About Us and the Program Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or “Merrill”), an indirect wholly-owned subsidiary of Bank of America Corporation “BofA Corp.”), is a global financial services firm that offers a broad range of brokerage, investment advisory, retail and other services. Merrill is registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer and has been registered as an investment adviser since 1978. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences. It is important to understand the differences, particularly when determining which service or services to select. You can review a general description of these programs in the “Summary of Programs and Services” at ml.com/relationships. Merrill offers investment advisory services under the Merrill Personal Retirement Strategy program (“Personal Retirement Strategy” or the “Program”) as discussed in this Brochure. For purposes of this Brochure, the following terms have the following meanings: (i) “MLPF&S”, “we”, “our” or “us” refers to Merrill; (ii) “participant”, “their”, “you” or “your” refers to the Plan participant; (iii) “Plan” refers to the participant-directed defined contribution plan maintained by the Plan Sponsor, or as applicable, the designee or other named fiduciaries of the Plan Sponsor (“Plan Sponsor”) utilizing Merrill’s recordkeeping platform and enumerated in the Master Services Agreement between the Plan Sponsor and Merrill (the “Master Services Agreement”); and (iv) “Employer” refers to the employer of the participant. All capitalized terms are defined in the body of this Brochure and/or in the Glossary which can be found at the end of this Brochure. Personal Retirement Strategy is an online investment advisory program available to participants of Plans that also utilize Merrill for recordkeeping services. Our Services as an Investment Adviser and Relationship with You under the Program. Merrill provides services to Plan participants under the Program in its capacity as a registered investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”) and a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The fiduciary standards we follow are established under the Advisers Act and ERISA. In Personal Retirement Strategy, Merrill acknowledges and agrees to be an ERISA Fiduciary, to the extent that it renders investment advice within the meaning of section 3(21)(A)(ii) of ERISA. When providing discretionary services in this Program through Merrill Managed, Merrill acknowledges that it is acting as an investment manager within the meaning of Section 3(38) of ERISA. A Plan Sponsor must enter into an amendment to the Master Services Agreement to make Personal Retirement Strategy available to Plan participants (the “Plan Sponsor Amendment”). You must enter into an investment advisory agreement with us (or will be provided information regarding the terms of that agreement where a Plan Sponsor uses Merrill Managed (defined below) as a qualified default investment alternative) (the “Participant Advisory Agreement”) that describes our obligations to you under the Program and expressly acknowledges that we act as a fiduciary under the Program and, with respect to Merrill Managed, you appoint us as a discretionary investment manager within the meaning of Section 3(38) of ERISA. The scope of our investment advisory relationship is defined in the Participant Advisory Agreement. Termination of your Participant Advisory Agreement will end that investment advisory fiduciary relationship. Under the Program, we are a fiduciary to the participant. Merrill has certain fiduciary obligations in providing services under the Program. As a fiduciary, we will act in your best interest and will endeavor to ensure that you are informed about and have access to material facts and information relating to services provided through the Program and described in this Brochure. The Brochure is a key element in meeting this disclosure obligation. This Brochure describes the advisory services that we provide, any fees that are charged for those services, our role and that of our personnel, our other business activities and financial industry affiliations and the economic and other benefits and arrangements we have that create conflicts of interest in certain situations. DESCRIPTION OF PROGRAM SERVICES The Program is designed to help you establish and pursue your retirement income

goals by providing you with tools, investment guidance and advice and access to investment management services delivered through the Program’s interactive Website at www.benefits.ml.com (the “Program Website”) and as described in this Brochure (“Services”). Before accessing the Services, please read the description of our Services and the other information in this Brochure and contact us at (866) 731-3127 if you have any questions. Personal Retirement Strategy will utilize data received from the Plan Sponsor and from you, if provided, to provide Services. Data used will include, but is not limited to, the participant’s Plan account balance and contribution rate, salary, account balance(s) and anticipated savings outside of the Plan, retirement age, and desired retirement income. If the neither the participant nor the Plan Sponsor provides the required compensation and indicative data, Personal Retirement Strategy will not be able to provide you with advice and guidance, and you will not be able to enroll into Merrill Managed. The Program Website allows you to provide information about certain other assets held outside the Plan. We also ask you questions to gather information about you. We incorporate the personal and financial information you have provided into the guidance and advice we provide under the Program, as described in this Brochure. It is your responsibility to ensure that the information you provide to us is complete and accurate. When you provide accurate and complete information, we are better able to make appropriate recommendations in this Program. It is also your responsibility to notify us if any information you have provided to us is inaccurate, becomes inaccurate or is incomplete. The Program provides investment advice and guidance through the following:
• Goal Funding Status Analysis
• Retirement Income Planning
• Retirement Tax Illustration
• Asset Allocation Recommendation
• Merrill Managed Detailed Description of Services Goal Funding Status Analysis Merrill will provide information and tools to assist you in determining 1) an annual retirement income goal, 2) your progress to accumulate sufficient total assets to achieve that annual retirement income goal (the “Goal Funding Status”), 3) a suggested contribution amount to your Plan account, 4) a suggested contribution amount to financial accounts external to your Plan account (External Accounts) that you have elected to provide information about that you are using to fund your retirement goal (such as IRA, Roth IRA, taxable brokerage accounts, and savings accounts) and 5) steps you can take that are designed to improve your Goal Funding Status. Personal Retirement Strategy will use a default retirement income goal of achieving 85% of your projected salary at your target retirement age and in each of your years in retirement (calculated based on your life expectancy or as provided by you). Your projected salary is your current salary adjusted for inflation. The Program Website provides you with the ability to customize the annual retirement income goal to either a different percentage of your projected salary or a target dollar amount, expressed in today’s dollars. Additionally, you’ll have the ability to see how changes to variables such as savings rate, retirement age, retirement income goal, household information, income and expenses in retirement, Social Security payments, additional accounts and more may affect your Goal Funding Status. Any suggestion to make a contribution to your Plan account and if provided, other financial accounts external to your Plan account, and general educational information for additional savings approaches are point in time recommendations designed to help you make your decisions for retirement based on the provided information at the time. The actual decisions you make related to the suggestion are not monitored or reviewed or updated on an ongoing basis. However, you can return at any time to engage with the goal funding analysis tool and receive additional point in time recommendations. Federal tax laws may limit the contribution rates in the Plan of some participants who are defined as “Highly Compensated Employees,” by the Internal Revenue Code. A majority of Plans utilizing Personal Retirement Strategy have implemented controls that will not allow Highly Compensated Employees to over contribute to the Plan. However, some Plans do not utilize these controls, which may cause Highly Compensated Employees to receive refunds of excess contributions. Participants defined as Highly Compensated Employees should adjust their contribution rate in the Plan to avoid such refunds. (see