Alera Retirement Advisors has been in business since January 18, 2011. The Alera Group is the principal owner of Alera Retirement Advisors. Alera Retirement Advisors’ investment advisory services are currently limited to the discretionary management of investment portfolios in accordance with the investment objective(s) of the client. Alera Retirement Advisors generally does not provide financial planning or other consulting services. To the extent specifically requested by a client, Alera Retirement Advisors may provide limited consultation services to its investment management clients on investment and non-investment related matters. Any such consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis. Investment Management Services Alera Retirement Advisors can be engaged to manage all or a portion of a client’s assets. Alera Retirement Advisors intends to primarily allocate its client’s investment management assets, on a discretionary basis among Independent Managers (as defined below), mutual funds, and exchange traded funds. Alera Retirement Advisors may also provide advice about any type of investment held in a client’s portfolio. Alera Retirement Advisors also may render non-discretionary investment management services to clients relative to: variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, Alera Retirement Advisors either directs or recommends the allocation of client assets among the various investment options that are available with the product. The client assets shall be maintained at the specific insurance company or custodian designated by the product. It is Alera Retirement Advisors’ practice to tailor its advisory services to the individual needs of clients. Alera Retirement Advisors will ensure that each client’s investments are suitable for that client and consistent with their investment needs, goals, objectives and risk tolerance as well as any restrictions requested by the client. Clients shall have the ability to impose reasonable restrictions on the management of their account, including the ability to instruct Alera Retirement Advisors not to purchase certain securities or types of securities. Alera Retirement Advisors’ clients are advised to promptly notify Alera Retirement Advisors if there are ever any changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Alera Retirement Advisors’ management services. Use of Independent Managers As mentioned above, Alera Retirement Advisors recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment manager(s) (“Independent Manager(s)”), based upon the stated investment objectives of the client. The terms and conditions under which the client shall engage the Independent Manager(s) shall be set forth in separate written agreements between (1) the client and Alera Retirement Advisors and (2) Alera Retirement Advisors or client and the designated Independent Manager(s). Alera Retirement Advisors shall continue to render services to the client relative to the discretionary selection of Independent Manager(s) as well as the monitoring and review of account performance and client investment objectives, for which Alera Retirement Advisors shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Manager(s). When selecting an Independent Manager for a client, Alera Retirement Advisors shall review information about the Independent Manager(s) such as its disclosure statement and/or material supplied by the Independent Manager(s) or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that Alera Retirement Advisors shall consider in recommending Independent Manager(s) include the client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s), together with the fees charged by the wrap fee program sponsor and corresponding designated broker- dealer/custodian of the client’s assets, may be exclusive of, and in addition to, Alera Retirement Advisors’ investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by Alera Retirement Advisors, the designated Independent Manager(s), wrap fee program sponsor (if applicable), and corresponding broker-dealer and custodian. In addition to Alera Retirement Advisors’ written disclosure statement, the client shall also receive the written disclosure statement of the designated Independent Manager(s) and wrap fee program sponsor (if applicable). Certain Independent Manager(s) may impose more restrictive account requirements and varying billing practices than Alera Retirement Advisors. In such instances, Alera Retirement Advisors may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Manager(s) or wrap fee program sponsor. If Alera Retirement Advisors refers a client to certain Independent Manager(s) where Alera Retirement Advisors’ compensation is included in the advisory fee charged by such Independent Manager(s) and the client engages those Independent Manager(s), Alera Retirement Advisors shall be compensated for its services by receipt of a fee to be paid directly by the Independent Manager(s) to Alera Retirement Advisors in accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, as amended, and any corresponding state securities laws, rules, regulations, or requirements. Any such fee shall be paid solely from the Independent Manager(s) investment management fee or the program fee of the wrap fee program (as appropriate), and shall not result in any additional charge to the client.

Management Through Similarly Managed Accounts For certain clients, Alera Retirement Advisors may manage client portfolios by allocating portfolio assets among various securities on a discretionary basis using one or more of its proprietary investment strategies (collectively referred to as “investment strategy”). In so doing, Alera Retirement Advisors shall buy, sell, exchange and/or transfer securities based upon the investment strategy. Alera Retirement Advisors’ management using the investment strategy has been designed to comply with the requirements of Rule 3a-4 of the Investment Company Act of 1940, as amended. Rule 3a-4 provides similarly managed accounts, such as the investment strategy, with a safe harbor from the definition of an investment company. In accordance with Rule 3a-4, the following features have been specifically included in Alera Retirement Advisors’ management using the investment strategy: 1. Initial Interview – an initial interview is conducted with each client to determine the client’s financial circumstances, goals, acceptable levels of risk, any reasonable restrictions on the management of their account, and other relevant circumstances; 2. Individual Treatment – the client’s account is managed on the basis of the client’s financial circumstances and investment objectives; 3. Consultation – an Advisory Affiliate of Alera Retirement Advisors knowledgeable about the client’s account shall be reasonably available to consult with the client relative to the status and management of their account; 4. Notice of Transactions – the client shall receive notice of all transactions in their account as if they had maintained a similar account outside of the investment strategy; 5. Quarterly Statement – the client shall be provided with a quarterly statement containing a description of all activity in the their account; 6. Ability to Impose Restrictions – the client shall have the ability to impose reasonable restrictions on the management of their account, including the ability to instruct Alera Retirement Advisors not to purchase certain securities or types of securities; 7. No Pooling – the client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the client’s account; 8. Separate Account – a separate account is maintained for the client with the custodian; and 9. Ownership - each client retains indicia of ownership of the account (e.g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). In addition to the foregoing, clients may, in writing, place reasonable limitations upon Alera Retirement Advisors’ discretionary authority. The investment strategy may involve an above-average portfolio turnover that could negatively impact upon the net after-tax gain experienced by an individual client. Securities in the investment strategy are usually exchanged and/or transferred without regard to a client’s individual tax ramifications. Certain investment opportunities that become available to Alera Retirement Advisors’ clients may be limited. For example, various mutual funds may limit the ability of Alera Retirement Advisors to buy, sell, exchange or transfer securities consistent with its investment strategy. As further discussed in response to Item 12B (below), in order to meet its fiduciary duties to all of its clients, Alera Retirement Advisors will endeavor to allocate investment opportunities among its clients on a fair and equitable basis. Participation in Alera Retirement Advisors’ investment strategy carries additional risk to clients in that a mutual fund or insurance company may unilaterally restrict and/or prohibit Alera Retirement Advisors’ trading activities thus prohibiting it from managing the assets consistent with the investment strategy. Additions and Withdrawals to Accounts Clients may make additions to and withdrawals from their account at any time, subject to Alera Retirement Advisors’ right to terminate an account. Clients may withdraw account assets on notice to Alera Retirement Advisors, subject to the usual and customary securities settlement procedures. However, Alera Retirement Advisors designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Alera Retirement Advisors has $38,959,318 under discretionary asset under management and $0 under non-discretionary asset under management as of December 2022. Retirement Plan Advisory Services ARA provides advisory services to retirement plans (each a “Plan”) pursuant to The Employee Retirement Income Security Act of 1974 (“ERISA”). Services include both fiduciary and non-fiduciary services to the sponsor of the Plan (the “Plan Sponsor”) and the participants of the Plan (the “Plan Participants”). Services will be provided on either a non-discretionary basis (ERISA 3(21) Fiduciary Services) or on a discretionary basis (ERISA 3(38) Services). Advisory services are negotiated based on the needs of the Plan and the direction and engagement by the Plan Sponsor and are included in the terms of a retirement plan advisory agreement. ARA typically provides the following Plan Fiduciary Services pursuant to the scope and terms of ARA’s agreement with each Plan Sponsor:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Searches
• Investment Review, Analysis, and Monitoring
• Performance Reporting
• ERISA 404(c) Assistance
• Qualified Default Investment Alternative Designation
• Non-Discretionary Advisory Services (ERISA 3(21) Fiduciary Services)
• Discretionary Advisory Services (ERISA 3(38) Fiduciary Services) ARA may also provide communication and education services to the Plan and the Plan Participants, pursuant to the terms of the retirement plan advisory agreement. Services may include:
• Assist with Plan Participant enrollment
• Plan Participant Investment Education
• Periodic on-site visits with Plan Sponsor for account updates and reviews
• Periodic Plan Participant Education Advice (may require separate engagement by the Plan Participant)