A. Description of the Firm 1. Background Pentegra Investors is part of a complex of companies known today as Pentegra Retirement Services or simply Pentegra. Pentegra was founded in 1943 by the formation of the Pentegra Defined Benefit Plan for Financial Institutions (Pentegra DB Plan), a tax-qualified, defined-benefit retirement plan created for employees of the Federal Home Loan Bank System. The Pentegra DB Plan is currently a multiple-employer, defined-benefit retirement plan for employers primarily in the banking and credit union markets. It offers most of its services through its wholly owned subsidiary, Pentegra Services, Inc., (Pentegra Services), a for-profit Delaware Corporation. In the years since its formation, the Pentegra DB Plan has expanded its services and offerings and currently offers a range of financial services through Pentegra Services and its subsidiaries. 2. Pentegra Investors Pentegra Investors (formerly Retirement System Investors, Inc.) was incorporated in Delaware in 1989 and has been registered as an investment adviser with the United States Securities and Exchange Commission since August 1990. Pentegra Investors has been offering investment advisory services to clients since that date. In 2008, Pentegra Investors was acquired by Pentegra Services as part of an acquisition by Pentegra of a group of companies from Retirement System Group Inc., an unaffiliated firm that had been offering retirement plans and related services in some of the same markets as Pentegra. Through the acquisition, Pentegra Services also acquired a registered broker- dealer, Pentegra Distributors, Inc.; a Maine non-depository trust company, Pentegra Trust Company; a New York insurance agency, Pentegra Insurance Agency, among other entities. The addition of the regulated companies expanded the services that Pentegra Services could offer to its clients. B. Types of Services 1. Asset Management Services Pentegra Investors offers ongoing management of assets for retirement plans and for other institutional clients. Assets can be managed in both pooled accounts, such as collective investment trusts, for a group of clients or directly in separately managed accounts. Investments for some clients may be limited to registered investment company securities (mutual funds) or interests in collective investment trusts, exchange traded funds (ETFs) or other pooled investments. Investments for other clients may include all types of securities, such as equities, fixed income, and bonds. Where clients give Pentegra Investors discretion to implement the purchases and sales of securities, Pentegra Investors places orders directly with broker-dealers for the transactions it recommends. Pentegra Investors will also manage assets for clients on a nondiscretionary basis. Under those arrangements, the client must approve each transaction before Pentegra Investors will place an order to execute the transaction or for some clients, Pentegra Investors may recommend the transaction and the client directs the execution of the transaction. a. Outsourced Chief Investment Officer (OCIO) Services In addition to traditional asset management services, Pentegra Investors is also dedicated to providing clients’ investment committees and/or chief investment officers with the support they need to meet their fiduciary obligations in managing their respective assets. These outsourced chief investment officer (OCIO) services are marketed under the name Pentegra Client Solutions. Pentegra Investors’ OCIO services relieve much of the administrative and oversight burden otherwise placed on clients’ investment committees and/or chief investment officers. Pentegra Investors reviews and makes recommendations about the allocation and reallocation of each client’s entire portfolio on an ongoing basis. Pentegra Investors oversees the investment of client portfolios based on the guidelines and risk profile provided by the client and develops investment strategy, recommends portfolio

construction, addresses risk management and handles the hiring, retention and termination of asset managers. Pentegra Investors reviews the overall asset allocation of client assets and make recommendations as needed so that the client’s investment goals, guidelines, policies and risk profile are addressed on a continuing basis. 2. Model Portfolios Pentegra Investors manages the PENTelligent Portfolios, a series of four diversified model portfolios constructed along conventional risk tolerance lines comprised of the following: Conservative Portfolio, Conservatively Moderate Portfolio, Moderate Portfolio, and Aggressive Portfolio. The four model portfolios are comprised exclusively of ETFs, are broadly diversified across asset classes, and are rebalanced on a quarterly basis. The PENTelligent Portfolios are made available to institutional advisors and other financial intermediaries for a 25 basis point (bps) strategist fee. 3. Consulting and Educational Services Pentegra Services offers bundled services to its retirement plan clients that often include ongoing advice, education and consulting services to plan sponsors and/or participants. Where those services involve advice about securities, the services are provided by Pentegra Investors. The services of Pentegra Investors may include providing advice to plan sponsors about the securities that are used to fund the retirement plans, educating plan participants about the various investment options available under their retirement plans, and recommending tools to plan participants seeking assistance with their investment and retirement alternatives. Pentegra Investors does not provide individualized investment advice to plan participants or any other retail clients. C. Tailoring Services to Needs of Clients 1. Retirement Plans For all retirement plan assets, before beginning the management of the plan assets, Pentegra Investors evaluates any restrictions on investments or strategies for the plan, any restrictions communicated to it or known to be imposed by the Employee Retirement Income Security Act of 1974 (ERISA) and any risk levels, asset requirements or other guidelines that are imposed by the plan sponsor or investment committee. Based on its review, Pentegra Investors will recommend the management of the plan assets in a pooled or separate account that Pentegra Investors believes will meet the requirements of the plan. Pentegra Investors reviews those requirements at least annually with the plan sponsor, trustees and/or investment committee, as directed by the plan sponsor. 2. Other Institutional Clients The management of assets for other institutional clients is customized for each client. At the time Pentegra Investors enters into a contract with a client, and regularly thereafter, Pentegra Investors obtains information from the client concerning the investment guidelines, objectives, risk tolerance levels, financial requirements, investment restrictions, asset and liability structure and any specific requests or needs of the client. Pentegra Investors then recommends the type of structure – pooled investments or separate accounts and the types of securities for that client. Whatever the structure, Pentegra Investors continues to monitor the needs of the client to assure that the investments continue to meet the requirements of the client. 3. All Management Services All retirement plan services provided by Pentegra, to include asset management services performed by Pentegra Investors, are documented by a written agreement between Pentegra and the client, describing the services to be provided and the guidelines that must be followed, as well as any restrictions involved in serving the client’s needs and objectives. D. Wrap Fee Programs Pentegra Investors does not offer a wrap fee program. E. Assets under Management As of December 31, 2023, Pentegra Investors had $5,895,243,080 in assets under management, of which $3,697,789,914 was being managed on a discretionary basis and $2,197,453,166 was bei ng managed on a non-discretionary basis.