PGIM Custom Harvest is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”) and has been in business since 2017. PGIM Custom Harvest is an indirect, wholly-owned subsidiary of Prudential Financial, Inc. (Prudential), a publicly held company (NYSE Ticker “PRU”). When we use the terms “we,” “us” and “our” in this Brochure, we are referring to PGIM Custom Harvest and the functional groups that support PGIM Custom Harvest (i.e., compliance, law and finance). In addition, any references to “our employees” or “our officers” mean PGIM Custom Harvest’s officers or employees and employees who work in the functional groups. As of December 31, 2023, PGIM Custom Harvest managed $3,582,625,285 of regulatory assets under management on a discretionary basis. PGIM Custom Harvest specializes in creating and managing portfolios invested across asset classes, indices and custom models while seeking to maximize after-tax returns using capital loss harvesting strategies. PGIM Custom Harvest provides tax-loss harvesting (“TLH”) investment advisory services to various types of clients, including high net worth and other individuals, trusts, corporations/other businesses, registered investment advisers and other financial intermediaries such as broker-dealers. Discretionary Advisory Services (Direct and Sub-Advised Accounts) PGIM Custom Harvest provides discretionary advisory services to clients that enter into an investment advisory agreement with PGIM Custom Harvest directly or through a sub-advisory or similar arrangement with the sponsor of a managed account program or another investment adviser. Under such arrangements, PGIM Custom Harvest has full authority to determine which securities to buy and sell in the client account and, as described in Item 12 - Brokerage Practices, typically has the authority to select the broker-dealers with which to execute such securities transactions. PGIM Custom Harvest’s investment philosophy in managing client accounts is that it is driven to meet the needs and expectations of its clients by providing tailored investment advisory services to each client. Clients may impose restrictions on investing in certain securities or types of securities, most of which will be honored unless it is not feasible for PGIM Custom Harvest to incorporate a requested restriction into the management of a client’s account, in which case the client will be notified of the issue. PGIM Custom Harvest or the client’s sponsor firm or financial professional consults with the client initially and on an ongoing basis to ascertain the client’s investment objectives and any restrictions that the client may request. Client portfolios are monitored on an ongoing basis to ensure that any restrictions on a client’s portfolio are maintained and complied with. A client also may request a customized version of a PGIM Custom Harvest strategy or a customized investment strategy by establishing reasonable investment guidelines for management of the client’s account. Such guidelines may include allocation guidelines that vary significantly from those followed by PGIM Custom Harvest in managing non-customized client accounts. Most customization requests will be honored unless it is not feasible for PGIM Custom Harvest to comply with such guidelines in managing the client’s account, in which case the client will be notified of the issue. A client account that is subject to client-imposed restrictions or that is managed in accordance with a customized PGIM Custom Harvest strategy could experience performance that is significantly different from non-custom strategy composite returns and could experience significant tracking error relative to the relevant PGIM Custom Harvest strategy’s benchmark. In addition, a client- imposed restriction on transactions in specific exchange-traded funds (“ETFs”) within a sector could negatively impact PGIM Custom Harvest’s ability to harvest tax losses in that sector in the client’s account and the account’s after-tax performance relative to the after-tax performance of other PGIM Custom Harvest accounts. Non-Discretionary Advisory Services In addition to providing discretionary advisory services, PGIM Custom Harvest might enter into an advisory agreement with a managed account program sponsor or another investment adviser to provide non-discretionary services. Under such arrangements, PGIM Custom Harvest provides investment recommendations to the program sponsor or another investment adviser and such party has the ultimate authority to follow or not follow such recommendations. Depending on the provisions of the agreement between PGIM Custom Harvest and the program sponsor or investment adviser and the degree, if any, to which

PGIM Custom Harvest’s advice is tailored to the circumstances of each of the program sponsor’s or investment adviser’s clients, PGIM Custom Harvest might or might not be treated as having its own advisory client relationship with program clients. Wrap Fee Programs Certain of the managed account programs under which PGIM Custom Harvest offers its strategies and provides either discretionary or non-discretionary advisory services are unaffiliated third-party programs sponsored by registered broker-dealer firms that charge a bundled or wrap fee for investment advisory services and the execution of client trades (“Wrap Fee Programs”). The sponsor of a Wrap Fee Program is responsible for the execution of trades placed with the sponsor by the party with discretion over the client’s account. Where PGIM Custom Harvest provides discretionary or non-discretionary advisory services under a Wrap Fee Program and does not contract directly with the client, PGIM Custom Harvest is compensated for its services by the program sponsor out of the bundled or wrap fee that is charged to the client’s account. Accounts managed by PGIM Custom Harvest on a discretionary basis under a Wrap Fee Program are managed similarly to accounts managed by PGIM Custom Harvest on a discretionary basis that are not part of a Wrap Fee Program. Conflicts of Interest Conflicts of interest or potential conflicts of interest commonly refer to activities or relationships in which the interests of PGIM Custom Harvest or its affiliates compete with the interests of PGIM Custom Harvest’s clients. Like other investment advisers, PGIM Custom Harvest is subject to various conflicts of interest in the ordinary course of our business. When actual or potential conflicts of interest are identified we seek to address such conflicts through one or more of the following methods:
• Elimination of the conflict;
• Disclosure of the conflict; or
• Management of the conflict through policies, procedures, training or other mitigants. To address potential conflicts, PGIM Custom Harvest follows its own Conflicts of Interest Policy and Prudential’s standards on business ethics, inside information and information barriers. We also follow Prudential’s Code of Conduct, “Making the Right Choices,” which reflects Prudential’s core values and clarifies Prudential’s expectations of acceptable behavior. PGIM Custom Harvest also has adopted its own code of ethics, gifts and entertainment policy, and proxy voting policy, among others, and has adopted supervisory procedures to monitor compliance with our policies. We cannot guarantee, however, that our policies will detect and address, or result in the disclosure of, every situation in which a conflict could arise. Affiliate Relationships: As an indirect wholly-owned subsidiary of Prudential, PGIM Custom Harvest is part of a diversified, global financial services organization. We are affiliated with many types of financial service providers, including broker‐dealers, insurance companies and other investment advisers. These relationships could present potential or actual conflicts of interest. For example, our affiliates have an incentive to seek to influence decisions relating to client investment strategies to, among other things, invest in products that are managed by an affiliate or otherwise sponsored by Prudential. Further, certain third-party exchange-traded funds (“ETFs”) in which we invest that seek to track the performance of certain market sectors could invest in turn in securities of PRU. We seek to mitigate the risk from this conflict through policies, procedures, communication protocols, and periodic conflicts training of applicable PGIM Custom Harvest personnel. Client Relationships: PGIM Custom Harvest and its affiliates also derive certain indirect or incidental benefits from their advisory relationships with a client, other than advisory fees. Please see “Item 14 – Client Referrals and Other Compensation” for examples of such indirect or incidental benefits. Employee Roles: Some PGIM Custom Harvest senior managers perform other duties for Prudential affiliates. Conflicts of interest could arise from time to time in connection with these duties with respect to allocating management time, services, or functions among PGIM Custom Harvest and other Prudential affiliates. Outside Business Activities: From time to time, certain of our employees or officers could engage in an outside business activity. Any outside business activity is subject to prior approval pursuant to our personal conflicts of interest and outside business activities policy. Actual and potential conflicts of interest are analyzed during such approval process.