Popular Asset Management LLC (“Popular Asset Management” or “PAM”) is a directly and wholly owned subsidiary of Popular, Inc., a diversified financial holding company registered under the Bank Holding Company Act of 1956, as amended, and subject to the supervision and regulation of the Board of Governors of the Federal Reserve System. Popular, Inc. is the sole owner of PAM. Popular, Inc. is a public company with no individual shareholder owning 25% or more of its shares. PAM is also an affiliated entity of Banco Popular de Puerto Rico (“Banco Popular”) and Popular Securities LLC (“Popular Securities”). Banco Popular is Puerto Rico’s largest commercial bank with consolidated total assets of approximately $70 billion as of December 31, 2023. Popular Securities is a broker‐dealer and investment adviser member of the Financial Industry Regulatory Authority (“FINRA”) offering investment services to retail customers. When we use the terms “we,” “us” and “our” in this brochure, we are referring to Popular Asset Management and the internal groups that support PAM. In addition, any references to “our employees” or “our officers” mean PAM officers or employees who work in the functional groups. Popular Asset Management provides investment advice to three open‐end mutual funds which are commonly known as the “Popular Family of Funds” (“Popular Funds”), seven closed‐end mutual funds which are commonly known as the “Puerto Rico Residents Tax Free Family of Funds” (“PRRTFF Funds” and collectively with the Popular Funds, the “Funds”) and separate accounts for several institutions. When referring to both the Funds and separately managed accounts, we use “accounts, portfolios or clients”. We provide Investment Manager Services as defined in Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) to retirement plans and pension plans based in Puerto Rico. We also provide consulting services to the Fiduciary Services Division of Banco Popular with respect to certain of Banco Popular’s retirement plan, pension plan and personal trust account clients. The Popular Funds and the PRRTFF Funds were previously registered investment companies under the Puerto Rico Investment Company Act of 1954. In 2018, the Economic Growth, Regulatory Relief and Consumer Protection Act was signed into law, which among other things, amended the Investment Company Act of 1940, as amended (the "1940 Act") to revoke the exemption that had previously been granted to investment companies created under the laws of Puerto Rico, the U.S. Virgin Islands, or any other U.S. possession from the registration requirements of the 1940 Act effective May 24, 2021. As a result, the Funds have each filed a notification of registration under the 1940 Act, which respectively became effective on May 21, 2021. Each of the Popular Funds has also filed a registration statement under the Securities Act of 1933, which, in the case of the PF‐TFF (as defined below), became effective on May 9, 2022 and, in the case of each of the PF‐HGF and the PF‐ IPF, became effective on November 1, 2022. Each of the PRRTFF Funds has also filed a draft registration statement under the Securities Act of 1933, which respectively as of March 30, 2023, have not yet been declared effective. In open‐end funds, investors can continually buy and redeem shares by adding or withdrawing their money from the funds and there is no limit to the number of shares that can be issued. Open‐end funds are required to periodically establish a price for their shares, called the net asset value per share, or “NAV”. The NAV is the market value of all the assets of the funds minus its liabilities divided by the number of shares outstanding. Open‐end funds are obligated to issue (sell) and redeem (buy) shares at their current NAV. The Popular Funds, similar to many open‐end funds, have distribution and service fees (12b‐1 fees), which include fees for marketing and selling fund shares, such as compensation to PAM’s affiliated financial advisors who sell fund shares, and paying for the advertising, printing, and mailing of prospectuses and sales literature to new investors. Closed‐end funds, on the other hand, issue a fixed number of shares to raise capital, similar to selling stock in an initial public offering (IPO). After the initial public offering, the shares of the closed‐end funds are traded in the secondary market between investors. Unlike closed‐end funds that are typically issued in the United States these closed‐end funds are not listed on any exchange. Additionally, there is a limited secondary market and as a result, investors in closed‐end funds may not be able to sell their shares as easily as shares that are traded on an exchange. Therefore, investors in closed‐end funds should generally hold these shares only as a long‐term investment and not for purposes of active trading. The descriptions of advisory services and other items of information in this Brochure below are generally organized under headings naming the category of client. The Popular Funds PAM is responsible for implementing the investment objectives and strategies of the Popular Funds. We are also responsible for the larger strategic investment decisions such as determining the Popular Funds’ investment style and asset allocation targets. Day‐to‐day security selection is generally performed by the portfolio manager of the individual fund. We regularly report to the Board of Directors of each of the Popular Funds regarding each Fund’s investment performance and compliance with various policies and procedures established to assist in managing the Popular Funds. Popular Total Return Fund, Inc. PAM serves as investment adviser to the Popular Total Return Fund, Inc. (“PF‐TRF”).

The investment objective is long‐term capital appreciation. Current income is the secondary objective. The PF‐TRF invests primarily in equity securities, consisting mainly of Exchange‐ Traded Funds (ETFs). Popular High Grade Fixed‐Income Fund, Inc. PAM serves as investment adviser to the Popular High Grade Fixed‐Income Fund, Inc. (“PF‐ HGF”). The investment objective of the PF‐HGF is to provide a high level of current income that is consistent with the preservation of capital. The PF‐HGF will normally invest at least 90% of its assets in securities within the highest rating category by one or more nationally recognized statistical rating organizations. The Fund intends to increase the amounts available for investment through borrowings, which subject to certain exceptions shall not at any time exceed 33 1/3% of the Fund’s total assets. Popular Income Plus Fund, Inc. PAM serves as investment adviser to the Popular Income Plus Funds, Inc. (“PF‐IPF”). The investment objective of the PF‐IPF is to provide a high level of current income. The PF‐IPF will invest 95% of its assets in fixed income securities within the four highest rating categories of one or more nationally recognized statistical rating organizations. At least 67% of the assets will be invested in securities issued by Puerto Rico issuers. The Fund intends to increase the amounts available for investment through borrowings, which subject to certain exceptions shall not at any time exceed 33 1/3% of the Fund’s total assets. PRRTFF Funds The PRRTFF Funds are co‐managed by PAM and UBS Asset Managers of Puerto Rico, a division of UBS Trust Company of Puerto Rico (“UBS”). PAM and UBS are co‐investment advisers to the PRRTFF Funds. We, in conjunction with UBS, are responsible for implementing the investment objectives and strategies of the PRRTFF Funds. Jointly, we are also responsible for the larger strategic investment decisions such as determining the PRRTFF Funds’ style and asset allocation targets. All Investment decisions including security selection are jointly approved by both PAM and UBS. The PRRTFF Funds intend to increase the amounts available for investment through borrowings, which subject to certain exceptions shall not at any time exceed 33 1/3% of the PRRTFF Funds’ total assets. The investment advisory fees for the PRRTFF funds are shared with the co‐adviser to the funds. Puerto Rico Residents Bond Fund I PAM serves as co‐investment manager to the Puerto Rico Residents Bond Fund I (“PRRBF”). The investment objective of the PRRBF is to achieve a high level of tax‐advantaged current income, consistent with the preservation of capital for its shareholders. Puerto Rico Residents Tax‐Free Fund, Inc., and Puerto Rico Tax‐Free Residents Tax‐Free Funds II, III, IV, V, and VI, Inc. (the “Tax Free Funds”) PAM serves as co‐investment manager to each of the Tax‐Free Funds. Each Tax‐Free Fund’s investment objective is to achieve a high level of current income that, for Puerto Rico residents, is exempt from Federal and Puerto Rico income taxes, consistent with the preservation of capital for its shareholders. Separately Managed Accounts We also manage separate accounts for institutions with fixed income, equity and Exchange Traded Fund (ETF) investment strategies. The PAM managed or co‐managed Funds are not used as an investment vehicle within the Separately Managed Accounts. Other Investment Advisory Services Consulting Services PAM is also an advisor to its affiliate, Banco Popular, with respect to various consulting services provided by Banco Popular through its fiduciary services division to retirement and trust accounts. In this capacity, PAM provides general consulting or investment consulting services. General consulting includes services such as attending investment committee meetings, creating and reviewing quarterly reports, providing input to model portfolios, etc. Investment consulting includes asset allocation recommendations, trade implementation, performance reporting, presentations to plan sponsors and Investment Policy Statement review. Investment Manager Services to Employee Benefit Plans (ERISA 3(38)) In some cases, Institutional Clients delegate discretionary management responsibilities to us. For our standard ERISA 3(38) service, where a Named Fiduciary of an employee benefit plan (“Plan”) delegates investment management responsibilities to us with respect to all or such portion of the Plan’s assets as the Named Fiduciary may designate, together with all income, proceeds, and profits derived therefrom, we serve as a fiduciary to the Plan, and we act with full authority in the selection, monitoring, and replacement of the Plan’s investment options. We provide periodic monitoring of the specific investments in the approved investment list. As investment manager, we have the discretionary power and authority to select and update the underlying investment options in the Portfolios. In addition, we have the power and authority to instruct the service provider to implement any transactions with respect to the plan and its assets as necessary. We provide ongoing monitoring of the Portfolios and, unless otherwise instructed by the Plan Sponsor, select and place orders for the execution of such securities transactions with or through such brokers, dealer or issuers as Manager may select, which brokers or dealers are entitled to receive compensation from the Account for their services. Assets Under Management (AUM) As of December 31, 2023, we had the following assets under management: Discretionary $648,125,376 Non‐Discretionary $1,505,572,480 Total AUM $2,153,697,856