Janney Capital was formed on September 23, 2011 and commenced investment operations on September 1, 2012. Janney Capital is based in Pittsburgh, Pennsylvania and organized as a limited liability company under the laws of Delaware. The firm was originally known as Parker/Hunter Asset Management, LLC and, effective January 1, 2013, changed its name to Janney Capital Management LLC. Janney Capital is a wholly owned subsidiary of Janney Montgomery Scott LLC (“Janney”), a financial services firm registered with the U.S. Securities and Exchange Commission (“SEC”) as a broker-dealer, municipal advisor and an investment adviser. Janney is an indirect wholly owned subsidiary of The Penn Mutual Life Insurance Company. As of December 31, 2023, Janney Capital manages approximately $3,498,089,144 of client assets on a discretionary basis and $1,768,592,714 on a non-discretionary basis. Prior to September 1, 2012, Janney Capital (then known as Parker/Hunter Asset Management) operated as an asset management division of Janney. The original entity, known as Parker/Hunter Asset Management, was formed in 1994 as the asset management arm of Parker/Hunter Incorporated, a registered broker-dealer and investment adviser. Parker/Hunter Incorporated was acquired by, and incorporated into, Janney in 2005 and operated as an asset management group of Janney from 2005 to August 2012. Janney Capital provides discretionary investment management services primarily as a sub-advisor in certain fee- based managed account “wrap” programs (collectively, the “Programs”, and each a “Program”) offered by Janney. The firm also maintains model portfolios on a non-discretionary basis for the unified managed account program (i.e., Adviser’s MSP) offered by Janney. In addition, Janney Capital provides model portfolios on a non-discretionary basis to certain program sponsors (or their overlay managers) for unified management accounts (“UMAs”). Each program sponsor (or overlay manager) retains investment discretion over the UMA. With respect to the Programs, Janney Capital serves as the sub-advisor to Janney client accounts in the Keystone Discretionary, ETF Advantage, and Janney Capital Direct Programs offered through Janney. Janney Capital also provides general oversight and maintenance of model portfolios on a non-discretionary basis offered through Janney’s Pioneer Program. In providing services with respect to these Programs, Janney Capital personnel work closely with Janney’s Private Client Group, Wealth Management Department, and its Financial Advisors, in providing investment advisory services to clients. As described below, Janney Capital shares personnel, certain investment, and other resources with Janney. There can be no assurance that any particular strategy will be successful in achieving a client’s investment goals and objectives. Any investment in the securities markets involves risk, including the realization of investment loss. In some circumstances, it may be appropriate to restrict a position(s) based on a client request. Investment Strategies Equity Strategies Janney Capital’s equity strategy offerings include an (i) All Cap Core Equity Strategy, (ii) Global Sustainability Strategy, (iii) Equity Income Strategy, (iv) US Quality Dividend Strategy, (v) Global Small Cap Strategy, (vi) Active Index Strategy, (vii) Active Index Strategy – U.S. Only, (viii) Active Index Strategy – International, and (ix) JCM Direct Keystone Equity Growth Strategy. All Cap Core Strategy The primary investment objective of the firm’s All Cap Core Equity Strategy is capital appreciation. The strategy typically consists of a diversified portfolio of equity securities that reflect the firm’s Investment Committee’s JANNEY CAPITAL MANAGEMENT PAGE - 6 (“Investment Committee”) most compelling investment opportunities for the strategy regardless of market capitalization, style orientation or geographic location. Portfolio construction is based on the Investment Committee’s macro-economic views, combined with fundamental sector and security analysis. Investment decisions are made based upon recommendations from the Investment Committee which uses a combination of internal and external research, proprietary quantitative and qualitative screening and fundamental analysis. A deliberate focus on risk management is applied at each step of the process; macro, portfolio construction and individual security level. The portfolio may also hold cash and or American depositary receipts (“ADRs”) as an investment. Global Sustainability Strategy The Global Sustainability Strategy is an Environmental, Social and Governance (“ESG”) focused strategy with capital appreciation as its primary investment objective. ESG investing considers environmental, social and governance factors in the analysis, selection and management of investments. The strategy’s security selection process is driven primarily through fundamental research with the addition of utilizing a third-party quantitative model to assess ESG characteristics at the individual company level. This research ranks a company’s ESG risk against industry peers and against a global universe of stocks resulting in absolute ratings that enables comparability within industries. The ESG factors are actively assessed and may result in portfolio holdings changes. Examples of environmental factor rankings include business activities related to renewable and sustainability of natural resources, climate change, pollution, and water usage. Social factor rankings examples focus on human rights, health and safety, labor standards, supply chain, and social opportunities. Governance factors include items related to corporate behavior, risk management, data and cyber security. A deliberate focus on risk management is applied at each step of the process including at the macro, portfolio construction and individual security level. The portfolio may also hold cash and or American depositary receipts as an investment. The strategy excludes those companies that derive a significant portion of their revenues through Tobacco, Alcohol, or Firearms businesses. Equity Income Strategy The Equity Income Strategy seeks a substantially higher dividend yield than the broad market, with the potential for dividend growth and long-term capital appreciation. The strategy typically consists of a diversified portfolio of equity securities that reflect the Investment Committee’s most compelling investment opportunities for the strategy regardless of market capitalization, style orientation or geographic location. Portfolio construction is based on the Investment Committee’s macro-economic views combined with fundamental sector and security analysis. We apply a deliberate focus on risk management at every step of the process; macro, portfolio construction and individual security level. The portfolio may also hold cash and or ADRs as an investment. A socially responsible version of the Equity Income Strategy is available upon individual client request titled the Equity Income Socially Responsibility Strategy. The socially responsible version of the Equity Income Strategy considers moral, ethical or religious beliefs in the analysis, selection and management of investments. Socially Responsible Investing (“SRI”) factors are integrated in the security selection process utilizing fundamental analysis to apply exclusions to specific industries and companies. The strategy avoids companies in the Alcohol, Tobacco, Gambling, Weapons, Contraception and Animal Testing related industries. US Quality Dividend Strategy The US Quality Dividend Strategy will be invested in equities predominately domiciled in the United States that regularly pay dividends, show potential for long-term capital growth, and are believed to be undervalued. The strategy consists of a portfolio of equity securities (US) that reflect the Investment Committee’s most compelling investment opportunities. The portfolio will primarily be invested with an emphasis on large-capitalization stocks, although we may invest in US equities across all market capitalizations. Portfolio construction is based on the Investment Committee’s macro-economic views combined with fundamental sector and security analysis. Risk JANNEY CAPITAL MANAGEMENT PAGE - 7 management is applied at every step of the process including at the macro, portfolio construction and individual security level. Global Small Cap Strategy The Global Small Cap Strategy seeks to provide long-term growth by investing principally in the common stocks of companies with smaller market capitalizations. The strategy will generally be invested at least 80% in companies with market capitalizations less than $5 billion. The strategy may be appropriate for investors with a long-term time horizon and who are willing to accept the potentially higher risks associated with smaller capitalization companies (see further discussion of such risks under “Method of Analysis, Investment Strategies and Risk of Loss – Market Liquidity Risk” below). In order to ensure appropriate diversification and to expand the universe of investing choices, the Investment Committee intends to invest globally, in non-U.S. as well as U.S. small cap companies, including the use of ADRs. The strategy may include shares of exchange traded funds (“ETFs”) for the purpose of establishing a diversified position in a particular sector of the market or maintaining market exposure while awaiting an opportunity to purchase other securities, as well as such other purposes. Janney Capital Management believes that purchasing ETFs in such a manner will allow the strategy to invest in a particular sector of the market more efficiently than would otherwise be possible. Active Index Strategy The Active Index Strategy seeks to provide long-term capital appreciation. To achieve its investment objective, the strategy consists of a diversified portfolio of exchange traded products (“ETPs”) including ETFs, exchange traded notes (“ETNs”) and closed end funds (“CEFs”) that reflect the Investment Committee’s most compelling investment opportunities for the strategy. The portfolio may also hold cash as an investment. Portfolio construction is based on the Investment Committee’s macro-economic views combined with fundamental sector and security analysis. The portfolio may invest across all market cap sizes, investment styles, economic sectors and countries as deemed appropriate by the Investment Committee. Active Index Strategy – U.S. Only The Active Index Strategy - U.S. Only seeks to provide long-term capital appreciation. To achieve its investment objective, the strategy consists of a diversified portfolio of ETPs including ETFs, ETNs and CEFs that reflect the Investment Committee’s most compelling investment opportunities for the strategy. The portfolio may also hold cash as an investment. Portfolio construction is based on the Investment Committee’s macro-economic views combined with fundamental sector and security analysis. The portfolio may invest across all market cap sizes, investment styles, and economic sectors in securities that are predominantly U.S. focused and deemed appropriate by the Investment Committee. Active Index Strategy – International The Active Index Strategy – International seeks to provide long-term capital appreciation. To achieve its investment objective, the strategy consists of a diversified portfolio of ETPs and CEFs that reflect the Investment Committee’s most compelling investment opportunities for the strategy. The portfolio may also hold cash as an investment. Portfolio construction is based on the Investment Committee’s macro-economic views combined with fundamental sector and security analysis. The portfolio may invest across all international markets and include various market cap sizes, investment styles, economic sectors and countries excluding the U.S., as deemed appropriate by the Investment Committee. JCM Direct Keystone Equity Growth Strategy The JCM Direct Keystone Equity Growth Strategy seeks to provide long-term capital appreciation. To achieve its investment objective, the strategy consists of a diversified portfolio of no-load mutual funds and ETPs. The JANNEY CAPITAL MANAGEMENT PAGE - 8 portfolio may also hold cash as an investment. Portfolio construction is based on the Investment Committee’s macro-economic views combined with fundamental sector and security analysis. The portfolio may invest across all market cap sizes, investment styles, economic sectors and countries as deemed appropriate by the Investment Committee. The asset classes generally included in the strategy represent sector indexes, domestic indexes, international indexes, real estate, commodities, currencies and alternative investments. Fixed Income Strategies Janney Capital’s fixed income strategy offerings include the (i) Core Active Bond Strategy, (ii) Core Active Municipal Strategy, (iii) Active Index Fixed Income Strategy, (iv) JCM Direct Keystone Income Strategy, (v) PurePreferred Strategy, (vi) Short Duration Income Strategy, (vii) Taxable Laddered Fixed Income Strategy, (viii) Taxable Laddered Fixed Income Plus Strategy, (ix) Municipal Laddered Fixed Income Strategy, and (x) Municipal Laddered Fixed Income with High Yield Strategy. Core Active Bond Strategy The Core Active Bond Strategy, previously titled the Intermediate Government Credit Fixed Income Strategy, seeks to provide income by investing in investment grade taxable bonds, including Treasuries, agencies, corporate bonds, and taxable municipal bonds. At the time of purchase, all bonds will have an investment grade rating as determined by at least one nationally recognized statistical rating organization. The strategy does not include asset- backed or mortgage-backed securities. The firm seeks to construct a well-diversified portfolio of fixed income securities by sector, maturity and issuer. Individual security selection is a reflection of a client’s risk tolerance and investment objective. The firm uses economic analysis to establish an interest rate outlook, identify sector and yield curve opportunities and establish duration targets. Credit quality and liquidity are given special consideration. Core Active Municipal Strategy The Core Active Municipal Strategy, previously titled the Tax-Exempt Municipal Bond Strategy, seeks to provide tax exempt interest income by investing in investment grade tax exempt municipal bonds. At the time of purchase, all bonds will have an investment grade rating as determined by a nationally recognized statistical rating organization. The firm seeks to construct a well-diversified portfolio of tax-exempt municipal bonds by maturity and issuer. The firm uses economic analysis to establish an interest rate outlook, yield curve opportunities and maturity targets. Credit quality and liquidity are given special consideration. Portfolios may be tailored for state specific strategies or may be broadly based as a national strategy. Active Index Fixed Income Strategies The Active Index Fixed Income Strategies seek to provide current income. To achieve its investment objective, the strategy consists of a diversified portfolio of ETPs, including ETFs, ETNs and CEFs. The strategy incorporates economic analysis, which is utilized to establish an interest rate outlook, identify sector and yield curve opportunities and establish maturity, duration and credit quality ranges. JCM Direct Keystone Income Strategy The JCM Direct Keystone Income Strategy seeks to provide current income. To achieve its investment objective, the strategy’s portfolio consists of no-load mutual funds and ETPs. The portfolio may also hold cash as an investment. The strategy incorporates economic analysis to establish an interest rate outlook, identify sector and yield curve opportunities and establish maturity, duration and credit quality ranges. The asset classes generally included in the strategy represent segments of the bond market such as high yield bonds, corporate bonds, municipal bonds, and short-term instruments. JANNEY CAPITAL MANAGEMENT PAGE - 9 PurePreferred Strategy The PurePreferred Strategy seeks

to provide current income primarily by investing in issues of preferred securities. Individual security selection focuses on credit quality, fundamental analysis, and an issuer’s corporate structure. Securities initially will be screened and then continuously monitored for potential changes in credit quality, as determined by a nationally recognized statistical rating organization. The strategy may include shares of ETFs for the purpose of establishing or maintaining market exposure while awaiting an opportunity to purchase other securities, as well as other purposes such as short-term investment and liquidity requirements. Short Duration Income Strategy The Short Duration Income strategy seeks to provide current income with limited interest rate risk and limited portfolio volatility through the use of short-term fixed income investments. The strategy is not a money market fund or other stable value investment and should not be used as a substitute for liquid cash. The strategy portfolio is built with limited duration using a blend of government securities for liquidity and other investments for income generation. The portfolio construction targets at least 10% of the portfolio in highly liquid instruments such as Treasury bills, Treasury notes, and government agency securities. The remainder of the portfolio includes less- liquid securities with short-term maturities and/or floating interest rates to maintain a short duration. The strategy may invest in any combination of Treasury bills and Treasury notes, government agency securities, agency mortgage-backed securities, asset backed securities, investment grade corporate bonds, and high yield corporate bonds with a minimum of a “B” (or equivalent) credit rating from at least one nationally recognized statistical rating organization. Fundamental analysis is conducted to select issuers with stable credit and sufficient liquidity to meet their short-term obligations, with a particular emphasis on internally generated liquidity for high yield-rated issuers. Laddered Fixed Income Strategies Janney Capital’s laddered income strategy offerings include the (i) Taxable Laddered Fixed Income Strategy, (ii) Taxable Laddered Fixed Income Plus Strategy, (iii) Municipal Laddered Fixed Income Strategy, and (iv) Municipal Laddered Fixed Income With High Yield Strategy. Taxable Laddered Fixed Income Strategy The Taxable Laddered Fixed Income Strategy seeks to provide current income by investing in investment grade taxable corporate bonds. The laddered portfolio equally weights bonds by maturities and is diversified across sectors and issuers. Individual security selection emphasizes credit quality and liquidity. At the time of purchase all bonds will have an investment grade rating as determined by a nationally recognized statistical rating organization. Holdings are continually monitored for potential changes in credit quality. Clients have the flexibility to select from two separate levels of portfolio credit quality, high investment grade or medium investment grade (A Average or BBB+ Average) as well as two separate time ranges for bond maturities (1 – 10 years or 5 – 15 years). The strategy typically uses fixed income ETFs in two ways: one, to quickly establish market exposure for clients adding new cash to the strategy, as we await purchase of individual fixed income securities; and two, to maintain an extra liquidity buffer in accounts in order to efficiently raise cash to support client withdraw requests. Not all accounts will include ETFs, and the strategy may pause purchases of ETFs, depending on markets conditions. Taxable Laddered Fixed Income Plus Strategy The Taxable Laddered Fixed Income Plus Strategy seeks to provide current income by investing in investment grade taxable corporate bonds and preferred securities. The laddered bond portion of the portfolio equally weights bonds by maturities and is diversified across sectors and issuers. Individual security selection emphasizes credit quality and liquidity. At the time of purchase all bonds will have an investment grade rating as determined by a nationally recognized statistical rating organization. Holdings are continually monitored for potential changes in credit quality. JANNEY CAPITAL MANAGEMENT PAGE - 10 Clients have the flexibility to select from two separate levels of portfolio credit quality, high investment grade or medium investment grade (A Average or BBB+ Average) as well as two separate time ranges for bond maturities (1 – 10 years or 5 – 15 years). The preferred securities portion of the portfolio emphasizes current income generation. Preferred security holdings are also continually monitored for potential changes in credit quality. The strategy typically uses fixed income ETFs in two ways: one, to quickly establish market exposure for clients adding new cash to the strategy, as we await purchase of individual fixed income securities; and two, to maintain an extra liquidity buffer in accounts in order to efficiently raise cash to support client withdraw requests. Not all accounts will include ETFs, and the strategy may pause purchases of ETFs, depending on markets conditions. Municipal Laddered Fixed Income Strategy The Municipal Laddered Fixed Income Strategy seeks to provide tax-efficient current income by investing in investment grade municipal bonds that typically will be held to maturity. Clients have the flexibility to select from two separate time ranges for bond maturities (2-10 years or 5-15 years). The laddered portfolio approximately weights the bonds by maturities and can be diversified across issuer type (e.g. state, city, transit authority, water and sewer authority etc.), credit ratings, revenue and general obligation (GO) bonds. Portfolios may be constructed for state preference strategies or may be broadly based as a national strategy. State preference strategies will have a greater allocation of bond issues from the designated state, but also may be comprised of bond issues from multiple states with similar risk characteristics. At the time of purchase, all bonds will have an investment grade rating as determined by a nationally recognized statistical rating organization. Holdings are continually monitored for potential changes in credit quality. The strategy typically uses fixed income ETFs in two ways: one, to quickly establish market exposure for clients adding new cash to the strategy, as we await purchase of individual fixed income securities; and two, to maintain an extra liquidity buffer in accounts in order to efficiently raise cash to support client withdraw requests. Not all accounts will include ETFs, and the strategy may pause purchases of ETFs, depending on markets conditions. Municipal Laddered Fixed Income with High Yield Strategy The Municipal Laddered Fixed Income with High Yield Strategy seeks to provide tax-efficient current income through a combination of investments in both investment grade and below investment grade municipal bonds that typically will be held to maturity. Investment ratings will be determined by a nationally recognized statistical rating organization and continually monitored for potential changes in credit quality. The Portfolios may also be comprised of non-rated securities. Clients have the flexibility to select from two separate time ranges for bond maturities (2-10 years or 5-15 years). The laddered portfolio approximately weights the bonds by maturities and can be diversified across issuer type (e.g. state, city, transit authority, water and sewer authority etc.), credit ratings, revenue and general obligation (GO) bonds. Portfolios may be constructed for state preference strategies or may be broadly based as a national strategy. State preference strategies will have a greater allocation of bond issues from the designated state, but also may be comprise of bond issues from multiple states with similar risk characteristics. The strategy typically uses fixed income ETFs in two ways: one, to quickly establish market exposure for clients adding new cash to the strategy, as we await purchase of individual fixed income securities; and two, to maintain an extra liquidity buffer in accounts in order to efficiently raise cash to support client withdraw requests. Not all accounts will include ETFs, and the strategy may pause purchases of ETFs, depending on markets conditions. Asset Allocation Strategies The firm offers two asset allocation strategies: (i) Dynamic Asset Strategy; and (ii) Dynamic Income Strategy which seek long term capital appreciation and high current income, respectively, utilizing a predetermined asset class mix. Accounts invested in the asset allocation strategies may be invested actively across asset classes but may also be concentrated in specific asset classes that the firm believes offers the best opportunity for achieving the JANNEY CAPITAL MANAGEMENT PAGE - 11 strategy’s investment objectives. Such flexibility in portfolio construction has the risk of exposing client accounts to decreases in value due to concentration in certain securities or asset classes. Dynamic Asset Strategy The Dynamic Asset Strategy seeks long term capital appreciation. To achieve its investment objective, a dynamic portfolio is created that has no predetermined asset allocation mix and instead seeks to allocate capital to investments that appear to offer the most compelling opportunities to meet the investment objective. The strategy uses ETPs, including ETFs and ETNs, and CEFs to invest tactically across asset classes and market categories. Investment decisions are made with a focus on valuations, expected returns and correlations when developing an asset allocation. Dynamic Income Strategy The Dynamic Income Strategy seeks to deliver a high level of current income. To achieve its investment objective, the firm generally constructs portfolios with a 50% weighting in fixed income ETF securities. The strategy uses ETPs, including ETFs and ETNs, and CEFs to invest tactically across asset classes and investment categories such as index sectors, domestic indexes, international indexes, real estate, commodities, currencies, alternative investments and fixed income. The fixed income ETF security holdings generally represent segments of the bond market such as high yield bonds, corporate bonds, municipal bonds, and short-term instruments. Investment decisions are made with focus on valuations, expected returns and correlations when developing an asset allocation. Managed Account Wrap Programs Offered by Janney Janney Capital provides investment management services on a discretionary basis to Janney client accounts under the following Programs: (i) Keystone; (ii) ETF Advantage; and (iii) Janney Capital Management Direct. Janney Capital also maintains model portfolios, on a non-discretionary basis, to Janney client accounts under the following Programs: (i) Adviser’s MSP; and (ii) Pioneer. Keystone Discretionary Under the Keystone Discretionary Program, client accounts are invested on a fully discretionary basis in a portfolio of no-load and load-waived mutual funds, ETFs and ETNs based on a predetermined asset-mix strategy selected by the client and with the advice of the client’s Janney Financial Advisor. We may use our discretion to periodically rebalance client accounts and to make changes in the investments in the account where appropriate. The strategies offered include equity growth, diversified growth, balanced, income and diversified income. The asset classes included in equity and other asset class strategies represent index sectors, domestic indexes, international indexes, real estate commodities, currencies and alternative investments. The asset classes generally included in income strategies represent segments of the bond market such as high yield bonds, corporate bonds, municipal bonds, and short-term instruments. ETF Advantage Under the ETF Advantage Program, client accounts are invested on a fully discretionary basis in a portfolio of ETPs, including but not limited to ETFs and ETNs based on a predetermined asset-mix strategy selected by the client with the advice of the client’s Janney Financial Advisor. We may use our discretion to periodically rebalance client accounts and to make changes in the ETFs, ETNs and other ETPs in the account where appropriate. The strategies offered include equity growth, diversified growth, balanced, income and diversified income. The asset classes included in equity and other asset class strategies represent index sectors, domestic indexes, international indexes, real estate, commodities, currencies and alternative investments. The asset classes generally included in income strategies represent segments of the bond market such as high yield bonds, corporate bonds, municipal bonds, and short-term instruments. JANNEY CAPITAL MANAGEMENT PAGE - 12 Janney Capital Management Direct Under the Janney Capital Management Direct Program, client accounts may employ equity-only, balanced, fixed income-only and asset allocation strategies. Typically, individual securities, ETFs, ETNs and mutual funds are used to execute the strategies. When appropriate to the needs of the Client, Janney Capital may recommend the use of short-term trading (securities sold within 30 days), short sales, margin transactions (under limited conditions) or options writing. Because these investment strategies involve certain degrees of risk, they will only be recommended when consistent with the Client’s stated tolerance for risk. Advisers MSP Program Offered by Janney Janney Capital maintains model portfolios, on a non-discretionary basis, based on certain established guidelines, for the Adviser’s MSP Program offered by Janney. For more information about Janney’s Advisers MSP Program, please visit www.Janney.com to view Janney’s Form ADV Part 2A Investment Management Disclosure Brochure and the Janney Wrap Fee Program Brochure. Pioneer Program Offered by Janney Janney Capital assumes responsibility of and provides general oversight and maintenance, on a non-discretionary basis, of select equity model portfolios provided by Janney’s Wealth Management Research Department and based on analysis by a third-party research provider. The Pioneer equity model portfolios include the Dividend Aristocrats Model, the Total Return Model, the Intrinsic Value Model, and the High-Quality Capital Appreciation Model. For more information about Janney’s Pioneer Program, please visit www.Janney.com to view Janney’s Form ADV Part 2A Investment Management Disclosure Brochure and the Janney Wrap Fee Program Brochure. Third-Party Model Delivery Janney Capital makes available model portfolios, separate from the Adviser’s MSP Program and Pioneer Program, that it distributes through third-party platforms on a non-discretionary basis. The third-party platforms provide investment advisory services to financial institutions, broker-dealers, registered investment advisors and/or entities exempt from such registration (each a “Sponsor”). Each Sponsor would manage the accounts or portfolios of their respective investors. Janney Capital currently has third-party model delivery agreements with Vestmark Advisory Solutions through the Vestmark Manager Marketplace Program and Adhesion Wealth Advisory Solutions. UMA Model Portfolios Janney Capital provides model portfolios to certain program Sponsors (or their overlay managers) for unified management accounts (“UMAs”). Each program Sponsor (or overlay manager) retains investment discretion over the UMA. The program sponsor (or overlay manager) also is responsible for effecting trades resulting from these model-only recommendations. Janney Capital has no investment discretion over the program sponsor’s UMAs, has no responsibility for trading, and has no specific knowledge of the program sponsor’s knowledge or their circumstances.