Stadion Money Management, LLC (“Stadion”) is a privately owned money management firm based in Watkinsville, Georgia. Stadion has been in business since 1993. On December 20, 2021, Stadion entered into an agreement with Smart USA Co. (“Smart”) that provides for the merger of Stadion with Smart (the “Transaction”). The Transaction closed on March 9, 2022. The Transaction will not result in any change in the advisory fees paid by any of Stadion’s clients or the investment objective or the principal investment strategies which Stadion employs on behalf of its clients, and Stadion’s portfolio management team will remain the same immediately following the Transaction. Stadion offers portfolio management for businesses and their employees and institutional clients. These services are offered through Stadion’s Institutional Account Management Program and Retirement Account Management Program. A description of each of these Programs is set forth below. Institutional Account Management Program. Through its Institutional Account Management Program, Stadion provides advisory and sub-advisory services to separate accounts of insurance companies (“Insurance Separate Accounts”) and Collective Investment Funds (“CIFs”). In cases where Stadion serves as adviser or sub-adviser to an Insurance Separate Account or CIF, Stadion generally expects to use the portfolios within its managed account service available as an option under the Recordkeeper’s 401(k) platform as described above in Retirement Account Management Program section.  TargetFit. Stadion’s TargetFit product is a group of three CIF target date fund series – the Stadion TargetFit Conservative Strategies, the Stadion TargetFit Moderate Strategies, and the Stadion TargetFit Growth Strategies. TargetFit was designed to offer multiple target date fund options based on a particular risk objective. Each TargetFit target date fund is a CIF. As such, TargetFit is only available to certain 401(k) and similar retirement plans through open-architecture platforms. Retirement Account Management Program. Through its Retirement Account Management Program, Stadion offers discretionary money management services to participants in certain 401(k) and similar retirement plans. Stadion offers its Retirement Account Management Program in the following ways:  QDIA, Participant Choice and related arrangements with various 401(k) recordkeeping and administration firms (“Recordkeepers”). Recordkeepers enter into an arrangement with Stadion to make Stadion’s money management services available to retirement plans and participants, subject to the agreement and direction of the plan sponsor or fiduciary. In these cases, Stadion enters into an agreement with the plan’s sponsor or fiduciary directing Stadion to manage participants’ personal 401(k) or similar accounts. Stadion’s services are offered as either a default option, typically as a Qualified Default Investment Alternative (“QDIA”) or a participant choice option (“Participant Choice”) within retirement plans. For QDIA, Stadion is appointed by plan sponsors to manage the accounts of participants who have not made any affirmative investment decisions for their account. Stadion offers two QDIA structures: target date portfolios and managed accounts. For Participant Choice, participants elect to directly engage Stadion to manage their retirement plan account by entering into a Stadion advisory agreement.  StoryLine. Stadion’s StoryLine product line (“StoryLine”) is a managed account service that provides retirement plan sponsors and their plan participants with QDIA and related investment services that have customizable glide paths. Stadion offers Storyline as a QDIA and Participant Choice option through arrangements with Recordkeepers, employers and plan sponsors. The responsible party engaging Stadion to provide StoryLine to plan participants is required to select for the plan the lineup of available investment options that Stadion will use to implement StoryLine’s customizable glide paths (“Investment Lineup"). While the Investment Lineup is expected to consist primarily of mutual funds and/or collective investment funds of trust companies (“CIFs”), and target date funds (“TDFs”) it may also include third party products or proprietary products sponsored by the Recordkeeper. Plan sponsors who elect to make StoryLine available to participants are directing Stadion to only use investments from the Investment Lineup to construct portfolios. Stadion also offers a version of StoryLine that consists primarily of CIFs or ISAs that invest in

exchange-traded funds (“ETFs”) that bear the SPDR® trademark (“StoryLine with SPDR ETFs”) and may also include third party products or proprietary products sponsored by the Recordkeeper (collectively the “Platform”). Plan sponsors who elect to make StoryLine with SPDR ETFs available to participants are also selecting the Platform and directing Stadion to only use investments from the Platform to construct portfolios. Only the responsible party engaging Stadion to provide StoryLine or StoryLine with SPDR ETFs (and not Stadion itself) will be permitted to change the investment options. Stadion also offers its StoryLine service as a “white label” named offering such as Target Pro Portfolios and Target Date Plus.  StoryLine Income. StoryLine Income (“SLI”) is a post-retirement extension of Stadion’s StoryLine retirement managed account service designed to assist retirement plan participants in retirement income planning and execution through education and investment management. SLI includes a user interface where retirement plan participants can educate themselves on savings goals and income needs, and income solutions. To the extent all income solutions fit within Stadion’s capabilities as a designated investment manager to the retirement plan and upon hire, Stadion will manage the retirement plan participants account using its methodology adjusted to the specific goals of the participant. If a participant wishes to utilize income solutions available outside of the retirement plan account, Stadion, to the extent it is capable, will assist in providing education and instruction on where to seek such solutions, but will not provide a specific recommendation to a particular product or product sponsor. Stadion may recommend the services of third- party investment and non-investment service providers and participants are under no obligation to engage such service providers. As such, it is the participant’s responsibility to independently determine the appropriateness of the external income solution and purchase it. If the participant shares details of the external income solution with Stadion, SLI is designed to incorporate that information into its investment management process.  Custom Advisor Managed Accounts. Stadion’s Custom Advisor Managed Account service (“CAMA”) is a managed account service that allows non-affiliated retirement plan advisers (“RPA”) to select and customize investment options, participant allocations and participant assignment through Stadion’s technology platform. RPAs may elect to provide some or all of the customization options with Stadion providing the remainder, if any. The RPA may elect to utilize Stadion’s technology platform as 1) a co-fiduciary to the plan along with Stadion; 2) a fiduciary to the plan using Stadion as a sub-adviser; or 3) a fiduciary to the plan with Stadion only offering technology support. Stadion’s Retirement Account Management Program is offered as a “wrap fee” program where Stadion acts as a non-sponsor portfolio manager to retirement plans and participants. The advisory fees paid by a client in this program cover Stadion’s investment management services, brokerage commissions and transaction fees and other related costs and expenses. Stadion provides clients in the Program a discretionary portfolio management service in which Stadion allocates client assets according to one or more of Stadion’s investment strategies. The Program is generally offered through arrangements with retirement plan recordkeeping platforms where Stadion acts as a non-sponsor portfolio manager. There is no account minimum for accounts managed through Stadion’s Retirement Account Management Program. Where Stadion acts as a non-sponsor portfolio manager through arrangements with various retirement plan recordkeeping platforms, Stadion determines its clients’ appropriate portfolio investment style (e.g., growth, moderate or conservative) based on pertinent and available information provided by clients or recordkeepers, such as: age, financial circumstances, investment objectives, risk tolerance, and other relevant data. Stadion’s clients have the ability to impose reasonable restrictions on Stadion’s management. If an investment restriction is fundamentally inconsistent Stadion’s strategy or the nature of operation of a particular portfolio, Stadion reserves the right to reject a new client account or terminate an existing account. Assets Under Management: As of 12/31/2022, Stadion managed approximately $2,046,953,608 of client assets on a discretionary basis and $0 of client assets on a non-discretionary basis.