Mutual of America Capital Management LLC (“Capital Management,” “we,” “us,” “our”) was founded in 1993. We are wholly-owned by Mutual of America Holding Company LLC and are an indirect wholly- owned subsidiary of Mutual of America Life Insurance Company (“Mutual of America”). We provide investment advisory services to registered investment companies (mutual funds); to institutional investors (including pension and profit sharing plans, state and local government retirement plans, endowments and foundations, charitable organizations, and other institutional investors); and to our ultimate parent, Mutual of America, and its family of companies. I. Mutual of America and MoA Funds Mutual of America is a life insurance company that is also a registered investment adviser under the Investment Advisers Act of 1940. Capital Management provides investment advisory services to Mutual of America and its general account pursuant to various group annuity contracts at negotiated rates. Capital Management also advises the MoA Funds Corporation (“MoA Funds”), a registered investment company, composed of 28 series of funds, which are made available to the variable insurance products offered through the Separate Accounts of Mutual of America, to retirement plans through financial intermediaries, and to institutions, such as endowments, foundations, corporations, not-for-profit corporations, tribal organizations, municipalities and other public entities, and trusts. The MoA Funds are distributed by Foreside Fund Services, LLC, a registered broker- dealer. The MoA Funds include the following the Equity Index Fund, All America Fund, Small Cap Value Fund, Small Cap Growth Fund, Small Cap Equity Index Fund, Mid Cap Value Fund, Mid Cap Equity Index Fund, Catholic Values Index Fund, Balanced Fund, International Fund, Money Market Fund, Intermediate Bond Fund, Core Bond Fund, three Allocation Funds (Conservative Allocation, Moderate Allocation and Aggressive Allocation) and twelve Target Date Funds (MoA Retirement Income, MoA Clear Passage 2015, MoA Clear Passage 2020, MoA Clear Passage 2025, MoA Clear Passage 2030, MoA Clear Passage 2035, MoA Clear Passage 2040, MoA Clear Passage 2045, MoA Clear Passage 2050, MoA Clear Passage 2055, MoA Clear Passage 2060 and MoA Clear Passage 2065). Capital Management manages the MoA Funds in accordance with their written investment objectives, strategies

and guidelines, as disclosed in their SEC registration statements. The investment program of a MoA Fund cannot be tailored to the individual needs of any particular investor. Investment in a MoA Fund does not create an advisory client relationship between the investor and Capital Management. Therefore, investors should consult their financial representatives and consider whether a MoA Fund meets their investment objectives and risk tolerance prior to investing. II. Institutional Clients Capital Management provides investment advisory services to institutional clients, including pension and profit sharing plans, state and local government retirement plans, endowments and foundations, charitable organizations, and other institutional investors (“Institutional Clients”). A. Separately Managed Account Clients Capital Management offers Institutional Clients active and passive investment management across a broad range of asset classes, including equity, fixed income, and multi asset class strategies. Generally, we require at the initiation of the advisory agreement a minimum portfolio of $10 million for fixed income portfolios and a minimum portfolio of $5 million for equity portfolios, although these minimums may be waived at our discretion. B. Asset Allocation Clients Capital Management also provides asset allocation services to Institutional Clients. Asset allocation services are limited to investments within the MoA Funds. Pursuant to the client’s written authorization and investment guidelines, Capital Management will, at its discretion, allocate assets among the funds offered by MoA Funds. The asset allocations are limited to allocations among MoA Funds. We tailor our advisory services to our clients consistent with our investment approach and management capabilities. This includes managing client assets based on the individual needs of the client, including any client imposed restrictions on investing in particular securities or types of securities. As of December 31, 2023, we managed approximately $26,920,800,000 in assets on a discretionary basis. As of this same date, we did not manage any assets on a non-discretionary basis. This amount for assets managed on a discretionary basis includes the assets in the Target Date Funds and the Asset Allocation Funds, which invest in other MoA Funds for which we also serve as investment adviser.