THE COMPANY Transamerica Financial Advisors, Inc. (“we/our/us/TFA”) is a registered investment advisor registered with the SEC since 1991. TFA is also a broker-dealer and has been a member of the Financial Industry Regulatory Authority (FINRA) since 1984 and member Municipal Securities Rulemaking Board (MSRB). This enables us to offer a wide range of financial products to our clients such as variable annuities, mutual funds, and other financial products. TFA’s core mission is offering financial products and services, employer retirement solutions, and life insurance. TFA is directly owned by AUSA Holding, LLC, Commonwealth General Corporation, and AEGON Asset Management Services, Inc., which are indirect, wholly owned subsidiaries of the ultimate parent, AEGON N.V., a publicly traded company listed on the New York Stock Exchange (NYSE) and trading under the symbol AEG. SERVICES In its capacity as a registered investment advisor, TFA offers various types of advisory services and programs, including wrap fee programs, third-party money management programs, and employee retirement services. TFA’s advisory services are made available to clients through individuals registered with TFA as investment advisor representatives (“Advisors”). Please refer to TFA’s current Form ADV Part 2A for information regarding these services. The information in this Wrap Fee Brochure pertains to the Transamerica® ALPHA Program (“Transamerica® ALPHA” or “Digital Advice Program”) only. This brochure describes the Transamerica® ALPHA program, however, TFA Advisors can offer you advisory services other than Transamerica® ALPHA, those advisory services are described in a different brochure. For example, Advisors have access to third-party money managers who manage model portfolios on behalf of clients. Additionally, Advisors can refer you to various third-party providers that offer certain administrative services relating to employee benefit plans. TFA Advisors have access to Transamerica® ONE which is a wrap fee program that offers clients access to fee-based investment management. TFA also manages Transamerica® Strategy Solutions which is a suite of risk-based allocations to strategies on the Transamerica® One platform. TFA Advisors have access to TFA Elite which is a wrap fee program that offers various types of investment alternatives that vary in terms of strategies and investment style dependent upon the model portfolio selected. For more detailed information about these programs, your Advisor can provide you with a copy of TFA’s Form ADV Part 2A or you can access the form directly by visiting our public website at www.tfaconnect.com. At the time TFA offers you our advisory services, our Advisor conducts an interview with you to determine your financial needs, time horizon, and objectives. The Advisor will analyze your current financial situation, investment goals, and present strategies. The Advisor will then provide advice to you based on the Advisor’s analysis. The Advisors do not provide legal, tax or accounting advice. If your Advisor determines that your stated investment objectives are best met by investing in Transamerica® ALPHA, your Advisor will recommend that you open an account within the Transamerica® ALPHA program. Your Advisor will also explain any special instructions for the management of the assets in a Transamerica® ALPHA account; the investment management process, investment objectives, and the investment strategies undertaken as part of the service; review and assist you in completing the electronic and/or written materials required to open the account; and answer questions about the service. Your Advisor will meet with each of their clients enrolled in the Transamerica ® ALPHA Premier program, at least annually, to review your stated investment objectives and goals to assess whether a Transamerica ® ALPHA Premier account is still in your best interest given your current investment objectives. Transamerica® ALPHA is a digital advice program under which clients receive investment portfolio recommendations and discretionary investment management of the assets held in their accounts. To make some of the services in Transamerica® ALPHA available, TFA has an agreement with Betterment LLC (“Betterment” or “Sub-Advisor”), an unaffiliated registered investment advisor. Betterment provides sub-advisory services to clients in Transamerica® ALPHA, including the model portfolios recommended through the program’s website. Additionally, the client delegates discretionary authority to Betterment regarding the day-to-day management and trading of each client’s account underlying the program. TFA and your Advisor will not have, nor exercise, discretionary authority over your account in the Transamerica® ALPHA Program. Clients and prospective clients will receive a copy of Betterment’s Wrap Fee Brochure, which contains additional information regarding Betterment’s services, processes, and policies. Clients and prospective clients should understand that Transamerica® ALPHA is a digital offering and that the primary method of communicating with clients and providing client’s investment advice will be through the Transamerica® ALPHA website and/or other digital interfaces that are available. The Transamerica® ALPHA program offers clients the ability to participate in a centrally managed, goals-based investment advisory program that is made available through the Transamerica® ALPHA web-portal. Your Advisor and Betterment are responsible for providing ongoing guidance and advice for the suitability of the Program. Through the Betterment website, your Advisor and Betterment can review your investments and goals and provide recommendations to help you achieve your investment objectives. The recommendations are limited algorithms and are based upon the information you have provided through the Transamerica® ALPHA web-portal. Transamerica® ALPHA uses Betterment’s proprietary, automated, computer algorithms to create asset allocation portfolios for a client’s goals and to provide certain services described in this Wrap Fee Program Brochure, including:
• Determining the asset allocation to recommend to each client, based on the client information captured during the account opening process.
• Clients can elect to automatically update asset allocations for each goal as the goal date gets nearer.
• Providing trade orders in each client’s account underlying the program(“Account”).
• Monitoring Transamerica ® ALPHA Accounts regularly to determine whether to rebalance back to the target asset allocations based on parameters determined by Betterment in its sole discretion (current drift parameters vary based on the percentage of the client’s portfolio that each asset class represents); and
• At a client’s election, placing trades for tax loss harvesting purposes (as further described below). The model portfolios are developed and overseen by Betterment, Vanguard, or TFA. Betterment seeks to create asset allocation that maximize returns for given levels of risk, refines the Model Portfolio Theory (MPT) allocations to consider potential increases in exposure to value and small capitalization equities. Betterment’s Socially Responsible model portfolios may use socially responsible ETF’s for various asset classes at Betterment’s discretion. Vanguard’s model portfolios are based on a long-term static asset allocation chosen at Vanguard’s discretion. TFA will not provide or review performance information to determine or verify its accuracy and does not calculate model portfolio performance. This information will be reviewed and provided by Betterment. Transamerica® ALPHA Stars portfolios will use ETFs to gain broad market exposures to both stocks and bonds which are diversified across asset categories, industries, and countries but with a heavy weighting toward the U.S. and with a bias in growth stocks over value stocks. The ideal client prefers less trading and higher tax-efficiency (long-term capital gains/losses rather than short-term). Risk management is based solely on stock-bond allocations rather than active management. The portfolio has some active management in that ETFs used in each asset categories will be periodically reviewed and replaced by TFA based on risk, returns, ratings, daily liquidity, fees and other metrics as measured over select trailing time periods. Under Transamerica® ALPHA, TFA and Betterment collect certain demographic information, financial information, initial and ongoing investment amounts, investment time horizon, and investment objectives to recommend an asset allocation for the chosen model portfolio comprised of exchange-traded funds (“ETFs”) that are diversified across multiple asset classes. The model portfolios TFA defaults to are TFA’s Alpha Stars portfolios, which consist of a set of globally diversified stock and bond allocations through ETFs. Clients also have the option to alternatively select from Betterment Core Portfolios, Betterment Socially Responsible Portfolios or Vanguard Portfolios. The percentage of stock and bond allocations is based on the answers to the information collected from the client. Clients have the option of accepting the model asset allocation recommended by the algorithm or adjusting the parameters for the purpose of receiving a different model asset allocation. Adjusting the parameters may lead to a recommendation that is not risk appropriate for such clients. To participate in the Digital Advice Program, clients must establish an account with Betterment Securities, an affiliate of Betterment. The account is a brokerage account that is opened when the client enters into a separate customer agreement with Betterment Securities to act as the introducing broker-dealer for all transactions executed under the Digital Advice Program. Please refer to “Brokerage Practices” below for additional information. TFA and its Advisors are not a party to this agreement. After a client has established an advisory relationship with TFA and opened an account with Betterment Securities, the assets in such account will be managed on a discretionary basis by Betterment in accordance with the model portfolio selected by the client. In order to permit time to ensure that the transfer of assets from a client’s existing bank, brokerage, or custodial account into a client’s account has been successfully completed and to complete any other required processing, there may be a delay of typically no more than 3 business days between the time the applicable deposit is credited to the account and the time when Betterment begins to place orders to purchase ETFs for the account. As a result, the deposit or transfer made will generally not be invested immediately upon opening an account and clients will not be subject to investment gains or losses resulting from the movement in market prices until the processing is completed. Fees are not assessed until assets are invested in the program’s model portfolios. To be a client of Transamerica® ALPHA, TFA requires a minimum asset value of $10.00 for a Program account to begin being managed. Note that an account will not be invested according to a Model Portfolio until the applicable minimum for the Model Portfolio and allocation has been reached. Clients may impose reasonable investment restrictions on the management of their accounts. If a requested investment restriction is deemed to be unreasonable, or if TFA determines that a previous restriction has become unreasonable, TFA will notify the client that, unless the instructions are modified, TFA may reject or terminate the client relationship at its discretion and upon notification to the client pursuant to the notification terms in the applicable Advisory Brochure and this Appendix. Clients should notify their TFA Advisor in the event there are changes in a client’s financial or demographic information or financial objectives or any other information previously provided, so that the Advisor can help each client assess whether the selected model portfolio is still appropriate based on the client’s stated investment objectives, investment time horizon, risk tolerance and any other pertinent factors. Advisors will review with each of their clients enrolled in the Transamerica ® ALPHA Premier program at least annually, whether any of the above noted information has changed and update investments if warranted. Transamerica ® ALPHA also offers tax-loss harvesting services to clients who opt for this service. Betterment will use algorithms to analyze tax-loss harvesting opportunities (such as gains or losses) and wash sale management. Clients, and not TFA, are responsible for any tax consequences or tax or filing obligations resulting from the sale of securities in their account and from their election of tax-loss harvesting, if applicable. The tax-loss harvesting service does not provide a comprehensive tax management solution. Clients should consult their tax advisor prior to making any decision that may affect their tax obligations. TFA, TFA Advisors, and Betterment do not provide tax advice. Within the Transamerica ® ALPHA program, clients will enroll in a Standard or Premier version. Specific features and services of each are outlined below: Features and Services Transamerica ® ALPHA Standard Transamerica ® ALPHA Premier Personal One on One Advice 1 Upon Request Yes Automated Rebalancing Yes Yes Automated Tax Loss Harvesting Optional Optional Tax Coordinated Portfolios (Auto Asset Placement) 2 Optional Optional Conduct Advisor Led Annual Reviews Upon Request Yes Aggregated Reporting - Of Held-Away Assets3 Yes Yes Easy to use Internet based Platform & Live Customer Support via Phone or Email Yes Yes This is not intended to represent a comprehensive list of all features and services available through the Standard or Premier versions of the Transamerica ALPHA program. If you need clarification on which version you are enrolled in, or if you would like to switch between the Standard or Premier versions, please contact your TFA Advisor. 1 Personal One on One advice will include, but not be limited to, advising clients on personal “What If?” scenarios, offering behavioral coaching, implementing personalized investment strategies with the coordination and consideration of the client’s existing holdings, and providing life events consultation along with ad hoc advice. 2 Tax Coordinated Portfolios are not designed to, and do not, provide comprehensive tax advice to clients. Clients are solely responsible for the determination of whether, and

when, to enable these features in their accounts, as well as any tax consequences arising from any transaction associated with these features. 3 Betterment will not base its recommendations on external accounts that clients sync to their Betterment account via Betterment’s online interface. Clients should also understand that use of this feature is not directly incorporated or correlated into a client’s Transamerica® ALPHA investment strategy or performance. BROKERAGE PRACTICES/TRADE EXECUTION In connection with the client’s participation in Transamerica ® ALPHA, the client will authorize all trades for his or her account to be placed with Betterment Securities, in its capacity as an introducing broker-dealer, to be cleared and settled through the custodian Apex Clearing Corporation (“Apex”). Millennium Trust Company will serve as the custodian for qualified retirement accounts. Clients will bear the risks associated with these transactions and should understand that Betterment will send all trades to Betterment Securities for execution (which will use Apex for clearance and settlement) even if the use of a different broker-dealer may result in lower prices or more favorable execution. Clients will receive the price at which such orders are executed in the marketplace. Each client participating in the Transamerica® ALPHA Program is required to enter into a brokerage account agreement with Betterment Securities to open an account that will hold the client’s assets covered by the program. Clients also direct that all orders for the purchase or sale of securities in their accounts will be introduced to Apex by Betterment Securities and settled and cleared by Apex. By directing trades in the foregoing manner, TFA will not be able to: (i) select broker-dealers on the basis of price or other attributes; (ii) negotiate commissions or negotiate the price or quality of the custody, settlement and clearing services provided by Apex Clearing; or (iii) aggregate or “batch” orders for purposes of execution with orders for the same securities for other accounts managed by TFA which are not executed by Betterment Securities or settled and cleared by Apex. As a result, certain transactions may result in less favorable net prices on the purchase and sale of securities than would be the case if TFA were able to select other broker-dealers. The ability to achieve best execution may be partially or wholly limited by the nature of the directed brokerage arrangement and clients may not achieve executions of the nature, quality, speed, or price that might otherwise occur. As a result of the foregoing, a client’s account might not generate the returns it would if orders were not directed. However, since management of the account occurs via a bundled fee arrangement that includes the costs of Betterment Securities’ execution services and Apex’s settlement and clearance services, the use of Betterment Securities and Apex should not result in additional brokerage fees to a client. Clients authorize TFA and Betterment to aggregate purchase and sale orders for securities held (or to be held) in client accounts with similar orders being made on the same day for TFA’s and Betterment’s other accounts which are also custodied or cleared through Apex. Betterment may aggregate trades for clients and transmit “batched” orders to reduce market impact and to obtain best execution. In some cases, aggregating orders may adversely affect the size of the position obtainable, and in some cases, clients would receive better price execution if they did not participate in a batched order. Clients do not pay separate fees for trade execution, clearance, settlement, or custody services received under the Transamerica ALPHA program. Additional details about trade execution, account maintenance, and asset custody may be found in Betterment’s Wrap Fee Brochure. Betterment generally trades on the same business day as it receives deposits or withdrawals; however, transactions will be subject to processing delays in certain instances. For example, orders initiated on non-business days or before/after trading hours (prior to 9:30AM EST or after 4:00PM EST) will not transact until the stock market opens (9:30AM EST) that same day or the following business day. Each trading day, Betterment’s trading team conducts a market assessment prior to market open to review items such as, but not limited to, market volatility, bid-ask spreads, and ETF market prices. Should Betterment’s trading team decide during their market assessment that factors in the market are causing heightened volatility, they have discretion to not trade or halt trading until they believe pricing has normalized. Betterment may, at any time and without notice to TFA or the client, delay or manage trading in response to market volatility. Betterment has a practice of generally not placing trades during approximately the first thirty minutes after the opening of any market session to avoid periods of market volatility. Betterment also generally stops placing orders arising from model portfolio allocation changes (including rebalancing and increasing or decreasing the exposure to asset classes) approximately thirty minutes before the close of a market session. Betterment will continue to place orders associated with withdrawals and deposits until the market closes. Client account deposits are automatically subject to a processing period that may be up to five business days or longer. Deposit-related transactions will not occur until the next business day after this processing period is complete. Clients should refer to Betterment’s Wrap Fee Brochure for additional details regarding its portfolio management practices. FEES AND COMPENSATION For services provided under Transamerica® ALPHA, clients pay an annualized wrap fee for the ongoing services of TFA and Betterment which include, but are not limited to investment advisory services, the execution of transactions and other administrative and custodial services. Two service model options are available to clients: a Standard Service Model and a Premier Service Model each priced as follows: Program Assets Billed Client’s Total Fee Betterment’s Portion of Total Fee TFA’s Portion of Total Fee Transamerica® ALPHA Standard All Assets 0.65% 0.25% 0.40% Transamerica ® ALPHA Premier First $10,000.00 1 All assets over $10,000.00+1 0.65% 0.95%2 0.25% 0.25% 0.40% 0.70% 1 Clients with $10,000 or less in total assets invested in the Program will be placed in the Standard Service level. For clients with multiple accounts in Transamerica® ALPHA, the applicable program will be determined based on the combined assets in all accounts within Transamerica® ALPHA by the client with matching social security numbers (“SSN”). For joint account with multiple SSN’s, all accounts with a matching SSN will be included as part of the combined assets calculation. For trust accounts, all accounts matching the trustee’s SSN (not the trust’s Federal tax ID number) will be included as part of the combined assets calculation. Please refer to the account establishment paperwork for Transamerica ® ALPHA for additional details on aggregating fees and expenses. 2 TFA’s portion of the client’s total fee within the Transamerica ® ALPHA Premier program may be negotiable. TFA will pay the Advisor a portion of its fee according to a compensation grid that may change from time to time. The amount of the fee you pay TFA may be higher than the fees charged by other investment advisors for similar services. Please note, Betterment, LLC offers direct-to-consumer services. Therefore, clients would pay a lower advisory fee for similar investment strategies as Transamerica® ALPHA [algorithm-driven, automated (“Digital Advisor”)] investment advisory services by investing directly with Betterment, LLC or other similar Digital Advisors, but would not receive the personal advice provided by TFA Advisors. The relative cost of the Transamerica® ALPHA program is affected by such factors as the administrative costs associated with wrap fee arrangements, the fees charged when investment adviser and brokerage services are purchased separately, and the size of a client’s account. The Wrap Fee does not include certain fees and charges associated with securities transactions, including the following: (i) charges imposed by law; and (ii) internal charges and fees, including redemption or short-term trading fees, that may be imposed by any collective investment vehicles, such as mutual funds, closed-end funds, or exchange-traded funds (clients pay a pro-rata portion of such fees, which are in addition to the fees paid to TFA under the program). All fees paid to TFA, or Betterment are separate and distinct from the fees and expenses charged by ETFs to their shareholders. These fees and expenses are described in each ETF’s prospectus. All ETFs held within the Transamerica® ALPHA account have ongoing expenses that will impact the return received by the client’s account. The ongoing expenses include management fees, distribution expenses, shareholder servicing, and other similar fees and are automatically deducted by the ETF daily. The ETFs charges and expenses are subject to change. An explanation of the ETF charges and expenses are provided in each ETF’s prospectus for client review. Clients should read each ETF’s prospectus carefully. The total fees charged under the Transamerica® ALPHA program may be higher than what another investment adviser firm would charge for a similar combination of services if the investment advisory and securities brokerage services were provided separately. The relative cost of the Transamerica® ALPHA program is affected by such factors as the administrative costs associated with wrap fee arrangements, the fees charged when investment adviser and brokerage services are purchased separately, and the size of a client’s account. WRAP FEE BILLING The Wrap Fee is accrued daily in arrears by applying the applicable advisory fee rate (0.65% or 0.95% as applicable) to the average portfolio value of all assets of client’s account as of the close of each calendar day. Monthly, Betterment will calculate the applicable Wrap Fee and will automatically deduct the amount due from a client’s account. The model portfolios in the Transamerica ® ALPHA program do not have an allocation to cash. Accordingly, securities will be sold monthly to pay for the Wrap Fee. In non-tax qualified accounts such sales may result in a taxable event for clients. Clients are solely responsible for all taxes payable in connection with the sale of securities in their account. Clients should consider such tax ramifications before deciding to participate in the program. Additional assets may be added at any time and will result in an adjustment to the Wrap Fee with respect to such new assets prorated from the date of the addition. Withdrawals of assets may be made at any time. The proceeds of a withdrawal will be delivered to the client after the time necessary for the resulting trades to clear and settle. Either TFA or a client may terminate the investment management agreement at any time with written notice, effective as of the date of the notice and thereby terminate an account under the Transamerica® ALPHA program. Upon termination of the agreement, Betterment is authorized by client via the Client Services Agreement to redeem or otherwise liquidate any investments in the account and disburse the proceeds to the client. Such redemption or liquidation will affect the asset allocation and/or market value of the account and may also have tax consequences. The client may alternatively request transfer of assets to a broker- dealer other than Betterment Securities by submitting a request to Betterment in a form determined by Betterment Securities. Certain assets held in the account may not be accepted by another broker-dealer and, therefore, may need to be liquidated and not transferred in- kind. Betterment and TFA shall not be liable for any losses caused by the liquidation of securities pursuant to the termination of the investment management agreement, including but not limited to any tax liabilities. CUSTODIAN FEES AND CHARGES The custody fee charged by Betterment Securities will be paid out of the Wrap Fee. CHANGES IN FEES TFA, at its discretion, may revise TFA’s portion of the Wrap Fee with 30 days prior notice to clients which will increase the fees paid by the client. A client will be deemed to have approved a fee change unless he or she objects to the fee change by sending written notice to TFA within 30 days from the date of the fee increase notification. We also may negotiate, discount, or waive any fees associated with the Transamerica® ALPHA program, at our discretion with no notice. Furthermore, TFA employees and employees of affiliates may be entitled to fee discounts by virtue of their employment. CONFLICTS OF INTEREST TFA and your Advisor will receive a portion of your total fee for our ongoing advisory, administrative, and marketing services related to the program. Two service model options are available to clients: a Standard Service Model priced at 0.65% and a Premier Service Model priced at 0.95% on assets above $10,000 and 0.65% for assets $10,000 and below (based on the combined assets in all accounts within Transamerica® ALPHA held by the client). Of the 0.65% in the Standard and Premier Service Models, TFA will receive an annualized fee of 0.40% for its investment advisory, administrative, and other services and Betterment will receive 0.25%. Of the 0.95% in the Premier Service Model, TFA will receive an annualized fee of 0.70% and Betterment will receive 0.25%. The Total Annual Advisory Fee charged may be higher than the fees charged by other investment advisor firms for similar services. For instance, Betterment, LLC offers direct-to-consumer services similar to Transamerica® ALPHA. Clients would pay a lower advisory fee for algorithm- driven, automated (“Digital Advisor”) investment advisory services by going direct to Betterment, LLC, or other similar Digital Advisors. TFA reserves the right to waive or lower the fee in certain cases. TFA sponsors and manages various other investment advisory programs, which provide clients with a mix of investment advisory and related services that may cost clients more than participating in the Transamerica® ALPHA program.