Our Firm Transamerica Retirement Advisors, LLC (“TRA”) is a registered investment advisory firm that, with its predecessors, has been in business since 1992. TRA is part of the AEGON family of companies, a global leader in pensions. TRA is a wholly-owned subsidiary of Transamerica Retirement Solutions, LLC (“TRS”), a firm dedicated to providing services to retirement plans and their participants and is also an indirect wholly-owned subsidiary of Aegon Ltd., a publicly traded company (“AEGON”). As of December 31, 2023, TRA manages approximately $4.8949 billion of client assets on a discretionary basis and approximately $7.831 billion of client assets on a non-discretionary basis. Not all these assets are associated with the Defined Benefit (“DB”) service. These figures are computed in the same fashion as in our Form ADV, Part 1A. Please refer to TRA’s other Form ADV brochures for discussions of the other investment advisory services offered by TRA. Our Advisory Services Defined Benefit Plan Investment Advisory Services. TRA provides investment advice to plan sponsors with respect to asset allocation and fund selection and monitoring for defined benefit pension plans and other employer or trustee directed retirement plans including where the plan sponsor retains discretion over the selection of the investment options. TRA offers discretionary asset management services under which TRA determines the allocation of a client’s pension plan assets, within client defined asset allocation targets and ranges, among affiliated and unaffiliated collective investment trust (“CIT”) fund and mutual fund options (collectively, “funds”) based on the fund lineup that is determined by the client. TRA also offers a variation of this service that is nondiscretionary, in which TRA makes asset allocation recommendations that are presented to the client for approval prior to implementation. In formulating an asset allocation strategy, TRA takes into consideration the financial characteristics of each client’s plan, including the level of future plan liabilities and/or plan cash flow

needs. TRA works with each client to develop an Investment Policy Statement, if the client chooses to create one. TRA works with all clients to develop Investment Guidelines for the plan. TRA manages a client’s plan in accordance with the Investment Policy Statement, as applicable, and established Investment Guidelines. A client may impose reasonable restrictions on the management of the plan account within these Investment Guidelines. TRA’s general non-discretionary investment advisory services in relation to fund selection and monitoring are designed to assist clients in their decision on the specific investment funds to use by providing recommendations on the funds available for use on the TRS investment platform. Another advisory service offered to employer plan sponsors for defined benefit pension plans is the DB Complete Investment Advisory Solution (the “Solution”). The Solution combines TRA’s expertise using funds, TRS non-advisory support services including DB Risk Management services as well as optional DB plan administration and actuarial consulting services and the fixed income expertise of our affiliate, AEGON USA Investment Management, LLC (“AUIM”), for a bundled solution to meet plan sponsors’ goals and objectives. TRA and AUIM work together to offer investment advice. Under the Solution, TRA collaborates with TRS and AUIM (Fixed Income) to create a Dynamic Asset Allocation (“DAA”) strategy appropriate for each client’s unique objectives which will be discussed with and approved by the client prior to its implementation. With respect to the Solution, TRA offers either (i) discretionary investment advisory services in which the client delegates discretion to TRA to select, monitor and replace investment funds on their behalf, or (ii) non-discretionary investment advisory services in which TRA provides recommendations to the client on specific investment funds, but the client maintains the responsibility for the selection of the funds. Fund selection services are limited to funds available for use on the TRS investment platform.