2 firms that generally have less than $2 billion under management and/or meet certain other client specified criteria. We believe the skillful construction of multi-manager portfolios comprised of emerging managers can generate above-benchmark returns, particularly where there are market inefficiencies. Emerging managers also tend to be smaller firms that are in the early phases of the entrepreneurial business cycle. In selecting emerging managers and constructing portfolios comprised of such emerging managers, the firm's Multi-Manager Investment Governance Committee strives to minimize the business and investment risks that can accompany investment in smaller firms. Xponance will enter into an investment management agreement with each client for whom it manages a separate account, specifying the investment strategy and any restrictions or limitations for the account. Sub-Managers are generally retained through a contractual sub-advisory agreement with Xponance. Multi-manager portfolios are customized in accordance with client guidelines and risk parameters, and Sub-Managers are selected based on their ability to fill specific roles towards achieving the portfolio’s overall investment objectives. In addition to trading securities for accounts where Xponance has trading authority, from time to time Xponance may establish or assist its clients in establishing one or more trust or custodial accounts with an unrelated financial institution, and also monitor brokerage transactions executed on behalf of multi- manager portfolios. The extent to which Xponance provides these services and the amount of discretion given to Xponance with respect to these services, is determined by mutual agreement between Xponance and each client. Clients designate the benchmark against which their account will be measured for the purpose of determining investment skill, and clients may also place reasonable restrictions on the securities to be held in their account in accordance with each client’s investment guidelines. SUB-ADVISORY PORTFOLIO MANAGEMENT Xponance provides investment sub-advisor services to separate account investment portfolios that seek stable investment returns through the use of a variety of fixed income securities, which portfolios are directly managed by T. Rowe Price Associates (the “Manager”). Pursuant to an investment sub-advisory agreement, Xponance provides discretionary investment management services for such assets in compliance with applicable investment guidelines and restrictions, and provides periodic performance reports to the Manager. The Manager is responsible for selecting and monitoring sub-advisors such as Xponance, as well as ascertaining the financial circumstances, investment objectives, and investment restrictions applicable to each client through information provided by the client. Xponance is entitled to rely on such information provided by the Manager. COLLECTIVE INVESTMENT TRUSTS Xponance provides investment advisory services to the FIS Group Collective Investment Trust (the “FIS Group CIT”), for which Global Trust Company (“GTC”), a trust company organized under the laws of Maine, is the trustee. Xponance manages the assets of a fund established by GTC (the “FIS Group CIT Fund”). Xponance is responsible for constructing and monitoring the asset allocation and portfolio strategies for the FIS Group CIT Fund, consistent with the CIT Fund’s investment objective, strategy and risk parameters. We believe it is possible to enhance portfolio performance by hiring multiple Sub- Managers who have demonstrated the capacity to achieve desired investment objectives to manage the assets of the FIS Group CIT Fund. Accordingly, we manage the FIS Group CIT Fund using a “manager of managers” approach. Xponance’s Investment Governance Committee selects multiple Sub-Managers to manage the FIS Group CIT Fund, based upon its evaluation of the Sub-Manager’s investment style and performance in managing the asset class in which the CIT Fund will invest. Each client desiring to invest in the FIS Group CIT Fund will be provided offering and subscription documents relating to the CIT Fund, which will typically include a confidential offering memorandum, participation agreement and a copy of the CIT’s Declaration of Trust (collectively, the “FIS Group CIT Offering Documents”). Xponance does not have the authority to invest eligible plan assets into its CIT Fund on a discretionary basis. Xponance provides investment management services to Comerica Bank & Trust, National Association (“Comerica”), in its capacity as the Trustee of an S&P 500 Index CIT, that Comerica established (the “S&P 500 Index CIT”). Xponance is responsible for constructing and monitoring the asset allocation and portfolio strategies for the S&P 500 Index CIT, consistent with the CIT’s investment objective, strategy and risk parameters. Each client desiring to invest in the S&P 500 Index CIT will be provided offering and subscription documents relating to such CIT, which will

typically include a confidential offering memorandum, participation agreement and a copy of the CIT’s Declaration of Trust (collectively, the “CIT Offering Documents”). Xponance has the authority to invest eligible plan assets within the S&P 500 Index CIT on a discretionary basis in accordance with the investment guidelines of the S&P 500 Index CIT. NOTE: For additional information and disclosures regarding the FIS Group CIT Fund or the Comerica Xponance S&P 500 Index CIT, investors should refer to the Offering Documents for each such CIT, which can be obtained from Xponance. COMMON TRUST FUND (CTF) Xponance also provides investment management services to a common trust fund (“CTF’) that Comerica has established. A CTF is a commingled investment product available to not-for-profit organizations exempt from taxation under §501(c)(3) of the Internal Revenue Code of 1986. Pursuant to the terms of an Investment Management Agreement that Xponance has entered into with Comerica, Xponance is responsible for constructing and managing a Fixed Income portfolio in accordance with the CTF’s investment guidelines. Each client desiring to invest in a CTF will enter into a Trust Agreement with Comerica, which will designate Comerica as Trustee and grant Comerica full discretion to allocate assets to Xponance. Xponance has the authority to invest eligible plan assets within the CTF on a discretionary basis in accordance with the investment guidelines of the CTF. WRAP FEE ACCOUNTS Xponance participates in wrap fee programs sponsored by unaffiliated broker/dealers (each, a “Wrap Program”) by providing portfolio management services to these programs. There are no differences in the way Xponance manages Wrap Program accounts versus institutional accounts, except with respect to trading. For institutional accounts, Xponance uses the institutional trading desks of our approved brokers to execute trades. For Wrap Program accounts, Xponance uses the respective Wrap Program sponsor’s platform to execute trades. As payment for the provision of portfolio management services to Wrap Programs, Xponance receives a portion of the fee that is paid to the Wrap Program sponsor. PROPRIETARY ACCOUNTS Xponance provides investment management services for proprietary accounts owned by related persons or entities. Those proprietary accounts are managed in the same manner as any client accounts that are managed in the same strategy and benchmarked against the same index. Proprietary accounts are managed on a fully-discretionary basis but are non-fee paying accounts. AMOUNT OF ASSETS MANAGED As of December 31, 2023, Xponance had $16,611,528,774 in assets under management, which includes $16,376,524,065 of client and proprietary account assets managed on a discretionary basis and $235,004,709 of client assets managed on a non-discretionary basis. Assets managed on a discretionary basis and assets managed on a non-discretionary basis are included in computing “regulatory assets under management” reported in Item 5.F in Part 1 of Xponance’s Form ADV. With respect to the assets managed on a non-discretionary basis, these assets are included in computing “assets under management” because Xponance has continuing or regular supervisory or management responsibility for these assets. GENERAL INFORMATION: Xponance offers services on a fee-only basis, except for proprietary accounts which are non-fee paying. Clients enter into one of two fee arrangements. For Wrap Program accounts, the all- inclusive fee includes the investment management fee paid to Xponance, as well as the brokerage expenses (e.g., commissions, ticket charges and similar expenses) of the account, charges for custody services and certain other administrative fees. For most non-discretionary portfolio management services and certain discretionary portfolio management services, clients will pay management fees to Xponance separately from the brokerage expenses, transaction costs and custody fees related to the account. We generally charge fees based upon a percentage of assets under management and fee structures are tiered based upon the amount of assets managed for each mandate. A number of factors are considered in establishing fees including the amount of assets to be placed under management, asset class mandate, complexity of the client relationship, performance reporting requirements and pre-existing contractual commitments. For multi-manager portfolios, Xponance’s fees are typically inclusive of the fees charged by the Sub-Managers. The annual fee charged by Xponance is generally within the range of .10% and .80% for Active Equities, .01% and .25%, for Passive Equities and .05% and .3% for Fixed Income and is further dependent upon the size of the investment in each strategy, the overall size of the client relationship as a whole, extent of desired customization, the required reporting, and other factors.