CAP STRAT is a registered investment adviser founded in 2009 by Will Woodall, Barbara Best and Nancy Rizzuto. CAP STRAT provides institutional investors, corporate retirement plans (defined contribution and defined benefit), high net worth individuals, trusts, and estates with both discretionary and non-discretionary consulting and investment advisory services, including manager recommendations and monitoring, asset allocation, investment policy, financial planning and portfolio management services based on customized asset allocations that CAP STRAT designs based upon clients’ individual investment goals, policies, objectives and risk tolerances. We provide these services both in a one-time report outlining CAP STRAT’s conclusions and recommendations, and on a continuous basis. In addition, CAP STRAT provides general consulting services to corporate retirement plans including plan design, fee analysis and negotiation, employee education and provider management. Nancy Rizzuto, Alison Bettonville, Barbara Best, Mike Rarey, Mike Warford, and Neil Davies are principal owners and officers of CAP STRAT. The William F. Woodall and Janet M. Woodall Living Trust is the majority shareholder of CAP STRAT. One of Will Woodall’s family members, who is not a supervised person and not involved in the daily operations of CAP STRAT, serves as trustee to The William F. Woodall and Janet M. Woodall Living Trust. As of December 31, 2023, CAP STRAT had a total of approximately $19,147,821,636 in assets under management. $4,901,172,675 is managed on a discretionary basis and $14,246,648,961 is managed on a non-discretionary basis. Portfolio advisory and management CAP STRAT works with clients to develop an individually tailored, overall investment strategy. Based on information provided by a client and on a thorough analysis of the client’s investment objectives, policies, constraints and risk tolerance, we develop a customized strategy that is designed to help each client meet their desired investment goals. We document the resulting investment strategy. For institutional clients, such documentation is made in a written Investment Policy Statement (“IPS”), which includes a general investment plan and recommends an asset allocation (the percentage of assets to be invested in cash, bonds and stocks) that is designed to identify the mix of asset classes best suited for the client (in terms of risk and return). For institutional clients not requiring an IPS and our private wealth clients, we memorialize the preceding information using other written questionnaires and forms. CAP STRAT invests clients’ accounts in a mix of no-load mutual funds, exchange-traded funds (“ETFs”), collective trusts, limited partnerships, cash equivalents and fixed income and equity securities. For more information on the strategies and investments that CAP STRAT may use when implementing the investment strategies it develops with clients, see Item 8, “Methods of Analysis, Investment Strategies and Risk of Loss.” Asset Management Services CAP STRAT offers asset management services, which involves CAP STRAT providing you with continuous and ongoing supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we buy, sell or recommend for any other clients or for our own accounts. Conflicts can arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Investment Consulting Services We are available to provide financial and investment consultations on accounts not managed or maintained by us. Only accounts in which we are not “Investment Advisor” of record and therefore we do not have trading authority on the account are eligible for this service. Accounts are reviewed based upon your specific needs and desires for future financial goals and/or objectives. General or specific recommendations are provided to the client by CAP STRAT. The service provides continuous and regular consultations provided on a quarterly or more frequent basis. Through this service, we will not have any authority or responsibility to implement our recommendations. All final decisions to accept our advice and implement our advice are the responsibility of the client. If you have accounts reviewed by our firm and are unable to implement our investment recommendations, it is important to notify us so that we can properly adjust future recommendations. Clients are always responsible for notifying CAP STRAT of any changes to their financial situation or investment objectives. We will meet with the client as often as needed to determine the client’s financial situation and investment objectives and to find out if the client would like to impose and/or modify any reasonable restrictions on their accounts. It is important that you understand that CAP STRAT provides investment advice to other clients and gives them advice or take actions for them or for our personal accounts that is different from the advice we provide to you. We are not obligated in any way to recommend to you any security or other investment that we buy, sell or recommend for any other clients or for our own accounts. There can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Private wealth advisory services CAP STRAT works with you to develop a comprehensive financial plan that incorporates all aspects of your financial life as it evolves. We evaluate the financial impacts of your decisions as you reach certain milestones to help you make informed decisions about Medicare, Social Security, required minimum distributions (RMDs), and long-term care. Our comprehensive support includes cash flow planning, developing a tax efficient distribution strategy, charitable giving, and estate planning strategies. In the event that other significant and unforeseen events arise, our discussions and analyses will help you make informed decisions that also align with your finances. Economic Consulting Services. CAP STRAT provides clients with economic projections that could impact various client business activities (e.g., product demand, labor union wages, trends and outlook within their/related industries). Projections are based on CAP STRAT’s economic and investment framework and are customized based on the client’s most applicable economic performance drivers. We regularly discuss with clients the basis for and drivers of these projections, as well as the risks to, and standard errors around, them. Manager recommendations Beyond our discretionary investment advisory services, we also offer non-discretionary services whereby we recommend to a client one or more unaffiliated investment managers who will manage a portion of the client’s account. For institutional clients, CAP STRAT will provide the client with an Investment Manager Search Report that contains a list of investment managers whose investment philosophies and policies are, in our judgment, compatible with the client’s investment objectives, policies, constraints and risk tolerance outlined in their IPS. The search reports are designed to assist clients with interviewing the investment managers that we recommend, and, if necessary, we will coordinate those interviews between our clients and those recommended investment managers. These interviews enable the client to gain additional information regarding the investment managers’ investment philosophies, policies and business operations. We perform ongoing monitoring of investment managers that the client selects. For private wealth advisory clients, we

select from available investment options where appropriate, to best align with the client’s overall risk and return objectives. Retirement Plan Services CAP STRAT offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. We offer our services to various types of retirement plans and participants (i.e. individual account holders) that include, but are not necessarily limited to:
• 401(k) Plans
• Self-Directed Profit-Sharing Plans
• Employer Sponsored Group Profit Sharing (i.e. Defined Contribution) and Pension (i.e. Defined Benefit) plans Our retirement plan services can include the following services. The exact service and levels of services provided to each client will be outlined in the client’s agreement for services. Fiduciary Management 3(38) Services CAP STRAT provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. CAP STRAT will provide you with continuous and ongoing supervision over the designated retirement plan assets. This service can be provided at the Plan level or on an individual participant account level. CAP STRAT will actively monitor the designated retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with you. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services. CAP STRAT will monitor the investment options of the Plan and add or remove investment options for the Plan. CAP STRAT will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants.
• Default Investment Alternative Management. CAP STRAT will develop and actively manage qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c- 5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election.
• Investment Management via Model Portfolios. CAP STRAT will provide discretionary management via model portfolios. CAP STRAT manages Model Portfolios which are investment options available to Plan participants. If a Plan has elected to include CAP STRAT’s Model Portfolios as available options for the qualified retirement plan, then each Plan participant will have the option to elect or not elect the Model Portfolios managed by CAP STRAT and will be allowed to impose reasonable restrictions upon the management of each account by written instructions to CAP STRAT. If you elect to utilize any of CAP STRAT’s Fiduciary Management Services, then CAP STRAT 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 CAP STRAT hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Fiduciary Consulting 3(21) Services CAP STRAT provides the following Fiduciary Retirement Plan Consulting Services:
• Investment Policy Statement Preparation. CAP STRAT will help you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. CAP STRAT will provide you with general, non- discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement.
• Investment Selection Services. CAP STRAT will provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. CAP STRAT will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. CAP STRAT will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and CAP STRAT will make recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. CAP STRAT will provide you with non- discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5).
• Individualized Participant Advice. Upon request, CAP STRAT will provide one-on-one advice to Plan participants regarding their individual situations. We can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and CAP STRAT does not serve as trustee of the plan. CAP STRAT does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). Non-Fiduciary Services Although an investment adviser is considered a fiduciary and required to meet certain fiduciary duties, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. CAP STRAT provides clients with the following Non-Fiduciary Retirement Plan Consulting Services to institutional clients (qualified and non-qualified plans):
• Participant Education. CAP STRAT will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. CAP STRAT’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. CAP STRAT will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.
• Plan Development. CAP STRAT will assist you with the establishment of a qualified and/or non-qualified plan by working with you and a selected Third-Party Administrator. If you have not already selected a Third-Party Administrator, we shall assist you with the review and selection of a Third- Party Administrator for the Plan.
• Due Diligence Review. CAP STRAT will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers.
• Fiduciary File Set-up. CAP STRAT will help you establish a “fiduciary file” for the Plan which contains trust documents, custodial/brokerage statements, investment performance reports, services agreements with investment management vendors, the investment policy statement, investment committee minutes, asset allocation/asset liability studies, due diligence fields on funds/money managers and monitoring procedures for funds and/or money managers.
• Benchmarking. CAP STRAT will provide you benchmarking services and will provide analysis concerning the operations of the Plan. General Information 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. Plan sponsors and 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 clients’ responsibility 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, CAP STRAT cannot assure that investments will be profitable or assure that no losses will occur in their 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.