Advance Capital Management, Inc. (“Management”, “we” or “us”) provides investment advice to many types of clients including individuals, investment advisers, investment companies, pension, profit sharing and other forms of retirement plans, trusts, estates, charitable organizations, and corporations. We were founded in 1986 and since that time have offered investment advisory and consulting services. We are owned by Advance Capital Group, Inc. (“ACG”). The principal owner (person who owns 25% or more) of ACG is the ACG Employee Stock Ownership Plan. The remaining shares are owned by John C. Shoemaker, Raymond A. Rathka, Robert J. Cappelli and Christopher M. Kostiz. As of December 31, 2023, we managed a total of $ 4,023,482,795 in assets. This includes approximately $ 3,900,057,983 in assets managed on a discretionary basis, and approximately $ 123,424,812 managed on a non-discretionary basis. Advance Capital Management, Inc. is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Advance Capital Management, Inc. may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset Advance Capital Management, Inc.'s advisory fees. Individuals We specialize in financial planning. Financial planning involves providing individualized investment advice based upon each client’s needs and objectives. Discussions normally begin with an analysis of the client’s risk tolerance, income objectives and growth expectations. In most cases a detailed financial plan is created based on these objectives. The plan is used as the cornerstone from which we derive specific investment recommendations, projected asset growth, income projections, expected tax implications and other detailed financial information. Financial planning services are generally limited to advice and recommendations on those securities for which fees are charged, and recommended securities are generally limited to mutual funds and exchange traded funds (“ETFs”). In certain client specific circumstances, we may provide investment advice on a range of securities beyond mutual funds and ETFs. These securities may include exchange listed and over-the-counter securities, foreign issues, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities and U.S. Government securities, commodities, precious metals, public and private real estate, private debt and private lending vehicles, private equity funds, structured products, and crypto currencies and other digital assets. Clients may request restrictions on investing in certain securities or types of securities. We will review the feasibility of such restrictions and inform the client as appropriate. Institutional Investment Consulting We act as an

investment adviser or sub-adviser to various institutional clients such as other financial services firms, banks, foundations, endowments, and pension funds. In this capacity, we offer our consulting services on a discretionary and non-discretionary basis based on the client’s investment policy statement and after general discussions with the client. Our services may include investment policy statement review and construction, asset allocation review, investment manager research and selection, portfolio construction, reporting, performance review, trading, and other ancillary services as agreed upon. Platform Advisory Services (Sub-Advisory Services): We offer our investment strategy and portfolio modeling services to other investment advisers on a sub-advisory basis. In these cases, we are contracted by the client for our investment management services and the use of our investment models and asset allocation strategies. We will also provide necessary training on those strategies, quarterly updates, and limited sales support to promote the use of the strategies by advisers using the investment manager’s suite of services. Retirement Plans We provide a full set of consulting and investment advisory services to retirement plan sponsors, whose plans are typically subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The specific services we provide to a plan sponsor and its plan participants may vary and are governed by the specific terms and conditions of the Retirement Plan Investment Advisory Agreement (“Plan Agreement”) we execute with each plan sponsor. IRA-based retirement plans (SEP IRAs, SIMPLE IRAs, etc.) are supported through our individual service platform. Our core advice service is designed to assist the plan sponsor with their fiduciary responsibilities and to give their employees substantial opportunities to save for retirement. Based on fi360's "Prudent Practices for Investment Advisors" handbook (www.fi360.com), our advice covers:
• the investment line-up,
• plan design and provisions, including automatic enrollment, escalation, etc.,
• the Investment Policy Statement (IPS),
• the Qualified Default Investment Alternative (QDIA),
• investment safe harbors,
• plan cost analysis and benchmarking,
• plan administration guidance,
• employee enrollment and education (within the meaning of the U.S. Department of Labor guidance in Interpretive Bulletin 96-1), and
• Third-party vendor review and coordination (recordkeeper, TPA, etc.). Investment lineup services involve the selection, monitoring, removal, and or replacement of investment options under the plan in accordance with the governing written investment objectives. Advance Capital Management conducts these services as a fiduciary and either as a discretionary 'investment manager" under ERISA 3(38) or as a non-discretionary "investment consultant" under ERISA 3(21), per the arrangement agreed to by the plan sponsor and set forth in the Plan Agreement. Our "Chief Retirement Officer" service is an enhanced offering geared towards improving retirement plan effectiveness and employees' overall financial wellness. Through results-based strategies designed to encourage employee engagement and to monitor overall retirement readiness, we work with the plan sponsor and individually with plan participants to attain their specific goals and objectives.