Description of Harbor Harbor Investment Advisory, LLC (“Harbor”, “our” and/or “we”) is an investment adviser and broker-dealer providing investment advisory and brokerage services to our clients (“Client”, ”you”, and/or “your”). The firm is registered with the United States Securities and Exchange Commission (“SEC”), and various states, and is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Harbor has been registered since 2010 and is 100% owned by Harbor Investment Management, LLC. It is important to understand that investment advisory services and brokerage services are separate and distinct from each other and each is governed by different laws and by separate arrangements that we have with our Clients. The specific services or investment strategies that we provide and our legal duties to you in each arrangement are described in detail in our applicable agreements between you and Harbor. In its capacity as an investment adviser, Harbor provides investment advisory services (“Advisory Services” or “Advisory Programs”) to its advisory Clients across a broad range of asset classes, strategies, and investments, which are described in this Brochure. Separately, Harbor provides wrap fee programs where the Client pays Harbor a single, bundled, or wrap fee for investment advice, transaction services, administrative expenses and other fees and expenses, which are described in the Harbor Form ADV Part 2A Appendix 1 Wrap Fee Program Brochure (“Wrap Fee Brochure”). In its capacity as a broker-dealer, Harbor also offers brokerage account services (“Brokerage Services”) that allows you to invest through a commission or transaction-based account, and that may be more appropriate than investing through Advisory Services, if you do not want ongoing investment advice or management of your account, but instead desire only periodic or on-demand recommendations. By utilizing Brokerage Services, Harbor will make recommendations which are suitable for your account based on information you provide, but we will not necessarily monitor your account unless we have specifically agreed to provide you with that service. Brokerage Services are separate from, and are not described in this Brochure. In addition, when we are providing investment advice with respect to your IRA or other ERISA qualified plan, including advice to roll over assets from an employee benefit plan to an IRA, we are acting as a fiduciary and must follow the impartial conduct standards under ERISA and Section 4975 of the Internal Revenue Code. Asset Information As of December 31, 2023, Harbor had Regulatory Assets Under Management (“AUM”) and Assets Under Administration (“AUA”) of approximately: Regulatory Assets Under Management: Discretionary: $2,710,900,000 Non-Discretionary: $2,517,700,000 Total AUM: $5,228,600,000 Brokerage Assets Under Administration*: $3,459,000,000 Total Assets: $8,687,600,000 * AUA refers to assets held in non-advised brokerage accounts at Harbor. Advisory Services Working with a registered investment adviser representative (“Financial Advisor”), investment advice, financial planning and portfolio management services are provided on a continuing basis, which includes managing Client assets among cash, stocks, mutual funds, exchange traded funds (“ETFs”), bonds, variable annuities and other securities (collectively “Assets”). Our advice and services are also based on your stated investment objectives for your investment portfolio account (“Account”). We will execute investment recommendations in accordance with information gathered in the Harbor New Account Form, the Harbor Master Advisory Agreement (“Advisory Agreement”), and other documents which describe the investment objectives of Clients and a description of their Assets, earnings, tax status, acceptable levels of investment risk, imposed investment restrictions, and other information.1 Based on this information Harbor will provide a variety of investment related services including, but not limited to:
• Provide ongoing managed Advisory Services pursuant to the Advisory Agreement,
• Assisting Clients in determining investment objectives and establishing an investment implementation strategy,
• Performing due diligence on third-party asset managers (“Portfolio Manager”) and individual securities,
• Performing agency brokerage transactions for the Account effected by Harbor in its capacity as introducing broker and executed by Pershing LLC (“Pershing”); and
• Performing administrative services including, but not limited to, the processing of deposits and withdrawals from the Account pursuant to the Client’s instruction. Envestnet Services Harbor offers certain Advisory Services through an integrated third-party service and technology provider, Envestnet Portfolio Services, Inc., Envestnet

Asset Management, Inc., and/or their affiliates (collectively, “Envestnet”) for various administrative, investment advisory, investment management, model portfolio management, overlay management, tax overlay services, Environmental, Social and Governance (“ESG”) overlay services, investment and manager due diligence, research, reporting, trade implementation, compliance monitoring, operational support, and/or other services. Envestnet is not a tax advisor nor does it provide any tax advice; Client should consult with Client’s tax consultant prior to investing in the tax overlay service. The Advisory Program selected by the Client is defined in the Advisory Agreement and the Envestnet Statement of Investment Selection (“SIS”) agreement, when applicable. Certain fees payable to Envestnet will be charged to your Account, which are further defined in the Advisory Fee Section of the Advisory Agreement, when applicable. For a complete description of Envestnet services, please refer to the Envestnet Form ADV Part 2A and Form Part 2A Appendix 1, which is available here, or upon request and free of charge. Advisory Programs Harbor and its Financial Advisor offer several different Advisory Programs and Services depending on the investment objectives of the Client, which are described as follows: Harbor Manager Select (“Manager Select”) In the Manager Select program, your Financial Advisor assists you with limited due diligence to assist you in selecting and engaging one or more individual Portfolio Managers in a manner consistent with your investment objectives without discretion. Client selects and engages Portfolio Managers, on a “dual contract” basis, to provide investment management services including the investment and re- investment of the Assets in your Account. Services provided and applicable fees charged by the Portfolio Managers are governed under a separate agreement maintained directly between Client and the Portfolio Managers. Harbor Investment Consulting (“Harbor Consulting”) The Harbor Consulting program is an investment management, consulting and reporting service, where your Financial Advisor assists you to determine the allocation of your Assets and to manage the Assets in your Account, and Assets held outside of your Account with third-party custodians or other broker-dealers, in a manner consistent with your investment objectives, on a non-discretionary basis. For Assets you have specifically identified for investment, Harbor will assist you in evaluating the investments and/or Portfolio Managers with you being responsible for the final decision on the selection of all investments, Portfolio Managers, and other Assets. Harbor will not affect any transactions on your behalf at third-party custodians or broker-dealers, and Client is responsible for separately making arrangements with outside parties regarding commissions, charges, trailing and other fees and account services. 1 Harbor provides certain Clients with tax consulting and compliance services pursuant to separate agreements with the Clients to whom these services are offered. The agreements specify the services to be provided and any fees to be charged. These services are not offered to all Harbor Clients. Retirement Plan Services Harbor offers Discretionary Investment Management Services, Non-Discretionary Investment Management Services and/or Retirement Plan Consulting Services to employer sponsored retirement plans and their participants. Depending on the type of plan, and the specific arrangement with the Sponsor, Harbor may provide one or more of these services. Financial Planning Services (“Financial Planning”) Harbor offers Financial Planning which may be comprehensive or limited in scope depending on a Client’s particular needs. The financial plan may include, but is not limited to, review and prioritization of the Client’s goals and objectives, development of a net worth statement, cash flow summary and insurance analysis, review of investment holdings, and development of an investment management strategy. A financial plan may also include financial projections and analysis, in addition to education funding, retirement and estate planning analyses. The scope of the Financial Planning, including fees, proposed length of the engagement and a description of any conflicts of interest are defined in a letter of engagement which is executed in advance between the Client and Harbor. Wrap Fee Programs Harbor sponsors five wrap fee programs to include the Harbor Advisor Discretionary, the Harbor Advisor Non-Discretionary, the Harbor Separately Managed Account, the Harbor Unified Managed Account, and the Harbor Fund Strategist Program. These programs are described in detail in Harbor’s Form ADV Part 2A Appendix 1 Wrap Fee Program Brochure.