Firm Description Checchi Capital Advisers, LLC (CCA or the Firm) is a registered investment adviser, which provides portfolio management services to high net worth individuals, trusts, foundations, charitable organizations, pension and profit sharing plans, corporations, and other business entities. CCA was founded in 2007. Principal Owners CCA is owned by Loeb Capital West, LLC, Canal Capital Partners, LLC , two trusts controlled by Kathryn D. Checchi, a Principal of CCA and Samuel T. Pfister. Adam D. Checchi, the Managing Member of CCA, is the sole member of Loeb Capital West, LLC. Asset Management CCA provides sophisticated globally diversified portfolio strategies for investors’ core long-term liquid equity and fixed income investments. Customized investment portfolios will be constructed using proprietary statistical and mathematical models which maximize diversification and tax efficiency while minimizing turnover, transaction costs and management expenses. CCA’s strategies are based on individually constructed domestic and foreign fixed income and equity portfolios that use statistical sampling to approximate the distribution of the world’s liquid traded assets by value. The gross returns and volatility of CCA portfolios should approximate the pre-tax returns of the major world indices weighted by market capitalization. CCA will include tax optimization and transaction cost reduction algorithms that optimize the client’s tax position. Assets are invested primarily in fixed income and equity, utilizing exchange-traded funds, where appropriate, to achieve maximum diversification. All securities are purchased or sold through a brokerage account. The brokerage firm charges a fee for stock and bond trades. CCA does not receive any compensation, in any form, from fund companies or brokers. Investments may also include: equities (stocks), warrants, corporate debt securities, certificates of deposit, municipal securities, investment company securities (variable

life insurance, variable annuities, and mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Pooled Investment Vehicles CCA serves as an investment adviser to two insurance dedicated funds, the CCA Core Return Insurance Fund and the CCA Aggressive Return Insurance Fund. CCA manages the Insurance Funds based on the investment goals and objectives as outlined in the Series Supplements to the Insurance Funds. Separately Managed Accounts CCA provides continuous advice to clients regarding investment of client funds based on the individual needs of the client. Through personal discussions in which goals and 5 Checchi Capital Advisers, LLC objectives based on a client’s particular circumstances are established, CCA will create and manage a portfolio based on that client’s needs. Sub-Advisory Relationships CCA provides services to other affiliated and unaffiliated registered investment advisers on a sub-advisory basis. Tailored Relationships CCA tailors advisory services to the individual needs of the client. The goals and objectives for each client are discussed and then an individual portfolio of domestic and foreign fixed-income and equity is constructed using a statistical sampling process to approximate the distribution of the world’s liquid traded assets by value. The gross returns and volatility of CCA portfolios should approximate the pre-tax returns of the major world indices weighted by market capitalization. CCA will include tax optimization and transaction cost reduction algorithms that optimize the client’s tax position. Clients may impose restrictions on investing in certain securities or types of securities. Wrap Fee Programs CCA does not participate in a Wrap Fee Program. Client Assets CCA manages client accounts and, as of December 31, 2023, these assets totaled approximately $1.9 billion. All accounts are managed on a discretionary basis.