LFI is a Tennessee corporation and a wholly owned subsidiary of The Lincoln National Life Insurance Company, itself a wholly owned subsidiary of Lincoln National Corporation, which is a publicly held company. Since 1984, LFI has been registered as an investment adviser with the SEC under the Investment Advisers Act of 1940 (the “Advisers Act”). LFI provides investment advisory services to (1) registered investment companies (“Mutual Funds”), which are included in insurance products such as variable life and annuities offered by affiliated and non-affiliated life insurance companies, and retirement plans and accounts; and (2) private funds (“Private Funds”) and insurance company separate accounts (“Separate Accounts”), which are offered by affiliated life insurance companies. LFI’s responsibilities include, among other things, recommending and overseeing sub-advisers and their investment activities, broker selection, and trading practices to determine compliance with a mutual fund’s, private fund’s or separate account’s investment objectives, investment restrictions and any applicable federal securities laws. LFI provides asset allocation services which generally are limited to advice regarding investments in other affiliated and/or non-affiliated registered open-ended mutual funds and exchange-traded funds (ETFs). In addition, LFI provides advice (such as due diligence on managers and recommendations regarding the investment of assets) and oversight regarding the investments of the Private Funds and the Separate Accounts. LFI’s advisory services may vary depending upon the investment objectives, strategies, and restrictions imposed by each Mutual Fund or separate account. LFI does not participate in any wrap fee programs. As of January 31, 2024, LFI’s assets under discretionary management totaled $85,595,921,962. Investment Strategy Models LFI also provides certain research, in the form of investment strategy models to firms, including Lincoln Financial Advisors Corporation (“LFA”) and Lincoln Financial Securities Corporation (“LFS” and, together with LFA, “LFN”) – each an affiliate of LFI – for use by the firms in providing investment services to their clients.

LFI is paid a fee (in basis points) on the assets being managed pursuant to the model. The fee is calculated based upon the average daily value for the period during which client assets are managed by the firm according to the model. The models are representative of other LFI managed asset allocations services. LFI anticipates that firms will follow the provided models, but the firms – and not LFI – are acting in an investment advisory capacity to their clients and have investment discretion over their clients’ assets. As a provider of investment strategy models, LFI is not acting in an investment advisory or fiduciary capacity to clients utilizing LFI models through a firm. LFI hires consultants to assist LFI in developing and refining the asset allocation analysis underlying the investment strategy models. With respect to LFI investment strategy models available to LFN, LFI is an affiliate of LFN and therefore LFN has a conflict of interest because of its financial incentive to recommend LFI over other strategists that are unaffiliated and also available to provide model portfolios (“Unaffiliated Strategists”). Selection of LFI would generate additional revenue for LFN’s affiliate, LFI. LFN mitigates this conflict of interest by: disclosing it to investors; ensuring that any strategist fee received by LFI for providing models to LFN is not shared with the LFN investment advisory representative (“IAR”) recommending LFI for an investor account; ensuring that any strategist fee received by LFI is reasonable in light of the strategist fees charged for Unaffiliated Strategist programs offered by LFN; ensuring that IARs do not have discretionary authority to select a particular strategist, whether LFI or an Unaffiliated Strategist, on an investor’s behalf; ensuring that IARs are not incentivized or receiving any additional compensation when recommending LFI over an Unaffiliated Strategist; and requiring that there be a review of investor accounts and transactions at account-opening and periodically to determine whether they are suitable and in an investor’s best interest in light of the investor’s investment objectives, financial circumstances, and other characteristics.