Description of Advisory Firm Asset Dedication, LLC (“Asset Dedication”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Limited Liability Company formed in 2002 under the lawsof the State of Delaware. Headquartered in San Francisco, California, The Firm is owned and operated by Steve Huxley, Managing Director of Research; Brent Burns, President and Chief Compliance Officer; Jeremy Fletcher, Managing Director, Investments; Dan Yeoman, Managing Director, Product Development. Description of Advisory Services Asset Dedication offers investment management and financial planning services using the Asset Dedication strategy. The Asset Dedication strategy seeks to achieve a client’s long - term goals by synchronizing equity securities with investment-grade fixed income securities that match the client’s cash flow needs. Asset Dedication provides sub-advisory investment management services to clients of third-party investment advisors (“Third-Party Advisors") who have contractually hired Asset Dedication. Asset Dedication also provides some advisory investment management and financial planning services through Investment Advisor Representatives who are employees of Asset Dedication, (“In-House Advisors”). Working with Asset Dedication The following process is applicable to Asset Dedication's management of client assets: 1. Investment Advisory Agreement – Prior to Asset Dedication providing investment management services, the client and/or the Advisor will be required to enter into a formal agreement with Asset Dedication. Asset Dedication works with clients in the following ways: A. Asset Dedication has a direct investment management agreement with the client that authorizes Asset Dedication to charge the account for the amount of Asset Dedication’s investment management fee and to directly remit that management fee to Asset Dedication; B. Asset Dedication has a direct investment management agreement with the client that authorizes Asset Dedication to charge the account for both the Third-Party Advisor’s management fee and Asset Dedication’s investment management fee and to directly remit the Third-Party Advisor its fee and Asset Dedication our fee C. Third-Party Advisors charge

clients for their management fee and Asset Dedication’s investment management fee and remit Asset Dedication’s fee to us. 2. Custodial (Separate Account) Agreement – Prior to Asset Dedication providing investment management services, the client will be required to enter into a separate account custodial/clearing agreement with the broker-dealer/custodian (“custodian agreement”) in order for the broker- dealer/custodian to custody the client’s account assets. The custodian agreement may authorize the broker-dealer/custodian to debit the account for the amount of Asset Dedication’s investment management fee and to directly remit that management fee to Asset Dedication; 3. Financial Planning – Before having Asset Dedication manage an account for a client, the client’s Advisor will obtain information sufficient to determine the client’s financial situation and investment objectives; 4. Portfolio Based on Client’s Plan – The Advisor will direct Asset Dedication to implement a portfolio strategy that they determine is the best fit for the client’s financial plan. Asset Dedication employs the Critical Path Analysis Data Sources, which uses historical index data from multiple providers to create a historical audit of an investor’s specific financial scenario; 5. Termination -- The investment advisory agreement between Asset Dedication and the client and/or Advisor will continue in effect unless terminated by either party by written notice in accordance with the terms and conditions of the investment advisory agreement. Any investment management fee shall be prorated through the date of termination. Types of Investments Asset Dedication provides investment strategies using the following types of securities:
• U.S. government and agency bonds, including inflation-indexed bonds
• Investment-grade municipal bonds
• Investment-grade corporate bonds
• Equity securities (i.e. public company stocks)
• Exchange traded funds (ETFs)
• Open-ended mutual fund shares
• Certificates of deposit
• Money market mutual fund shares for cash equivalent positions Client Assets Managed by Asset Dedication, LLC The amount of client assets managed by Asset Dedication totaled $2,538,962,898 as of December 31, 2023, all assets being managed on a discretionary basis.