Firm Description and History Smartleaf Asset Management, LLC (“Smartleaf Asset Management” or “SAM”) is a fee-based, registered investment adviser with its principal place of business located in Boston, Massachusetts. The firm was established in June 2014 as a Delaware limited liability company whose sole owner is Smartleaf, Inc. (“Smartleaf”) and the sole managing member is Gerard Michael. SAM has 12 employees including four investment advisory professionals. The Chief Compliance Officer is Diana Neuss. The team has over 40 years combined experience in the financial services industry. The firm currently has several service providers for administrative and technical support. For more information about SAM’s investment advisor representatives please consult the ADV Brochure Supplement. Business Summary SAM provides two types of advisory services: (1) sub-advisory portfolio management services that leverage the scale, customization and tax management capabilities of the portfolio management system developed by Smartleaf, (2) Direct Index (“Core”) Models as described below. SAM derives its revenues from investment advisory fees only. Fees are calculated as a percentage of the assets under management (“AUM”) in the sub-advisory accounts or, in the case of Direct Index Model clients, by the assets under management in accounts managed pursuant to the model. The fees for the sub-advisory accounts are typically directly debited from the sub-advisory clients’ custodial accounts as authorized by the client. The firm does not receive any commissions or other compensation in connection with its services. No cash payments or other benefits (e.g., “soft dollars”) are received from custodians or broker-dealers based on client securities transactions. SAM’s parent, Smartleaf, and its technology affiliates may receive subscription fees from SAM or from clients that use their technology, data and/or non- investment advisory data processing services. For more information regarding our investment philosophies and the risks of our strategies and/or specific investments recommended, please refer to the next section – Types of Advisory Services. SAM actively seeks to avoid, or at least minimize, conflicts of interest which may exist between the firm and its clients. Conflicts of interest will be disclosed to clients and managed, to the extent feasible in the context of SAM’s business model and operational capabilities, in the best interest of the client. In those instances when unavoidable conflicts of interest arise, we have adopted policies that seek to incorporate and address the client’s best interests. Sub-Advisory Portfolio Management Smartleaf Asset Management’s primary purpose is to support providing investors with high levels of personalization and tax optimization. Smartleaf Asset Management offers sub-advisory portfolio management services to third-party advisors (“Advisors”) who manage discretionary accounts. SAM enters into a sub-advisory agreement with the Advisor whereby the Advisor appoints SAM to manage all or a portion of its client’s accounts utilizing portfolio management software created by its affiliate Smartleaf. SAM has no direct relationship with the Advisor’s clients, and the Advisor is solely responsible for determining the suitability of the parameters given to SAM for management of each account. SAM offers Advisors using the Sub-Advisory Service extensive asset allocation, product choice, customization and tax management options, detailed below. Smartleaf Asset Management, LLC. | smartleafam.com 032924_v1.0 5 Trading decisions for each account are highly customized, depending on each account’s assigned asset allocations and models, customization settings, tax management considerations, and legacy holdings. As a result, it is possible that the same security may be purchased for some accounts and sold for other accounts on the same day. Separately Managed Accounts or Holistically Managed Accounts SAM manages, on a sub-advisory basis, holistically managed accounts meaning accounts that are managed as a whole, without use of subaccounts, targeted to follow composite models comprised of combinations of mutual funds, exchange traded funds (“ETFs”), cash, the Advisor’s equity models and third-party (“open architecture”) equity models. SAM can also manage, on a sub-advisory basis, separately managed accounts (“SMAs”), meaning accounts, or subaccounts, targeted to follow a single equity model provided by the Advisor or sourced from a third-party. Access to Third-Party and Direct Index Models For both UMAs and SMAs, SAM

provides Advisors with access to third-party models through the model hub of its parent, Smartleaf. These third-party model providers may charge an additional fee for the use of their models. SAM passes this cost through to the Advisor. The model hub that SAM makes available to Advisors includes direct index models – models designed to track an index, usually at lower cost than comparable actively managed models. The model hub includes direct index models from third parties, as well as SAM’s own “Core Models” which are direct index models, as described below. Custom Asset Allocation SAM manages accounts in accordance with asset allocations set by the Advisor. Advisors provide SAM with a set of standard asset allocations, e.g., “Conservative” or “Aggressive Growth,” which the Advisor may update as the Advisor sees fit. SAM itself does not create or recommend asset allocations, though it may make asset allocation models available from third-party providers through the Smartleaf model hub. The Advisor assigns each account an asset allocation from this predefined list. The Advisor may then customize the asset allocation of any account, as supported by the Smartleaf Portfolio Management software. For each asset class in their asset allocations, Advisors specify their desired investments– any combination of mutual funds, ETFs, and direct investment in individual securities based either on the Advisor’s proprietary equity models and/or equity models from third parties. Advisors may customize the type of investments in each asset class for each account. SAM does not recommend specific investments or products, though it may make its Core Models available to the Advisor, along with equity models available from third-party providers through the Smartleaf model hub. Environmental, Social and Governance (ESG) Customization SAM provides Advisors with extensive Environmental, Social and Governance (ESG) constraint options, e.g., Catholic Values,” “Sharia” or “Environmental,” for each account. Glide path Advisors may set up multi-year “glide paths” for each account, wherein the desired risk characteristics of the account change over time, e.g., moving from “Aggressive Growth” to “Conservative” over a 20-year period. Smartleaf Asset Management, LLC. | smartleafam.com 032924_v1.0 6 Tax management The advisor may set numerous tax management parameters for each account, including:
• Tax rates
• Tax budget
• Loss harvesting preferences
• Gains deferral preferences Other customization options SAM offers the Advisor additional customization options for each account, including security constraints and custom cash management parameters. Core Models SAM’s Core Models are direct index models, which means they are designed to track the performance of a selected equity index with a smaller number of securities than the index. SAM currently offers twelve Core Models: NAME BENCHMARK APPX # OF HOLDINGS SCM - S70 Large Cap Index S&P 500 70 SCM - S125 Mid Cap Core Index S&P 400 125 SCM - S150 Large Cap Index S&P 500 150 SCM - S150 Large Cap Growth Index S&P 500 Growth 150 SCM - S150 Large Cap Value Index S&P 500 Value 150 SCM - S150 Mid Cap Growth Index S&P 400 Growth 150 SCM - S150 Mid Cap Value Index S&P 400 Value 150 SCM - S200 SMID Cap Core Index S&P 1000 200 SCM - S200-All Cap Core Index S&P 1500 200 SCM - S300-Russell 1000 Core Index Russell 1000 0 SCM - S400-Russell 2000 Core Index Russell 2000 0 SCM - S400-Russell 3000 Core Index Russell 3000 0 SAM may also create customized models for use by individual clients. SAM’s Core Models are distributed to clients (“Model-Only Clients”) through Smartleaf’s model hub, which also includes index- based and active models from third parties which are made available to users of Smartleaf’s portfolio management overlay software. whose sole relationship with SAM is the purchase of the Core Models. Fees for Core Models are based on the AUM of the Model-Only Client’s accounts that are managed pursuant to the Core Models. Wrap Fee Programs Smartleaf Asset Management, LLC does not manage assets under wrap fee programs or manage assets for any wrap fee accounts. Smartleaf Asset Management, LLC. | smartleafam.com 032924_v1.0 7 Types of Investments SAM’s investment programs are limited to US publicly traded mutual funds, ETFs, ADRs and equities. Client Assets Under Management As of December 31, 2023, SAM has $2,691,262,439.00 of discretionary assets under management.