NFIS is wholly owned by Navy Federal Financial Group, which is a wholly owned subsidiary of Navy Federal Credit Union. NFIS began operations in September 2005. NFIS’ principal business activity includes acting as a dual registered investment advisory firm and broker-dealer. NFIS offers advisory clients portfolio management services for a fee. These services (known as “advisory services”) are offered through investment adviser representatives (“IARs”) of NFIS. Currently, all IARs are also registered with the firm’s affiliated broker/dealer, Navy Federal Investment Services, LLC. NFIS clients may also be clients of the broker/dealer, dependent upon the products and services the client has selected. Description of Primary Advisory Service The following pages list the programs offered by NFIS. In these programs, NFIS has discretionary authority to retain and terminate Third-Party Portfolio Managers who will be responsible for the portfolio management through discretionary asset allocation programs. An NFIS investment advisory representative meets with a potential client to discuss financial objectives, needs, risk tolerances, and financial status. The investment advisor representative will assist the client in determining the suitability and selection of the particular Program that will be used as well as the suitability of the model(s) selected within the program. The selected Third-Party Portfolio Manager will recommend a portfolio allocation with a specific investment recommendation. If the allocation is accepted by the client, the Third-Party Portfolio Manager is given discretionary authority to select and change portfolios as necessary. NFIS Advisory Program The NFIS Advisory Program is a program sponsored by NFIS, which provides clients with personalized asset allocation services using a wide range of mutual funds and exchange-traded funds based upon asset allocation models. Additionally, the NFIS Advisory Program provides clients with account monitoring, and rebalancing of funds, performance reporting and other advisory services, as well as trade execution and internet access to positions for a “wrap” fee. Under the NFIS Advisory Program, NFIS has the discretionary authority to retain and terminate Third-Party Portfolio Managers. The Third-Party Portfolio Manager shall act as the portfolio manager for accounts managed through the NFIS Advisory Program. The Third- Party Portfolio Manager shall have the full authority to supervise and direct the investment of monies contributed by the client to the NFIS Advisory Program account without prior consultation with the client. Subject to the limitations described in client responses to the Profile and Investment Strategy Report, or other appropriate suitability analysis, the Third-Party Portfolio Manager shall have unlimited investment discretion with respect to any changes to investments in the NFIS Advisory Program accounts, within the parameters of the selected portfolio model. This includes discretion to adjust asset allocations and replace or reduce the investment options in the NFIS Advisory Program portfolios. The Third-Party Portfolio Manager will have full authority to supervise and direct the investment of monies contributed by clients to the NFIS Advisory Program without prior consultation except that clients shall retain the ability to modify the Investment Strategy Report at any time and shall inform the NFIS investment adviser representative of any such modifications. The Third-Party Portfolio Manager, in its discretion and within the terms of the NFIS Advisory Program agreement executed between NFIS and the client, utilizes model portfolios to achieve the objectives of the various portfolio options offered under the NFIS Advisory Program. NFIS has no discretionary authority to select the investments in these NFIS Advisory Program accounts, but will have discretion to select the Funds to be liquidated if necessary to cover a debit balance in relation to the monthly fees or if a client requests a withdrawal of funds and the funds are not readily available in the Program account money market. Other than these specific liquidations, all transactions in NFIS Advisory Program accounts shall be initiated by the Third-Party Portfolio Manager. Clients participating in the NFIS Advisory Program will receive the Third-Party Portfolio Manager’s disclosure document in addition to NFIS’ brochure. Clients should review the Third-Party Portfolio Manager’s disclosure document for more information on the Third-Party Portfolio Manager. NFIS shall be responsible for, among other things: (1) determining client suitability for the NFIS Advisory Program and the recommended portfolio option; and (2) confirming with the client the accuracy and completeness of the information contained in the Profile and Investment Strategy Report. NFIS’ IARs shall communicate to clients the investments or separate account managers recommended by the Third-Party Portfolio Manager. NFIS will have discretionary authority to retain and terminate the Third-Party Portfolio Manager. NFIS offers programs through the Envestnet Platform and recommends various Third-Party Portfolio Managers through the platform. Envestnet includes wholly owned subsidiaries and the alternate names of Envestnet Asset Management Inc., (an unaffiliated registered investment advisor) Envestnet | PMC, Portfolio Management Consultants, and Envestnet Portfolio Solutions, Inc. (an unaffiliated registered investment advisor) and all herein shall be referred to Envestnet in this document. Digital Automated Portfolios NFIS also offers a Digital Investor Automated Portfolios product. This product is a fixed fee of $3.50 per month. Users complete a risk assessment and are then suggested a portfolio based on their risk tolerance. Portfolios are created and managed by Member’s Trust Company, and are cleared through DriveWealth, LLC they are comprised of ETFs and are weighted depending on the risk tolerance. The ETFs are as follows: SPDR Portfolio Developed World ex-US ETF, SPDR Portfolio Total Stock Market ETF, SPDR Bloomberg Barclays Aggregate Bond ETF, SPDR Portfolio Short Term Treasury ETF. There are six different risk portfolios available: Highly Conservative, Conservative, Moderately Conservative, Moderate, Moderately Aggressive, Aggressive, Highly Aggressive. Portfolios are rebalanced quarterly to account for portfolio drift. Envestnet Programs. – The following portfolio options are currently offered through Envestnet under the NFIS Advisory Program. NFFG Funds – Assets in this portfolio are limited to mutual funds. Mutual funds in this portfolio are selected based on each individual client’s needs with an emphasis on reaching the client’s overall investment objective. Each fund within this portfolio is selected for its individual strategy to fit within the confines of that client’s objective. Envestnet acts as the portfolio manager, objectively managing the portfolio in line with the client’s investment objective. Envestnet, as the registered investment advisor, provides ongoing investment monitoring and rebalancing. NFFG ETF – The NFFG ETF account is a 100% exchange traded fund (ETF) based managed account whereby Envestnet acts as the portfolio manager, objectively managing the portfolio in line with the client’s investment objective. The portfolios use exchange-traded funds (ETFs) designed to closely track the performance of a market index. Envestnet, as the registered investment advisor, provides ongoing investment monitoring and rebalancing. NFFG Index Plus – This strategy offers portfolios that seek to provide investors with the best complement of strategies available. It enables the advisor to leverage the resources from professional money managers to monitor and make changes to meet an individual client’s goals. These portfolios use active mutual funds in the categories where active managers have been more likely to outperform, and passive investments where, on average, active managers have been less likely to beat their benchmark. Envestnet acts as the portfolio manager, objectively managing the portfolio in line with the client’s investment objective. Envestnet, as the registered investment advisor provides ongoing investment monitoring and rebalancing. ActivePassive Portfolios – The Envestnet ActivePassive Funds are the building blocks used to create the ActivePassive Portfolios. The Third-Party Portfolio Manager Envestnet aims to enhance value to client portfolios through careful combinations of these funds, which feature both actively managed and passive (index-based) investments. Strategist Portfolios – The NFIS Strategist Portfolios offers mutual fund and exchange-traded fund (ETF) solutions that offer individual investors an actively managed portfolio comprised of carefully selected mutual funds and/or ETFs. Current Third-Party Portfolio Manager Offerings: BlackRock Investment Management, LLC. BlackRock Investment Management, LLC ("BlackRock") is an investment management firm that provides diversified investment management to institutional clients, intermediary and individual investors through various investment vehicles. Investment management services primarily consist of the management of equity, fixed income, multi-asset class, alternative investment, and cash management products. BlackRock offers its investment products in a variety of vehicles, including open-end and closed-end mutual funds, iShares® exchange traded funds ("ETFs"), collective investment trusts and separate accounts. We offer BlackRock ESG and non-ESG portfolios. The Target Allocation ESG Models are all-in-one, core portfolios with an extensive focus on companies that exhibit positive Environmental, Social, and Governance (ESG) characteristics. The portfolios are built with iShares ETFs with risk profiles ranging from moderate to aggressive. Brinker Capital, Inc. Brinker Capital is an investment management firm that provides customized investment products and services and offers a variety of asset allocation strategies, each targeting a specific investment objective, for both taxable and tax-exempt accounts. The strategies provide different balances of risk and reward depending on a client’s risk tolerance and time horizon and are designed to offer consistent, competitive performance while seeking to achieve attractive risk-adjusted returns over the long term. Brinker Capital monitors the performance of each fund and investment strategy and updates and modifies these strategies based on market conditions and Brinker’s investment outlook. Capital Group, Inc. Capital Group ("Capital") is one of the largest privately held investment management organizations in the world, serving thousands of leading institutions and millions of individual investors. Their roots date back to 1931, when Jonathan Bell Lovelace founded the Capital organization as a research-based company focused on helping investors in the wake of the 1929 Wall Street Crash. He believed that fundamental research is essential to achieving superior long-term investment results. Capital Group is globally recognized by investors seeking superior long-term investment results. In addition to managing the U.S.-based American Funds® family of mutual funds, Capital offers actively managed equity, fixed income and balanced investment portfolios through separate accounts, trusts and funds worldwide. Capital Group companies employ more than 7,500 associates globally. Capital Group's approach to portfolio management enables them to deliver superior long-term results for their clients. Fidelity Institutional Wealth Adviser, LLC Fidelity Investments ("Fidelity") was perhaps best known historically as a mutual fund company. Today, it operates multiple business lines, including investment management and advisory, banking and trust, and insurance. As a wholly-owned, indirect subsidiary of Fidelity Investments, Fidelity Institutional Asset Management (“FIAM”) offers traditional long-only equity, fixed income, asset allocation, and other customized investment solutions, including the Target Allocation Portfolios. The firm’s Alpha Model provides fund recommendations. The process employs regression analysis of the previous nine months of daily net returns of all active and passive Fidelity proprietary mutual funds in order to attribute the proportion of each fund’s return to systematic return and nonsystematic returns, or alpha. The alpha that is estimated in this analysis is used to rank funds relative to peers, and this ranking becomes an input in the fund selection process. The portfolio construction process uses optimization techniques that consider both the allocation guidance and the fund rankings to create a portfolio that balances relative portfolio risk exposures with capturing expected alpha. Frontier Asset Management, LLC Frontier Asset Management, LLC ("Frontier") is an independent investment advisory firm, registered with the SEC, and is majority owned and controlled by Frontier’s management team. Frontier's core business is providing investment management to the clients of independent financial advisors around the country. With a heavy emphasis on internal research, Frontier is an industry leader in investment manager due diligence, asset allocation, and portfolio construction. Frontier offers a wide range of investment strategies, each managed within a specified framework of return objectives and limits on risk. Frontier's investment strategies are intended for long-term investors. Goldman, Sachs & Co. Goldman, Sachs & Co. (GS&Co.), founded in 1869, is the principal United States broker-dealer subsidiary of The Goldman Sachs Group, Inc. In May of 1981, GS&Co. became a registered investment adviser under the Investment Advisers Act of 1940. Goldman Sachs is organized into four business segments: (i) Investment Banking; (ii) Institutional Client Services; (iii) Investing & Lending; and (iv) Investment Management. GS&Co.’s dynamic asset allocation approach combines strategic, long-term views with tactical tilts to create a diversified strategy that seeks to balance risk and return while navigating changing markets. MAPs seek diversification by strategically allocating to a variety of asset classes

and sub-asset classes for each risk profile. Members Trust Company Members Trust Company is organized as a national trust company that is owned by a consortium of credit unions and related organizations located throughout the U.S. Members Trust Company provides fee-based investment management and trust services. The service offerings of Members Trust Company include managed ETF portfolios and managed mutual fund portfolios, as well as customized managed account solutions. Navy Federal Financial Group, the parent company of NFIS, owns a portion (currently less than 10%) of Members Trust Company and the COO of NFIS serves as a member of the Board of Directors of Members Trust Company. The relationship between Navy Federal Financial Group, NFIS, and Members Trust Company creates a material conflict of interest. NFIS addresses that conflict of interest through due diligence reviews, financial audits, and an account review process to verify Members Trust Company fits the client’s investment needs. Further, Financial Advisors with NFIS are not incentivized or given any additional compensation for using Members Trust Company portfolios. Members Trust Company uses a conservative investment philosophy. In making portfolio decisions, Members Trust Company maintains a disciplined approach that is intended to manage downside risks. Members Trust Company provides active management utilizing passive ETFs to gain broad-based market exposures thereby mitigating company specific risk. ETFs provide portfolio managers greater flexibility and efficiency in maintaining and readjusting portfolio allocations across asset classes than individual bonds, stocks, or mutual funds. Other benefits of ETFs can include lower costs and increased liquidity and transparency. Portfolio options offered by Members Trust Company for the NFIS Advisory Program are based on long-term risk and return characteristics while incorporating Modern Portfolio Theory along with other portfolio design tools. Members Trust Company, Third-Party Portfolio Manager Referral Program – NFIS refers certain clients to Members Trust Company, and Navy Federal Financial Group receives an ongoing solicitor fee if such clients still maintain assets under the management of Members Trust Company. NFIS has a conflict of interest given that Navy Federal Financial Group, the parent company of NFIS owns a portion (less than 10%) of Members Trust Company and the COO of NFIS is a member of the board of directors of Members Trust Company. Please refer to Item 10.C.2 for additional details. Morningstar Investment Management, LLC Morningstar Investment Management LLC is a registered investment adviser and subsidiary of Morningstar, Inc. Model portfolio construction and ongoing monitoring and maintenance of the model portfolios are provided by Morningstar Investment Management, in some cases on behalf of Morningstar Investment Services. The model portfolios made available on the Envestnet platform may be offered by Morningstar Investment Management or Morningstar Investment Services and include exclusively or some combination of no-load/load-waived open-end mutual funds, ETFs, and common stocks. Envestnet | Portfolio Management Consultants (“PMC”) Envestnet | Portfolio Management Consultants (PMC) is the portfolio consulting group of Envestnet and is the manager of a set of discretionary investment products. PMC builds asset allocation strategies of a variety of mutual fund and ETF asset managers. PMC provides overlay management of the portfolios and provides ongoing investment monitoring and rebalancing. SEI Investments Management Corporation SEI Investment Management strategies invest across a range of SEI funds and fund managers to lessen the risk of manager concentration. Services are backed by SEI's research in behavioral finance, which supports blending tactical elements with strategic asset allocation in order to achieve greater diversification; available in both tax-managed and non-tax-managed versions. Vanguard Advisors, Inc. Vanguard was founded on a simple but revolutionary idea-that a mutual fund company should not have outside owners. From its beginning in 1975, Vanguard has been a very different kind of investment firm. To ensure that Vanguard's interests are aligned with those of its investors, Vanguard is structured in the U.S. as a "mutual" mutual fund company, owned by the Vanguard funds, which are owned by the investors who put their hard-earned money in them. Four decades later, Vanguard is still the only company in the industry structured this way. Throughout its history of serving investors, the unique ownership structure and client-first philosophy have driven many distinctive business decisions that set Vanguard apart. Vanguard has grown to become one of the world's largest investment management companies, with locations in the United States, Australia, the United Kingdom, Europe, Asia, and the Americas. Underlying it all has been its long-standing commitment to providing an exceptional value: outstanding performance and service at low costs. Unified Managed Accounts (UMAs) UMAs are offered by NFIS. A UMA account allows the layering of multiple Third-Party Portfolio Managers in one account for simplified account management and billing. Any of the above listed Third-Party Portfolio Managers can be combined with one another into a single UMA account. Private Wealth Consulting (PWC): PWC is for clients with $1,000,000 + to invest. PWC includes a consultation with adviser and client to understand required return, risk tolerance, unique investment objectives and circumstances, current portfolio analysis across asset allocation and manager selection. Portfolio recommendations based on Envestnet | PMC’s asset allocation and manager research output, with the ability to incorporate client specific tax and IMPACT (i.e., social) considerations. PWC services have an increased platform fee as follows: First $10,000,000 15 basis points Next $15,000,000 12 basis points Over $25,000,000 10 basis points Tax Overlay (Optional Service for additional fee) Provides a customizable solution for clients invested in fund strategist portfolios seeking to manage account tax consequences. The overlay services leverages Envestnet and Third-Party Technology risk optimization software to match risk characteristics of an unconstrained fund strategist portfolio through tax optimization algorithms. The tax management service is available for standalone fund strategist portfolio accounts; the service is not currently available to sleeve-level strategist portfolios within the unified managed account program. During the proposal process, the adviser will select the desired tax sensitivity (very high, high or moderate), which will influence the initial trading in either an existing or new account. The risk engine analyzes the portfolio changes and possible tax implications of implementing the manger’s updates and provides trade recommendations that balance the tax cost for the client’s portfolio risk measured by tracking error. Envestnet will place the corresponding trade execution order for the account in line with the tax implication analysis. Overlay Services Fee: 8 basis points on all assets utilizing the overlay service, Minimum Annual Per Account Overlay Services Fee: $40 Financial Planning Services NFIS, through its IARs, prepare and provide financial plans to NFIS clients. NFIS IARs will obtain the necessary data from the client to create the financial plan. The financial plan may include asset allocation, goal analysis, insurance analysis, education planning, portfolio analysis, and risk tolerance analysis. The client may receive a written financial plan from the NFIS IAR. In some instances, the results of the financial plan may lead to an investment recommendation. The client is not required to implement the financial plan. NFIS is not engaged in the practice of law or accounting and therefore does not offer legal or accounting advice as part of the financial planning process. Retirement Plans NFIS offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, we provide fiduciary management services through the NFIS Advisory Programs, as described above. If you elect to utilize any of NFIS’ Fiduciary Management Services then NFIS will be acting as an Investment Manager to the Plan as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and NFIS hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. The exact suite of services provided to a client will be listed and detailed in the advisory services agreement between NFIS and the retirement plan. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the responsibility of each individual client to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, NFIS cannot assure that investments will be profitable or assure that no losses will occur in the client portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. NFIS will disclose to the client, to the extent required by ERISA Regulation Section 2550.408b-2(c), any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practical). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the advisory services agreement between Navy Federal Investment Services and the retirement plan and any compensation or fees received in connection with such agreement that is required for the ERISA-covered plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b- 2(c)(1)(iv) or (vi), we will disclose to the client the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Termination of Services Either NFIS or the client may terminate services at any time by providing written notice to the other party. If the client terminates services within five business days of executing an agreement for services with NFIS, services will be terminated upon receipt of notice of termination without penalty. However, clients should be aware that they will still be subject to market risk during this period, meaning any declines in securities markets will likely reduce the value of the client’s Navy Federal Investment Services account assets. If services are terminated in the NFIS Advisory Program after the initial five business days, the date of termination shall be the date upon which the account manager receives notice of termination. Any unpaid fees as of that date shall be due and payable by the client. NFIS has 30 days from the date of termination to deduct fees from the client’s program account. Currently the termination fee is $125. Specialization NFIS specializes in providing asset management services through the selection of Third-Party Portfolio Managers. Type of Investments NFIS generally provides clients with advice regarding the selection of Third-Party Portfolio Managers. NFIS offers advice on the following types of securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Exchange-Traded Funds (ETFs)
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States government securities NFIS does not provide advice on foreign issues, warrants, options contracts on securities or commodities, futures contracts on tangibles or intangibles, securities exempted from registration, hedge funds, or interest in partnerships investing in real estate or oil and gas interests. Tailor Advisory Service to Individual Needs of Client NFIS’ asset management services are always provided based upon the specific needs of the individual client. The client is given the ability to impose reasonable restrictions including specific investment selections and sectors. Client Assets Managed by Navy Federal Investment Services, LLC In its capacity of holding discretionary authority to retain and terminate Third-Party Portfolio Managers of its portfolio management programs, NFIS has $1,016,882,342 of assets under management as of January 16, 2024