Washington Capital Management, Inc. (“WaCap” or “we”) is an SEC-registered investment adviser with its principal place of business located in Washington State. WaCap began conducting business in 1978. Listed below are the shareholders owning 5% or more of the company.
• Cory Carlson ............................................................... Chief Executive Officer & President
• Mark Clifford ................................................................. Senior Vice President, Real Estate
• Thomas Fisher ....... Executive Vice President, Senior Portfolio Manager, Real Estate Debt
• Patrick Malley ..................................... Executive Vice President, Chief Investment Officer
• Paul Ravetta .......................................... Executive Vice President, Chief Operating Officer WaCap offers the following advisory services to our clients: Portfolio Management WaCap is a multi-strategy investment manager that offers strategies/portfolios in stocks, bonds, commercial real estate (debt and equity) and feeder funds that invest in private equity funds managed by unaffiliated advisors. WaCap provides both privately offered commingled pooled investment funds (including feeder funds) and separately managed accounts. We serve as an investment manager primarily for institutional investors and accounts, such as pension and profit-sharing plans, corporations, charitable organizations, and governmental entities. Institutional investor clients generally engage us as an investment adviser for one or more of our investment strategies as determined by the client, working with us, to be an appropriate strategy for that client. WaCap manages specific investments, such as the pooled investment funds, based on the fund’s investment objective and strategy. For clients with separately managed accounts, investment portfolios are managed based on the investment guidelines as agreed upon between the client and us. We also manage separate account real estate equity and mortgage portfolios, both of which invest in secured mortgage loans and income-producing commercial real estate. These portfolios are managed in accordance with the client’s objectives and investment guidelines for the separate account. WaCap offers commingled pooled funds managed through the Washington Capital Joint Master Trust, a trust organized under the laws of the state of Washington and qualified and tax-exempt as a group trust under the provisions of IRS Revenue Ruling 81-100 (the “JMT” or the “Trust”). We are the Trust’s sponsor and discretionary investment manager. The Trust has established separate investment funds or portfolios that include a mid-cap growth fund, a fixed income fund, a mortgage income fund, a real estate equity fund, and a transportation infrastructure fund that invests its assets in a private equity fund managed by an unaffiliated investment manager (each, a “Fund”). Under the Trust’s governing documents, each Fund is separately held, managed, administered, valued, invested, distributed, audited, accounted for, and otherwise dealt with as a separate entity. Only qualified pension plans are permitted to invest in the Trust. Each Fund is exempt from registration as an investment company under the Investment Company Act of 1940, and its interests are exempt from registration under the Securities Act of 1933 in reliance upon an exemption available to an issuer whose securities are not publicly offered. Washington Capital Management, Inc. manages each Fund on a discretionary basis in accordance with the terms and conditions of the Master Trust Document and each Fund’s investment guidelines. WaCap also offers commingled real asset investments established as “feeder funds” (each, a “Feeder Fund”), both closed and open-ended funds, that invest in private equity and debt funds managed by an unaffiliated independent investment manager. Investors can include certain pension plans, profit sharing plans, retirement plans, or Government plans that are qualified purchasers or qualified clients and accredited investors (such investors are referred to as “Eligible Investors”). These funds are also offered for the benefit of qualified institutional investors subject to ERISA, who require the services of an ERISA fiduciary in connection with their investment through our Feeder Funds. WaCap also offers a comingled mortgage real estate fund outside of the JMT that anticipates applying the same fee structure and strategies as the mortgage real estate account offered through the JMT. Only qualified investors are permitted to invest in this fund. 3/25/2024

Washington Capital Management, Inc. -4- In addition, we provide investment management services to individual clients based on the needs of the client. Through personal discussions in which goals and objectives based on an individual client's particular circumstances are established, we assist the client in developing investment guidelines and manage a portfolio based on the client’s guidelines. During our information and data gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family or business composition and background. We generally manage client accounts on a discretionary basis. Clients have the opportunity to place reasonable restrictions on the types of investments to be held in their separately managed accounts. Account supervision is guided by the client's stated investment guidelines, investment policy statements, and tax considerations, if applicable. In some limited cases, primarily in a few separately managed real estate debt and equity accounts, we manage client accounts on a non-discretionary basis where the account requires client pre-approval of investment acquisitions or dispositions. Once the client's portfolio has been established, we monitor and review the portfolio on an ongoing basis. Our advisory services include, but are not necessarily limited to, investments in the following:
• Exchange-listed securities, including Exchange Traded Funds and iShares
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Interests in partnerships investing in real estate
• Other private investments: commercial mortgages, real estate equity, bonds, privately offered pooled investment funds (including Feeder Funds) Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we:
• Send quarterly account reports to the client and any other party as the client directs us
• Maintain contact with clients to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to modify existing investment guidelines
• Be reasonably available to consult with the client Consulting Services WaCap also offers consulting services, primarily related to real estate and economic consulting. Services include, but are not limited to, advice concerning investment strategy, policy statements, and asset allocation as well as advice on specific real estate transactions, investments, or market analysis. We also provide Qualified Professional Asset Manager (QPAM) services for clients that are employee benefit plans regulated by the Employee Retirement Income Security Act of 1974 (“ERISA”). WaCap is a QPAM within the definition set forth by the Department of Labor. Our net worth exceeds $1,000,000 and institutional assets under management exceed the $85 million minimum requirement. QPAM services include, but are not limited to, the following:
• Assessing and resolving “party in interest” conflicts
• Evaluating and engaging external real estate service providers
• Asset management
• Property acquisition
• Property disposition 3/25/2024 Washington Capital Management, Inc. -5-
• Development/redevelopment
• Property appraisal
• Valuation
• Client reporting Amount of Managed Assets As of December 31, 2023, we were actively managing $8,385,398,695 of clients’ net assets on a discretionary basis and were actively managing or loan servicing $551,053,302 of clients' net assets on a non-discretionary basis. Total firm assets under management include both discretionary and non-discretionary accounts managed and serviced including equity, fixed income, net real estate equity, real estate debt, and Feeder Funds. The amount of these net assets will differ from “regulatory assets under management” as reported in our Form ADV Part 1.