A. Description of Firm Asset Consulting Group, LLC, a Delaware limited liability company, is a wholly-owned subsidiary of GWM Holdco, LLC. GWM Holdco, LLC is controlled by its managing member, Guggenheim Manager, Inc. Guggenheim Manager, Inc. is a wholly-owned subsidiary of Guggenheim Capital, LLC. GWM Holdco, LLC is a majority-owned subsidiary of Guggenheim Partners, LLC. Guggenheim Partners, LLC is a wholly-owned subsidiary of Guggenheim Capital, LLC. Guggenheim Capital is owned in part by Sage Assets, Inc. Sage Assets, Inc. is a wholly-owned subsidiary of Sammons Equity Alliance, Inc. Sammons Equity Alliance, Inc. is a wholly-owned subsidiary of Consolidated Investment Services, Inc. Consolidated Investment Services, Inc. is a wholly-owned subsidiary of Sammons Enterprises, Inc. Sammons Enterprises, Inc. is owned by Sammons Enterprises, Inc. Employee Stock Ownership Trust, in which Greatbanc Trust Company is its Trustee. ACG provides general consulting services to taxable and tax-exempt investors such as trusts, endowments, foundations and other non-profit corporations, insurance company reserves, and corporate, public, Taft-Hartley employee benefit plans and high net worth individuals and family offices. In addition, ACG also provides outsourced research services to 3rd Party intermediaries and other advisers. ACG has provided investment consulting and investment research services since 1989. B. Description of Services General Consulting Services
• Creation/Review of Investment Policies and Objectives: Assisting the client in defining appropriate investment objectives and investment policies by which to achieve those objectives based upon that client’s unique situation.
• Asset Allocation and Review: Assisting the client in allocating its assets in a strategic manner among different investment vehicles, such as common stocks, debt instruments, foreign securities, temporary cash and alternative investments, so as to achieve the stated investment objectives.
• Investment Manager Due Diligence and Monitoring: Assisting the client in evaluating and monitoring investment managers appropriate to make specific security level investments for the client’s portfolio in accordance with the objectives of the client.
• Performance Measurement and Evaluation: Providing the client with customized quarterly written performance reports, which measure, compare and evaluate the investment managers selected by the client. We can also prepare other customized written reports based on client needs. All reports are part of fee-based rather than subscription-based services and are specifically

designed for that client’s reporting needs.
• Efficiency Reports: Assisting the client with regular review of investment manager and custodian fees and providing guidance for a systematic funding of investment managers from cash inflows.
• Best Practices Reviews: From time to time we are engaged to perform an assessment of a client’s processes, systems and resources for the purpose of providing perspective with regard to potential improvements.
• Financial Modeling: We have developed a proprietary tool for analyzing the effect of various asset allocation strategies. While we do not provide forecasting services, we can use this tool with client provided data to assist in developing various financial analyses. This tool is utilized when clients request that the structure of their related investment portfolio be stress-tested along with an integration of the client provided underlying forecasted business results. C. Customization ACG tailors its advisory services to the individual needs of each client. ACG provides advice on asset allocation, portfolio structuring and manager or fund selection that is customized for each client based on each client’s unique tolerance for risk, legal or regulatory requirements, nature of liabilities and other unique circumstances of each client. ACG acts primarily as an Investment Consultant rather than as a conventional investment advisor or “money manager.” As an Investment Consultant, ACG generally does not have discretion over client assets, however ACG does have 13 client relationships as of 12/31/2023 with clients who have granted ACG authority to select, retain, and terminate investment managers and/or pooled investment vehicles and to allocate assets among them subject to written guidelines provided by the client. These 13 discretionary relationships represented $613.8 million in client assets as of 12/31/2023. In addition ACG has 8 clients that have granted ACG authority to arrange and effect the purchase or sale of mutual funds at Client’s custodian upon Client’s direction. As of 12/31/2023 ACG had 132 client relationships where we served exclusively as a traditional Investment Consultant. In these relationships ACG provides its Client with alternatives and various courses of action; however, all decisions regarding the investment of Client’s assets, including the establishment of an investment policy and the selection and retention of investment managers and the arranging and effecting of the purchase or sale of investments remain with Client. As of 12/31/2023 these 132 traditional consulting relationships include clients whose assets were valued at approximately $176.3 Billion.