Overview SpiderRock Advisors, LLC (hereafter, “SRA” or the “Firm”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and registered as a commodity trading advisor with the United States Commodity Futures Trading Commission (“CFTC”). SRA was incorporated in January 2013. Effective May 1, 2024, BlackRock, Inc. (“BlackRock”) completed its acquisition of all of the remaining outstanding equity securities of SRA. As a result of the acquisition, SRA is an indirect wholly-owned subsidiary of BlackRock and a related person of BlackRock’s subsidiaries, including investment advisory and trust company subsidiaries (“BlackRock Investment Advisers”). SRA offers advisory services to a variety of clients, across different formats. The Firm primarily provides investment advisory and strategy management services to asset managers, registered investment advisors, banks, broker-dealers, family offices, pensions and endowments, and other fiduciaries (collectively “Advisors”) for use with their clients and constituents in several different capacities as further described below. The Firm also offers advisory services directly to high-net-worth individuals, family offices, pension funds, endowments and other institutional investors through separately managed accounts (“SMAs”). Discretionary Investment and Trading Solutions SRA seeks to manage proprietary overlay investment strategies for client portfolios (collectively, “Advisory Services”). These strategies, collectively, and in conjunction with the strategies pursued in a client’s portfolio, can potentially be an efficient means to achieving greater risk adjusted portfolio returns and enhanced yields. The strategies may also seek to hedge certain specific risks inherent in a client’s underlying portfolios. SRA’s overlay strategies are designed to mitigate risk and augment yield in a client portfolio. The Firm provides investment advice and implements strategies that utilize listed derivatives, namely listed equity and index options.

SRA can also offer advice on a wide range of securities, including, but not limited to, fixed income and exchange listed and over-the-counter securities. All SRA services are offered on a discretionary basis. Separately Managed Accounts SRA provides discretionary Advisory Services directly to high-net-worth individuals, family offices, pension funds, endowments, private funds, and other institutional investors, including on a sub-advisory basis. SMA clients generally select an investment strategy after consultation with SRA. SMA clients are permitted to impose reasonable restrictions if such restrictions are not materially different from a strategy’s investment objectives. SMA clients who impose investment restrictions should be aware that the performance of their accounts may differ from that of the investment strategies not subject to investment restrictions. Other Services SRA may also provide other services to clients, including but not necessarily limited to, (i) collateral management with respect to clients’ collateral assets and (ii) assistance to Advisors with respect to Advisors’ trading of over-the-counter derivatives on behalf of clients. Wrap Fees SRA does not currently sponsor any wrap fee program or charge wrap fees to clients. However, SRA may provide sub-advisory services to an Advisor that offers wrap fee programs to its clients. In addition, SRA may enter into direct advisory relationships with clients that participate in a wrap fee program with their Advisor. In each case, SRA’s advisory fees are not included in the wrap fee charged by the applicable Advisor and are separately borne by the client. Clients should consult with their Advisor to determine if their account is part of a wrap fee program and for more information regarding the costs and risks associated with wrap fee programs. AUM: As of February 29, 2024, SRA’s discretionary assets under management totaled approximately $4,853,616,658. As of that date, SRA did not manage any assets on a non-discretionary basis.