) with authority to manage the accounts through a separate agreement with the third party manager. The Firm will perform on‐going due diligence and monitoring of the third party managers to ensure they manage the account(s) in accordance with the asset allocation plan. Clients may terminate their relationship with the Firm at any time by giving the Firm thirty (30) days written notice. The Firm will provide a Client with all written work completed as of the date of termination. Client Tailored Services and Client Imposed

Restrictions Each Client portfolio is unique, based on the investment objectives, time horizon, income needs, tax implications, and risk profile of each Client. Clients may impose restrictions on investing by communicating to the Firm restrictions on securities, asset classes, managers, custodians or any other personal restriction the Client would like to impose on its portfolio. Wrap Fee Programs The Firm participates in a wrap fee program, in which the Firm receives a portion of the wrap fee for Firm’s services. There are certain differences between how wrap fee accounts are managed and how other accounts are managed. Specifically, the account minimum and fees are negotiated with managers and custodians in advance, often resulting in reduced fees and minimums. In the wrap program, the Client hires the wrap program sponsor and the fee payable to the sponsor includes the fees payable to the sponsor, the custodian, the Firm, and all brokerage and trading costs. The same or similar investment advisory services may be available from other investment advisers for a lower fee. The advisory fee (which includes transaction costs) may be more or less costly than paying for the services separately, depending upon the investment advisory fees charged, the number of transactions for the account, the type of investments selected for each Client’s account, the level of brokerage and other fees that would be payable if the Client obtained the services available under the program individually. Depending on the investment selected and the services to be provide, the fee schedule may be as set forth above, or it may be negotiated. Assets Under Management As of December 31, 2023, the Firm had $4,215,060,873 in non‐discretionary assets under management. Miscellaneous The Firm maintains a business continuity plan in the event of a disruption in business. Among other things, the plan details how Clients may access their accounts in the event of an emergency. A copy of the plan is available for review upon request. As reflected in the Firm’s privacy policy, the Firm prohibits the public disclosure of any Client related nonpublic, personally identifiable information, except as permitted by law. Such Client related information is maintained in a safe and secure manner. Questions regarding the Firm’s privacy policy should be directed to the Firm at 856‐ 793‐5000.