EPS is an investment management firm, registered as an investment adviser with the SEC since 1993, that provides investment management and investment advisory services through independent investment advisor firms (“Advisors”) for use with Advisors’ clients (each a “Client”). EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and provides advisory and research services directly to Advisors. As of December 31, 2023, EPS had $ 40.5 billion in assets under management. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE: ENV), a publicly held company. EPS provides Advisors with an extensive range of investment sub-advisory services for use by Advisors with their Clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Account (“UMA”), PMC Multi Manager Account (“PMC MMA”), and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs certain, investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies that we also make available in the SMA, UMA, MMA, and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (defined below), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). In general EPS offers its services to a Client’s independent Advisor as sub-advisory services to be performed on Client’s account at the direction of Advisor, and in certain limited instances, EPS works directly with the Client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers Advisors many advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. A Client’s Advisor determines which services and Programs of EPS to utilize with its Clients and may utilize the services of other third-party services providers in conjunction with the Programs; Clients should therefore consult their Advisor’s Form ADV Part 2 for a fuller description of that Advisor’s specific use of EPS, EAM and the Programs. The selection of services offered by EPS include:
• Assessment assistance of the Client’s investment needs and objectives
• Investment policy planning assistance
• Assistance in development of an asset allocation strategy designed to meet the Client’s objectives
• Recommendations on appropriate style allocations
• Identification of appropriate managers and investment vehicles appropriate for the Client’s goals
• Evaluation of asset managers and investment vehicles meeting style and allocation criteria
• Engagement of selected asset managers and investment vehicles on behalf of the Client
• Ongoing monitoring of individual asset manager’s performance and management for “Approved” investment strategies (see also Item 8 - PMC Research Statuses)
• Automated tools that assist in the review of Client accounts to ensure adherence to policy guidelines and asset allocation
• Recommendations for account rebalancing, if necessary
• Online reporting of Client account’s performance and progress
• Fully integrated back office support systems to Advisors, including interfacing with Client’s custodian, trade order placement, and confirmation and statement generation.
• Access to third party platforms and strategies through the EPS Platform. The Programs For all Programs, Client and Advisor compile pertinent financial and demographic information to develop an investment program that will meet the Client’s goals and objectives. Utilizing the EPS Platform tools, Advisor will allocate the Client’s assets among the different options in the Program and determine the appropriateness of the asset allocation and investment options for each Client, based on the Client’s needs and objectives, investment time horizon, risk tolerance and any other pertinent factors. EPS uses a number of proprietary analytical tools and commercially available optimization software applications in developing its asset allocation strategies. Among the factors considered in designing these strategies are historical rates of risk and return for various asset classes, correlation across asset classes and risk premiums. For all Programs, the Client directly owns the securities (e.g., stocks, bonds, mutual funds or exchange traded funds (“ETFs”) purchased within each of the Program’s investment strategies. Mutual funds, ETFs, closed-end funds, unit investment trusts and real estate investment trusts and ETFs are collectively referred to throughout this document generally as a “Fund” or “Funds." For Clients participating in the SMA program, the Client’s Advisor is recommending an actively managed or index-ed investment portfolio managed by a roster of independent asset managers (each a “Sub-Manager”) with a variety of disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the Client’s investing preferences. EPS will assist Advisor in identifying individual asset managers and investment vehicles that correspond to the proposed asset classes and styles or Advisor may independently identify asset managers. EPS retains the Sub-Managers for portfolio management services in connection with the SMA program through separate agreements entered into between EPS and the Sub-Manager on terms and conditions that deems appropriate. For many Sub-Managers, EPS has entered into a licensing agreement with the Sub-Manager, whereby the asset manager, acting as a “Model Provider,” constructs an asset allocation and selects the underlying investments for each portfolio on a non-discretionary basis. EPS implements the investment selections, performs overlay management and trade order placement duties pursuant to the investment directions of the Model Provider’s investment strategy (each a “Third Party Model”). In implementing the investment selections of a Model Provider for a Third-Party Model, Envestnet is adhering to the investment strategy selected for Client as instructed by Advisor and is not independently selecting the underlying investments nor exercising discretion as a “fiduciary” within the meaning of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). Clients may also select individual Funds through the SMA program. Client’s Advisor may also recommend asset allocation strategies of a variety of mutual fund and ETF asset managers in the Third-Party Fund Strategists program. Each portfolio may consist solely of mutual funds or ETFs or may combine both types of funds to pursue different investment strategies and asset class exposures. Pursuant to a licensing agreement entered into with the Model Provider, EPS provides overlay management of the portfolios, and performs administrative and trade order placement duties pursuant to the direction of the Model Provider. For Clients participating in the UMA program, the Client’s Advisor is recommending a single portfolio that accesses multiple asset managers and Funds, representing various asset classes, that is customized by the Client’s Advisor. Utilizing the EPS tools, Advisor customizes the asset allocation models for a particular Client or selects EPS’s proposed asset allocations for types of investors fitting Client’s profile and investment goals. The Advisor then further customizes the portfolio by selecting the specific, underlying investment strategies or Funds in the portfolio to meet the Client’s needs. Once the Advisor has established the content of the portfolio, EPS provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. Within the UMA program, the Client’s Advisor may also offer MMA portfolios created and managed by third party asset managers that access multiple asset managers and Funds representing various asset classes. Within the UMA program, the Client’s Advisor may also select a UMA portfolio Sub-Manager which customizes and manages the single portfolio by selecting the specific, underlying investment strategies or Funds in the portfolio (see Strategist UMA below). Client’s Advisor may also offer a version of the UMA, whereby Advisor does not exercise investment discretion in the selection of the asset allocation or the specific, underlying investment vehicles and investment strategies used in each sleeve of the UMA portfolio (“Client-Directed UMA”). In the Client Directed UMA, the Advisor will provide Client with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet the Client’s objectives, but the Client is directing the investments and changes made to Client’s UMA portfolio and is ultimately responsible for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described above, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. For Clients participating in the PMC Multi Manager Account program (“PMC MMA”), the Client’s Advisor is recommending MMA portfolios created and managed by EPS that access multiple asset managers and Funds representing various asset classes. EPS allocates the portfolios across investment asset classes, with the use of complementary asset managers to create a blend that fits the target investment profile and risk tolerance. EPS includes Funds in PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third party Model Providers, EPS has an economic incentive to choose Funds rather than third party Model Providers’ strategies within the PMC MMA. For Clients participating in the Strategist UMA program (“Strategist UMA”), the Client’s Advisor is recommending portfolios created and managed by third party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, with the use of complementary asset managers to create a blend that fits the target investment profile and risk tolerance. For clients using the Manager Outsourced Consulting Services (“Manager OC Services”) the Client’s Advisor is recommending custom MMA portfolios created and managed by third party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion of investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. EPS maintains a policy of strongly encouraging Sub-Managers and Model Providers to keep a minimum of 2% cash in the portfolios as a buffer to compensate for market fluctuation and supplement proceeds from Sell orders needed to cover Buy orders. The foregoing also applies to EPS’s proprietary strategies as well. Customized PMC Services EPS provides Advisors PMC Custom Case Design Service whereby EPS assists the Advisor in creating a custom portfolio designed generally for households with a minimum of $250K of investable assets where the Advisor has full discretion of investments within a UMA or a series of SMAs. The Advisor utilizes the PMC Custom Case Design Service to provide Client a customized portfolio design recommendation that accesses multiple asset managers and funds, representing various asset classes, which fits the Client’s investment profile and risk tolerance, as determined by the Advisor . EPS provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. EPS provides Advisors the “PMC White Label UMA Service” whereby PMC assists the Advisor in selecting from a series of UMA models designed for account size entry points at 250K, 500K and greater than 1M where the Advisor has full discretion of investments within a UMA. The Client is offered a portfolio design recommendation that accesses over 7 investment styles, multiple asset managers and funds, representing various asset classes, which fits the Client’s investment profile and risk tolerance, as determined by the financial representative. EPS provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. This service is closed to new investors. In Envestnet’s Private Wealth Consulting Services (“PWC Service”) the Client’s Advisor is recommending a custom MMA portfolio created and managed by EPS that access multiple asset managers and Funds representing various asset classes. EPS allocates the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor maintains full discretion of investments. EPS includes Funds in the PWC Service to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third party Mod. Providers, EPS has an economic incentive to choose Funds rather than third party Model Providers’ strategist within the MMA. For portions of the PMC MMAs, PMC Custom Case Design Service, and some of the PMC MMAs created within the PWC Service, PMC may also utilize proprietary strategies or a PMC Fund. Because PMC is also managing the portion of assets utilizing a PMC proprietary strategy, PMC has an economic incentive to recommend its proprietary strategies. Further, a portion of these assets may be invested in the PMC Funds or ActivePassive™ ETFs where appropriate, in conjunction with using multiple asset managers and other Funds that comprise these portfolios. Since EPS’ affiliate EAM serves as the investment advisor to the PMC Funds and ActivePassive™ ETFs, and receives fees for the PMC Funds, ActivePassive™ ETFs and fees as the portfolio manager, EPS waives the portfolio management fee that EPS normally charges for managing the portfolio on assets invested in PMC Funds or ActivePassive™ ETFs. EPS will still recognize ancillary benefits in investing assets in PMC Funds or ActivePassive™ ETFs. ActivePassive Portfolios In the ActivePassive Portfolios, EPS acts as a sub-advisor and provides discretionary investment advisory services under which EPS selects investments for Clients consisting of a series of third party index mutual funds or ETFs, as well as one or more actively managed funds from the PMC Fund family or the ActivePassive™ ETFs. EPS periodically monitors Client portfolios and when deemed appropriate makes changes in both asset allocations as well as specific mutual fund selections. EPS does not act as a qualified custodian for the Funds or other assets owned by each Client. The PMC Funds are a proprietary fund family of EAM and as the investment advisor to the PMC Funds, EAM receives a management fee based on assets invested in the PMC Funds. If PMC Funds are used within the portfolios, EPS does not separately charge a fee for its management of assets invested in the PMC Funds through the ActivePassive Portfolios but may charge a portfolio management fee for assets invested in third-party Funds. The ActivePassive™ ETFs are a proprietary ETFs of Envestnet and as the investment advisor to the ActivePassive™ ETFs, Envestnet receives a management fee based on assets invested in the ActivePassive™ ETFs. If ActivePassive™ ETFs are used within the portfolios, EPS does not separately charge a fee for its management of assets invested in the ActivePassive™ ETFs through the ActivePassive Portfolios but may charge a portfolio management fee for assets invested in third-party Funds. PMC Strategies and Portfolios For Clients selecting a mutual fund or ETF asset allocation strategy, EPS manages mutual fund asset allocations based on EPS’s recommended investment strategy (each a “PMC Strategy”). The PMC Strategies are fully discretionary, mutual fund and/or ETF asset allocation programs offering a series of model portfolios positioned at various points along the risk/return spectrum that

correspond to the individual Client’s goals and objectives. Once the Client’s assets are invested, EPS may add, remove or replace mutual funds at its discretion. Certain Advisors may re-brand a PMC Strategy and label the investment strategy according to that Advisor’s design, as further described in the Advisor’s Form ADV Part 2A. In the PMC Select Portfolios, EPS utilizes EAM’s proprietary mutual fund family, the PMC Funds or the ActivePassiveTM ETFs, for the investments based on the Client’s corresponding investment objectives and risk profile. Where appropriate, EPS may also utilize non-proprietary mutual funds in the PMC Select Portfolios. EPS is responsible for developing, constructing and monitoring the asset allocation and strategy for each portfolio. EAM, an affiliate, serves as the investment advisor of both the PMC Funds and the ActivePassive™ ETFs. Envestnet does not separately charge a fee for its portfolio management of assets invested in the PMC Funds or the ActivePassive™ ETFs through the PMC Select Portfolios, but may charge a portfolio management fee for assets invested in a third-party Fund. EPS will still recognize ancillary benefits in investing assets in PMC Funds. The PMC Select Dynamic Portfolios are centered on the strategic allocations of the PMC Funds or the ActivePassiveTM ETFs used by the PMC Select Portfolios, as described above, but also allow for underweighting or overweighting between the PMC Funds or the ActivePassiveTM ETFs for each portfolio. The PMC Paradigm Portfolios are a series of FSPs that, depending on the assets in the account, may include mutual funds and ETFs. EPS chooses the different asset allocations, investment strategies and Funds for each of the Paradigm Models. The models managed for the smaller asset accounts may only consist of liquid alternative mutual funds and ETFs. Third Party Models and Model Providers Many of the asset managers in the SMA Program and the Third-Party Fund Strategist Program described above are accessed through the use of Third Party Models, whereby the asset manager, acting as a “Model Provider”, constructs an asset allocation and selects the underlying investments for each portfolio on a non-discretionary basis. EPS performs overlay management of the Third-Party Models by placing trade orders, periodically updating, and rebalancing each Third-Party Model pursuant to the direction of the Model Provider. Investment selections are determined by the Model Provider. In implementing the investment selections of a Model Provider for a Third-Party Model, Envestnet is adhering to the investment strategy selected for Client as instructed by Advisor and is not independently selecting the underlying investments nor exercising discretion as a “fiduciary” within the meaning of ERISA. EPS may, from time to time, replace existing Model Providers or hire others to create Third Party Models and cannot guarantee the continued availability of Third-Party Models created by particular Model Providers. In managing the Third Party Models, certain Model Providers may pursue an investment strategy that utilizes underlying mutual funds or exchange traded funds advised by the Model Provider or its affiliate(s) (“Proprietary Funds”). In such situations, the Model Provider or its affiliate(s) may receive fees from the Proprietary Funds for serving as investment advisor or other service provider to the Proprietary Fund (as detailed in the Proprietary Fund’s prospectus). Please refer to each Model Providers Form ADV for information regarding this conflict. These fees will be in addition to the management fees that a Model Provider receives for its ongoing management of the Third Party Models and creates a financial incentive for the Model Provider to utilize Proprietary Funds. In selecting a Third-Party Model containing Proprietary Funds for a Client, an Advisor must independently determine that the use of the Proprietary Funds in the Third-Party Model is in the best interest of the Client. Clients should discuss any questions with or request further information from their Advisor concerning the use of Proprietary Funds in Third Party Models or the conflict of interest this creates. Tax and Values Overlay Services EPS also provides Tax and Values Overlay Services. Tax Overlay Services seeks to consider tax implications that may detract from the Client’s after-tax returns. Values Overlay Services seek to reflect a Client’s own personal values by excluding investments linked to companies that derive revenues from specific business areas or companies that are involved in controversial business activities (e.g., negative environmental impacts, human rights violations, corruption). If selected by the Client, EPS will provide Tax Overlay Services, Values t Overlay Services, or both, to an account or sleeve. The end goal of Tax Overlay Services is to improve the after-tax return for the Client while staying as consistent as possible with the risk/return characteristics provided by the model portfolios. Tax Overlay Services are available only to U.S. clients, though EPS may provide similar services for non-U.S. clients upon agreement with a program’s sponsor. EPS does not provide tax planning advice or services. Clients should discuss any questions with or request further information from their Advisor or tax consultant in using the Tax Overlay Services. The end goal of Values Overlay Services is to align a portfolio with the personal values of the Client, while staying as consistent as possible with the risk/return characteristics provided by the Third-Party Models. The Advisor establishes account fees for the programs offered to clients and in some cases may negotiate these fees with certain of Advisor’s Clients. EPS Tax and Values Overlay Services may be available at a lower overall cost in some of Advisor’s programs as compared to its other programs. In addition, lower fees for comparable services may be available from other sources. In providing Values Overlay Services, EPS is dependent upon information provided by third-party data providers. EPS does not independently verify or guarantee the accuracy, timeliness, or comprehensiveness of such information. The assessments and screens made by third parties are based on data that relates to a company’s involvement in a particular product or ESG-related topic, and such data may not cover all of a company’s services and practices. The overlay restrictions will only be applied in cases where the information is available, which is limited to a specific universe of securities covered by the third-party data research providers. Client may impose additional reasonable restrictions on the management of Client’s accounts, including the ability to restrict accounts from purchasing or holding certain securities that client believes are not aligned with client’s selected impact category restrictions, or securities that were not considered and screened out through the data provider overlay process that were not considered in the data provider screening process. In the event Client identifies additional securities in a portfolio that Client desires to be screened but were not identified by the third-party data research providers, Client’s remedy shall be limited to adding such securities to Client’s investment restrictions on a go-forward basis, and an instruction to Client’s Advisor to sell or otherwise dispose of such securities. Reasonable restrictions on the management of an account include, but shall not be limited to, the designation of particular securities that should not be purchased for the account, or that should be sold if held in the account. At the discretion of EPS, Values Overlay category criteria may change. Envestnet will periodically review the criteria and consider whether or not revisions may be appropriate. Envestnet is not affiliated with third-party data providers. In providing Values Overlay services, EPS will allow client’s account to deviate from client’s selected investment strategy, based on the additional reasonable restriction instructions provided by the Client. With the Values Overlay Services, Client’s account(s) may not own all holdings that are part of their selected investment model, and as a consequence, Client’s account may experience significant performance differences from the selected investment strategy. If Client chooses an overlay, Envestnet makes no guarantee that the account’s performance will be within any range of the selected investment strategy or the strategy’s benchmark. EPS may manage Client’s account using tools and processes which may result in client’s trades being executed at a different time or in a different manner than other Envestnet trades, including the potential to not participate in Envestnet’s standard trade rotation processes (if such trades would have been otherwise eligible to participate). Model Trading - Overlay Services When a Client utilizes a Third-Party Model within a UMA portfolio or utilizes a Tax and/or Values Overlay Service (such as tax-management or socially responsible investing) on the Third- Party Model, trading within such Third- Party Model may differ from Models that are not within a UMA and do not include an overly screen. Block orders for tax-managed accounts are processed separately from non-tax managed accounts. Therefore, tax-managed accounts utilizing a Third Party Model will effect securities transactions required to conform to a Model update as soon as practicable after receipt of the update instruction; in accordance with any Client- specific mandates such as tax overlay screens. Same-day or multi-day trade timing differences can occur between the submission of the Third Party Model update and the execution of securities transactions for tax- managed accounts resulting in execution price differences from non-tax managed accounts. Same-day trade timing differences are due to trade evaluation and order processing timing differences (i.e., dependent on timing of Third Party Model update submissions and tax overlay trade engine analysis completion). Multi-day trade timing differences are due to the evaluation and recommendation of the tax overlay trade engine to align with Client’s specific tax goals (i.e., whether to execute the trade the day of the model update vs. waiting until a future date based on Clients’ stated tax goals). Due to the referenced trade timing differences, Client’s may receive different prices than other Client’s in the same model. Given that each Clients’ tax situation can vary from one person to another, Client should discuss any questions with or request further information from their Advisor or tax consultant in using the Tax Overlay Services. Refer to Item 8 (Tax-Managed Investing Risks) for additional information regarding the risks associated with tax-managed accounts. PMC Strategies Availability on Non-Affiliated Platforms Certain PMC strategies may be offered through non-affiliated institutional platforms. In doing so, EPS contracts with the non-affiliated firm as a portfolio manager. For such portfolio management services, EPS obtains a manager fee, which is negotiated separately with each respective firm. Mutual Funds EPS’ affiliate, EAM, serves as the investment advisor to a mutual fund family: The PMC Funds, consisting of the PMC Core Fixed Income Fund and the PMC Diversified Equity Fund. Additional information available at www.investpmc.com/solutions/portfolios. ETFs Envestnet also serves as the investment adviser to the following newly launched proprietary ETFs: ActivePassive™ Core Bond ETF, ActivePassive™ Intermediate Municipal Bond ETF, ActivePassive™ International Equity ETF, and ActivePassive™ U.S. Equity ETF (collectively, the “ActivePassive™ ETFs”). Additional information available at www.activepassive.com. Account Customization and Investment Restrictions The discretionary Programs identified above are intended to comply with Rule 3a-4 under the Investment Company Act of 1940. Advisors instruct EPS on the management of each account based on the Client’s financial situation and stated investment objectives, in accordance with the Client’s reasonable investment restrictions imposed by Client on the management of the assets in the account. In addition, Clients will be contacted at least annually by their Advisor, and notified quarterly to contact Advisor, in order to confirm whether there have been any changes to the Client’s financial situation, investment objectives or if Client would like to impose or modify investment restrictions on the account. Customized Strategies and Direct Indexing Portfolios Certain Sub-Managers offer highly customized strategies and direct indexing portfolios. The customized strategies typically require additional input from the Adviser or Client. This input may include account level security or sector-based restrictions or tilts, or customizations based on a client’s specific tax, ESG or sustainable preferences. It may also include modifications to asset allocations in a multi-asset solution or include tilts away from or toward certain investment styles as part of the client account construction. While these portfolios are available within the SMA Program, Clients and Advisors should review and monitor these custom portfolios to ensure they are consistent with Client’s risk profile and investment objectives, as Sub- Managers build and trade these customized client models away from the EPS Platform and EPS does not have visibility into the holdings and performance of custom portfolios. EPS may perform periodic due diligence reviews of certain Sub-Managers who maintain custom portfolios; however, use of such portfolios are at the recommendation of Client’s Advisor and EPS does not undertake supervisory responsibility for the custom portfolios or Sub-Manager’s compliance practices. Customized Asset Allocation Program Firms may engage with EPS to create a customized asset allocation program (“Enterprise Program”) that is available to only their advisors. EPS will manage asset allocations based on the firm’s direction for investment strategy and available investment universe. The Enterprise Programs are fully discretionary asset allocation programs that access multiple third party Model Providers, mutual funds and/or ETFs offering a series of model portfolios positioned at various points along the risk/return spectrum. Once the Client’s assets are invested, Envestnet may add, remove or replace third party Model Providers, mutual funds and/or ETF at its discretion. Because Envestnet does not have to share management fees with Fund families but does share management fees with third party Model Providers, Envestnet has an economic incentive to choose Funds rather than third party Model Providers’ strategist within the Enterprise programs utilizing the Multi Manager Account (MMA) framework. Wrap Fee Programs Advisors may offer the Programs as “wrap fee programs” to Clients as described in Advisor’s Appendix 1 of its Form ADV Part 2A. EPS also offers the Programs as “wrap fee programs” and provides portfolio management services. EPS manages the wrap fee programs in the same manner as described in this document and receives fees for its portfolio management services as described in Appendix 1 of its Form ADV Part 2A. EPS may provide asset management services as a non-discretionary sub-adviser for unaffiliated RIA program sponsors. Under these arrangements, EPS provides model portfolio recommendations to third party platforms. Ultimately, the discretionary responsibility for the asset allocation and securities selection remains with the unaffiliated RIA program sponsors. The unaffiliated RIA program sponsors maintain responsibility for executing all security transactions in connection with such determinations, which means the portfolios may materially diverge from the model portfolio communicated by EPS. EPS receives a fee from the RIA sponsors for the services provided in these programs. Institutional Clients EPS also provides customized services to certain institutional clients, such as banks, charities/foundations organized under Section 501(c)(3) of the US Internal Revenue Code and employment retirement plans. These services generally consist of investment policy statement development and documentation, investment due diligence, and plan advice and management services under ERISA. As also described below, EPS may make its technology platform available to Advisors, banks, or trusts for them to manage their own advisory services for Clients. In such cases, EPS may be providing account billing, reconciliation and reporting and other administrative and technology services, but is not acting in an advisory role to any Client.