Founded in 1985, Dunham & Associates Investment Counsel, Inc. (“DAIC”) is a private wealth management firm, registered with the SEC as an investment adviser and Broker-Dealer. DAIC is wholly-owned by Dunham & Associates Holdings, Inc. (“Dunham Holdings”), which also owns Dunham Trust Company (“DTC”), a Nevada Trust Company. As of December 31, 2023, DAIC, together with DTC, had approximately $4.58 billion of assets under administration. Of that amount, DAIC had $3.07 billion in discretionary assets under management and $693 million in non-discretionary assets under management. The principal owner of Dunham Holdings is Jeffrey A. Dunham, Chief Executive Officer of DAIC. DAIC currently offers four types of advisory services: mutual funds, wrap programs, separately managed accounts (“SMAs”) and investment consulting services. DAIC offers a proprietary family of sub-advised mutual funds (the “Dunham Funds”) that operate on performance-based advisory fees, commonly known as fulcrum fees. DAIC is the investment adviser to the Dunham Funds. DAIC selects sub-advisers based on its evaluation of their skills and investment results in managing assets for specific asset classes, investment styles and strategies. The investment objectives of the Dunham Funds range from current income to total return. The Dunham Funds represent unique asset classes and are available individually or as part of wrap programs. DAIC sponsors two wrap programs: (i) the Standard Asset Allocation Program (“Standard Program”); and (ii) the Custom Asset Allocation Program (“Custom Program”) (collectively, the “Wrap Programs”). DAIC selects the Dunham Funds, or other mutual funds that are offered in the Wrap Programs. DAIC also determines the allocations and sector weights of the core asset allocation models (“Core Allocations”) for the Wrap Programs. Clients choose from the Core Allocations and/or any combination of eligible Dunham Funds available in their selected Wrap Program or the DunhamDC proprietary algorithm (“DunhamDC”, “Program”) representing different asset classes. The Standard Program features seventeen Allocation models. The Custom Program allows clients to invest in any combination of the eligible Dunham Funds and/or Core Allocations. Clients may place reasonable restrictions, or make reasonable modifications to existing restrictions, regarding the management of their Wrap

Program account. DAIC provides SMAs for high-net-worth individuals. DAIC serves as investment adviser to the SMAs and tailors its investment advice to each client based on the client’s investment profile/objectives. The SMAs may invest in individual securities, ETFs and mutual funds, including Dunham Funds. Clients may place reasonable restrictions, or make reasonable modifications to existing restrictions, regarding the management of their SMAs. To the extent specifically requested by a client, DAIC may determine to provide portfolio review and non-discretionary investment consulting services. Prior to engaging DAIC to provide stand- alone consulting services, clients are required to enter into a Consulting Agreement with DAIC setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client prior to DAIC commencing services. In performing its portfolio review and investment consulting services, DAIC shall not be required to verify any information received from the client or from the client’s other professionals, and it is expressly authorized to rely thereon. Moreover, each client is advised that DAIC’s services do not include investment implementation or ongoing investment supervision, monitoring, or reporting services. If requested by the client, DAIC may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from DAIC. Financial advisors may, as agreed from time to time with clients, provide financial planning or financial consulting services to clients utilizing the Dunham Retirement Income Plan (“DRIP” or “Plan”). DRIP places the focus on developing strategic investment plans that are based on the individual needs of clients. This framework attempts to help investors understand the benefits of having an overall long-term investment approach while segmenting their portfolio into two or more portfolios to budget for any combination of short-, mid-, and long-term goals. The financial advisor may recommend DAIC’s Custom Asset Allocation Program as a means of implementing the different portfolio strategies.