Description of MCM MCM is an independent investment adviser registered with the SEC. MCM primarily manages concentrated growth equity portfolios for diverse institutional and individual clients, as described further below. A significant percentage of MCM’s clients consists of a U.S. registered investment company and other pooled investment vehicles (such as a sub-advised foreign collective investment vehicle) (together, “Fund Clients”). MCM also manages separately managed private accounts (“Private Accounts”) for other institutions and individuals, such as corporate retirement plans, foundations, trusts, tax-exempt and charitable institutions, individual retirement accounts, and other institutions and individuals as described further in Item 7: Types of Clients. MCM also provides services to wrap account programs by serving as investment manager (or sub-adviser to a manager) of wrap program accounts or model portfolios. However, MCM does not sponsor any wrap programs. Founded by Thomas F. (“Tom”) Marsico in 1997, MCM is an independent firm controlled by its management through a parent company structure. Mr. Marsico also serves as Chief Executive Officer, President, and Chief Investment Officer of MCM. Principal Owners of MCM MCM is a direct, wholly-owned subsidiary of Marsico Subco, LLC, which is a direct, wholly- owned subsidiary of Marsico Holdings, LLC (“Holdings”). Holdings, in turn, is owned by Marsico Group, LLC (“Group”) and by third parties. Group controls Holdings as its managing member, holds 100% of the voting rights in Holdings, and owns approximately 38% of the equity interests in Holdings, the largest block of equity interests held by any single entity. Group, in turn, is owned by MCM management, including certain MCM employees and their family interests. The principal owner and managing member of Group is a partnership controlled by Tom Marsico. Through the partnership’s control of Group, the partnership retains all voting rights and control over the ongoing management and day-to-day operations of Holdings and its subsidiaries, including MCM. Tom Marsico also directly owns certain equity interests in Holdings in addition to the interests that he and other MCM employees indirectly own through Group. Taken together, Group, Mr. Marsico, and his family interests own approximately 60% of the equity interests in Holdings. The remaining minority of the equity interests of Holdings not held by Group and Tom Marsico are held by third parties. Because equity interests in Holdings do not include voting rights over management and operations, they are not considered voting securities under pertinent securities laws, and third-party owners of interests in Holdings are not considered affiliated persons of Holdings or its subsidiaries, including MCM. Equity interests in Holdings may be transferred privately subject to applicable agreements and securities laws. Marsico Capital Management, LLC Page 5 Form ADV Part 2A March 28, 2024 None of MCM’s affiliated companies are public companies, broker-dealers, or investment advisers, are substantially involved in MCM’s day-to-day business operations, or perform other functions that may be significant for regulatory purposes. Types of Advisory Services Provided by MCM As noted above, MCM primarily manages concentrated growth equity portfolios for diverse clients. As discussed further in Item 8: Methods of Analysis, Investment Strategies and Risk of Loss, the primary strategies through which MCM invests client portfolios consist of: Focused Growth Large Cap Growth Select Alpha Growth Midcap Growth Focus International Growth Global Growth MCM may invest particular clients’ accounts based on combinations or modifications of these or other strategies tailored to each client’s individual specifications. MCM seeks to accommodate any reasonable guidelines and restrictions that clients may specify, including restrictions on particular securities or industries. MCM may modify its customary strategies for particular clients if desired. As discussed further in Item 8 below, MCM primarily uses fundamental methods of analysis including top-down macroeconomic analysis and bottom-up company and security analysis in investing client accounts. From time to time MCM also may use other investment tools or strategies to check, refine, or enhance these methods. While MCM invests primarily in equity securities for clients, client accounts also may hold a variety of other securities and investments potentially including fixed income if desired. MCM does not generally manage portfolios based on alternative strategies such as asset allocation, long-short, risk-neutral, absolute return, or similar strategies, use quantitative filters or screens or optimization techniques in portfolio construction, or target tracking error levels, standard deviation, or other metrics in managing client portfolios. MCM generally does not manage portfolios that invest significantly in derivatives, swaps, commodities, commodity futures, options on commodities, or cryptocurrencies and crypto assets. MCM may exercise its discretion to seek to hedge portfolio exposures to individual securities held in a portfolio, broad-based securities indices, currencies, markets, interest rates, and other variables that could potentially affect returns to investors, but is not required to hedge any client account. MCM does not hold itself out as a commodity pool operator or commodity trading adviser, and any commodity interest trading advice that MCM may offer is incidental to its business of providing investment advice primarily relating to securities. Marsico Capital Management, LLC Page 6 Form ADV Part 2A March 28, 2024 Clients Include Fund Clients and Separately Managed Private Accounts Fund Clients served by MCM include the U.S. registered investment company identified in Item 10: Other Financial Industry Activities and Affiliations, and other pooled investment vehicles (such as a sub-advised foreign collective investment vehicle). MCM may provide services to an entire fund or portfolio or to a sleeve of a fund or portfolio as an advisor or sub- advisor. In serving Fund Clients, MCM typically serves as investment adviser or sub-adviser to the fund or its principal manager. Fund advisory arrangements and fees vary and generally are approved by fund boards. The prospectus or other disclosure document for each fund or portfolio provides information about advisory or sub-advisory services and fees payable to MCM (or to another principal manager which itself may pay MCM). Separately managed Private Accounts that MCM manages for other institutions and individuals include corporate retirement plans, foundations, trusts, tax-exempt and charitable institutions, individual retirement accounts, and other institutions and individuals. Clients Include Wrap Programs MCM provides services to wrap account programs (“wrap programs”) by serving as investment manager (or sub-adviser to a manager)

of wrap program accounts or model portfolios. MCM does not sponsor any wrap programs. Wrap programs are typically sponsored by a broker-dealer or affiliated advisory firm, and may help brokerage clients to obtain the services of selected managers like MCM in buying securities for accounts that may be too small to be managed as Private Accounts. Wrap programs also include other services such as the sponsor’s oversight of investment managers, sponsor execution of trades, and sponsor custody of portfolio securities. Participants should be aware that wrap account fee rates may be higher than fee rates that certain Private Accounts may pay to retain MCM’s services directly if minimum thresholds are met. Program sponsors, not MCM, generally set program fees and determine program services provided to participants. Wrap programs generally require sponsors and service providers to provide services to multiple participants. MCM seeks to serve each wrap program participant effectively. Due to the structure of wrap programs and sponsors’ primary role in providing certain services, MCM may not always be in a position to provide the same comprehensive client relationship services to each wrap program participant that it may provide to each Private Account. Depending on the type of wrap program, MCM’s services as investment manager may include maintaining a model portfolio to guide purchases and sales of securities for program participants, and communicating changes in the model to programs. An MCM portfolio manager, or other persons designated by a portfolio manager, such as MCM’s traders, may make or communicate management decisions for model portfolios based on similar portfolios and other considerations. Other duties potentially performed by MCM, such as assisting in trades if requested, vary depending on the wrap program involved. Marsico Capital Management, LLC Page 7 Form ADV Part 2A March 28, 2024 Unified Managed Account Wrap Programs. In unified managed account or similar wrap programs (each a “UMA” or a “UMA Wrap Program”), the sponsor (or an affiliated or independent “overlay manager” appointed by the sponsor) assumes the primary role in managing client portfolios using recommendations from other investment managers such as MCM. In return for a fee, UMA program clients receive investment management services directly from the sponsor or overlay manager rather than from MCM. The sponsor or overlay manager receives limited services from investment managers such as MCM, which provide ongoing investment recommendations in the form of a model portfolio and periodically update the model portfolio. The sponsor or overlay manager exercises its discretion in how best to implement the manager’s recommendations for clients as the sponsor deems appropriate, often by blending model portfolios provided by MCM and other managers to create portfolios the sponsor deems suitable for clients. The sponsor or overlay manager generally executes trades for UMA portfolios itself. In UMA arrangements, MCM’s duties typically are limited to providing model portfolios to sponsors or overlay managers. In unusual cases, MCM may advise the sponsor on the execution of certain trades. MCM receives a portion of the UMA Wrap Program fees for its services. Separately Managed Account Wrap Programs. In a separately managed account wrap program (“SMA Wrap Program”), the sponsor and other service providers provide a bundle of services to client participants in return for a single fee paid to the sponsor that “wraps” around the various services. The sponsor’s services typically include assisting the participant in selecting investment managers such as MCM that can implement investment strategies deemed suitable by the sponsor, participant, and manager based on participant investment objectives, overseeing the services provided by each manager, paying each manager, facilitating the execution of trades through the sponsor or its brokerage affiliate, and holding securities in custody. In SMA Wrap Programs, MCM typically would provide management services, oversee the execution of trades typically through the sponsor, and provide other services to SMA sponsors and participants. MCM typically would receive a portion of SMA account wrap fees for its services. The SMA Wrap Program sponsor and participants typically expect the manager to transmit most trades to the sponsor for execution. In unusual circumstances, a manager may request that another broker execute trades. The quality of trade executions for wrap programs is generally reasonable but may vary substantially, as described further in Item 12: Brokerage Practices. Effect of Participant Restrictions on Wrap Accounts. Participants in wrap programs may request reasonable investment-related restrictions on the management of their accounts. SMA Wrap Program participants who request multiple restrictions should be aware that because MCM follows a relatively concentrated strategy favoring a limited number of core equity holdings, MCM may hold cash, cash equivalents or other securities to fill any portion of an SMA Wrap Program account that participant restrictions prevent from being invested in core equity holdings. As a result, an SMA Wrap Program account subject to participant restrictions may hold a higher percentage of cash or cash equivalents compared to other accounts that are not restricted, while paying the same wrap fee as an unrestricted account. This could impact the investment performance of a restricted wrap account compared to a similar account without significant investment restrictions. Marsico Capital Management, LLC Page 8 Form ADV Part 2A March 28, 2024 Wrap Programs in Which MCM Participates. As of the date of this brochure, MCM offers its services through certain UMA Wrap Program sponsors including Envestnet and Counsel Portfolio Services IPC Private Wealth. Client Assets Under Management As of February 29, 2024, MCM managed approximately $3.25 billion of client assets invested on a discretionary basis. As of that date, MCM also provided investment advice to certain model portfolio wrap programs on a non-discretionary basis totaling approximately $67.6 million. Business Continuity Plan MCM has long maintained a business continuity and transition plan that is reasonably designed to ensure that MCM provides full service to clients despite any business disruption or impact on staff because of an incident such as a cybersecurity issue, pandemic, or other event. MCM maintains a fully functioning headquarters office, and also maintains a separate alternative work site, as well as the technological capability to allow staff to work securely from remote sites at any time. MCM and its clients did not experience any service disruptions relating to the COVID-19 outbreak nor have they for any other matters. During the COVID-19 outbreak, MCM’s staff at times worked remotely, or worked in staggered shifts alternating between headquarters offices and remote locations, and may continue to do so.