A. Firm Description We are an independent, fee-only; investment consulting firm providing advice to institutional investors, on investments and related fiduciary issues. Founded in 1984, Yon-Drake & Associates, Inc. (“Yon-Drake”) is registered with the SEC as an Investment Adviser. The firm is registered with the State of South Carolina as an S-Corporation and headquartered in Columbia, SC. We devote 100% of our resources to providing investment consulting services and do not engage in any other outside business activities. We do not sell any investment products and devote our full interest and attention to providing consulting services to our clients. We do not receive any compensation, fees, incentives, commissions, promotional goods or services, from any source other than the fee paid by the client. B. Ownership The company is an S-Corporation owned equally by David A. Yon (50%) and Michael C. Drake (50%). We are an independent firm and have no outside ownership, or affiliation. C. Services Yon-Drake provides a menu of investment consulting services based upon the dynamic and integrated nature of an institutional investment program. We work for an annual fee based upon the market value of assets under advisement. Our services are divided into five interrelated areas, as follows: 1. Investment Program Reviews and Evaluation Investment program reviews involve the collection and review of historical financial and investment information, including: statutory requirements, financial statements, investment policies, investment holdings, market values, investment performance reports, manager contracts, prospectuses, projected liabilities, and actuarial reports. This information is organized and evaluated to provide insight into where the investment program has been, how well it has met expectations and compliance with policy, and the opportunities for improvement going forward. 2. Investment Policy Design and Development This process is oriented toward understanding the purpose of the funds, expectations for achieving success and the appropriate policies to follow to achieve success. The initial “Financial Program Analysis and Evaluation” reveals the client’s expectations for risk and returns in the portfolio and serves as input on the design of an appropriate asset policy mix. In some cases, this step simply means reviewing the current policy and suggesting revisions to the written document. In most cases, this step involves a comprehensive rewriting of the policy to incorporate a fresh approach. YON-DRAKE & ASSOCIATES, INC. 5 This process involves the development of an asset mix policy primarily oriented toward a strategic asset allocation perspective. In the case of actuarially sensitive funds such as defined benefit plans and insurance funds, this may require the use of asset/liability modeling to hedge against interest rate movements. Foundations and endowments are provided with the results of our spending model designed to provide scenario forecasts for determining the appropriate asset mix relative to spending requirements. In most instances, we write an investment policy planning document detailing various policy issues to be addressed by fiduciaries in designing and documenting written investment policy guideline statements for all investment portfolios. As part of this process, we conduct a fiduciary education seminar to discuss the written policy planning document and to provide fiduciaries with information designed to assist them with making reasonably informed investment policy decisions. Make policy recommendations on an on-going basis. 3. Manager Evaluation and Selection The investment policy document serves as the guide for the process of evaluating and selecting the managers appropriate to a portfolio. The policy document will provide the specifications for asset classes, asset mixes, styles, types of managers, manager competency requirements, performance standards, et. al. Our search process involves the design and development of a management structure to meet the client’s needs. We screen manager candidates using a professional, credible universe of qualified investment managers containing quantitative and qualitative data with regard to the organization, personnel, investment philosophy, process and historical performance.

Yon-Drake makes use of several sources of information on managers including commercial databases to assist with manager data collection, compliance, screening, evaluation and reporting. In some cases, we employ questionnaires, RFP packages, and other communication materials necessary to execute a successful manager search and evaluation process for fiduciaries. This approach involves the screening of candidates, the transmission of bid packages, handling inquiries, collecting, assimilating and analyzing the bid packages. From this process, we recommend a list of qualified candidates to be interviewed and/or recommended. After a manager is hired, we assist the client with contract negotiations to ensure favorable commercial, operational and service agreements with all managers. 4. Performance Measurement, Evaluation, Reporting Yon-Drake conducts performance measurement and evaluations on an ongoing basis. We conduct account reviews monthly with reports designed to show changes in market value, asset mix compliance and investment returns relative to policy benchmarks. This process serves as the impetus for rebalancing the portfolio back to portfolio policy weights. Based on the need of individual clients, we provide a monthly report containing the information in their required format. Quarterly, we conduct a more formal, rigorous review that includes a comparison with the investment policy, comparative returns with absolute goals, YON-DRAKE & ASSOCIATES, INC. 6 benchmarks and peers. We provide an analysis of portfolio characteristics, risk statistics, and manager compliance. Routinely, we require signed audit reports from each manager documenting their stated returns and market values. These reports are compared with custody reports and used to uncover discrepancies and errors between Yon-Drake’s report and that of the managers and custodian. We attend quarterly meetings with the client to evaluate the performance of all investments and managers. In these quarterly reviews, we provide an overview of general market conditions and insights into the performance of various asset classes, styles and markets influencing the performance of the client’s portfolios. Also, we review the progress of individual managers showing their performance versus absolute goals, benchmarks and peer universes. Recommend changes of investment managers and funds, and/or asset mix as necessary. 5. Ancillary Services In addition to the services described above, we perform other tasks related to maintaining a healthy, successful investment program. These include the following:
•Ongoing Manager Due Diligence.
We continue to monitor all managers after they are hired as long as they are employed by our client(s). In addition to using the manager databases mentioned above, we send direct questionnaires to the managers requesting information on such things as legal/regulatory problems, organizational changes, personnel turnover, account turnover, comparative portfolio characteristics and risk statistics compared side-by-side with prior quarters.
•Investment Policy Audits.
We perform investment policy audits whereby each provision of a client’s investment policy is evaluated. We issue a management report showing which policy provisions are out of compliance and recommend courses of corrective action.
•Fiduciary Education Early in the policy review process, we disseminate, collect and analyze anonymous fiduciary surveys indicating the client’s knowledge, experiences, preferences, attitudes and opinions regarding investments. Completed surveys are synthesized into a report on the findings of the survey and serve as the basis for conducting fiduciary education. In addition to the education of policy makers during the policy design process, Yon-Drake provides ongoing education to new fiduciaries to orient them to the philosophy and rationale for the institution’s investment program. YON-DRAKE & ASSOCIATES, INC. 7
•Third-Party Service Provider Searches Yon-Drake conducts searches for third-party service providers such as custodians, actuaries, DC plan administrators, DC plan package providers, banking relationships, and others. D. Wrap Fee Programs Yon-Drake does not participate in a Wrap Fee Program. E. AUM Yon-Drake has non-discretionary assets totaling $261,874,476 as of 12/31/23.