McLean Asset Management Corporation ("MAMC") is a registered investment adviser that was founded in 1984. MAMC is an independent adviser firm that provides investment management services and consulting services to a broad range of clients, including individuals, employer-sponsored retirement plans, trusts, estates, charitable organizations, and business entities. MAMC is principally owned by Alejandro (Alex) Murguia. MAMC provides discretionary and non-discretionary investment supervisory services to its clients. At the beginning of a client relationship, MAMC consults with the client to obtain detailed financial information and other pertinent data that will assist in developing an effective investment management program tailored to the client's specific needs. MAMC manages the client's account(s) on an individualized basis, taking into consideration a client's goals, investment objectives, client mandated restrictions, risk tolerance, net worth, net income, and other various suitability factors. Further restrictions and guidelines may be imposed by a client, which will affect the composition and performance of portfolios. For these reasons, the performance of portfolios within the same investment objective may differ, and clients should not expect that the performance of their portfolios will be identical with other MAMC clients. In addition, depending upon a client's specific circumstances and needs, MAMC may provide clients additional services such as financial planning, risk management counsel, the establishment of and counsel on retirement plans, and review of assets outside direct management by MAMC. A client may choose to have MAMC provide one or more of the services described below. Each client is advised that any change in the client's financial situation or investment objectives must be immediately conveyed by the client to MAMC to ascertain whether the agreed-upon services/recommendations continue to be suitable and prudent for the client. The scope of the services to be provided to a client is governed by a written agreement between MAMC and the client. The services that MAMC provides include the following: Investment Supervisory Services. A client may identify specific assets to be managed by MAMC on a discretionary or non-discretionary basis, granting MAMC the authority to act as the client's agent to supervise, manage, and buy/sell assets on the client's behalf consistent with the agreed-upon investment strategy. For clients electing a non-discretionary relationship, trades will only be executed after obtaining the client's approval. In the event of a major market correction in either direction or negative news about a specific security or management of a security, MAMC will be unable to effect transactions in the client account without first obtaining the client's consent. MAMC considers the client's investment objectives for clients with a discretionary relationship but does not consult with the client before taking any action in implementing the investment strategy that MAMC and the client have previously agreed. Non-Discretionary Recommendations without Agent Authority. A client may identify specific assets to be subject to MAMC's non-discretionary advisory recommendations (i.e., non-discretionary investment recommendations approved and implemented by the client). Most commonly, these arrangements will cover assets held in accounts for which MAMC does not have trading authority, potentially including client accounts held on retirement plan platforms or sub-accounts underlying variable annuities. If mutually agreed to in writing, MAMC will make recommendations with respect to such assets as MAMC deems appropriate in light of the client's investment objectives. However, the client is solely responsible for determining whether to follow any recommendations made by MAMC, and for implementing any recommendations MAMC makes with respect to such assets. Additional Financial Services and Consultation. In addition to managing the discretionary and non-discretionary investment advisory services described above, MAMC may consult with clients on various financial subjects including income and estate tax matters, business sale structures, education funding, retirement planning, establishment and design of retirement plans and trusts, among other things. These services are provided as part of the financial planning services offered by MAMC. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, MAMC may provide financial planning and related consulting services regarding non- investment related matters. MAMC does not serve as a law firm or accounting firm and no associated person of MAMC acts as a lawyer or accountant. No portion of MAMC's services should be construed as legal or accounting services. Neither MAMC nor its associated persons prepare tax returns or provide tax advice. Neither MAMC nor its associated persons prepare estate planning documents or provide legal advice. All tax and legal strategies should be confirmed with your tax adviser or legal counsel. When appropriate for a client, MAMC may recommend the purchase of insurance products, including through MAMC's affiliated insurance agency, McLean Insurance Solutions, LLC ("MIS"), and MAMC representatives

in their separate capacities as insurance agents. The recommendation that a client purchase an insurance product presents a material conflict of interest, as the receipt of insurance sales compensation provides an incentive to recommend insurance products based on compensation received rather than on a particular client's need. No client is under any obligation to purchase any insurance products from MIS or any of MAMC's licensed insurance agents. Clients are reminded that they may purchase insurance products recommended by MAMC through other, non-affiliated insurance agents and agencies. Referrals to Outside Professionals. To the extent requested by a client, MAMC may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by MAMC or its representatives. Please Note: If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Employer-Sponsored Retirement Plans. Investment management and advisory services are also provided to qualified employer-sponsored retirement plans where MAMC may serve as a fiduciary under ERISA §3(21) and/or an investment manager under ERISA §3(38). As an ERISA §3(21) fiduciary, MAMC acts in a non-discretionary capacity, making recommendations to the plan sponsor regarding the plan investments, and can also assist in the development of an investment policy statement based upon the plan's goals and objectives; provide participant education; advise the plan regarding its fiduciary obligations; and assist with ongoing plan operations, as needed. Where MAMC has been appointed an investment manager under ERISA §3(38), MAMC possesses discretionary authority to select, monitor and replace the investment options made available to the plan participants according to the goals and investment objectives of the plan. MAMC can also design and maintain asset allocation model portfolios comprised of designated investment alternatives available to the plan participants. Plan participants have the option to select an asset allocation model portfolio or construct their own customized portfolio of funds. Each plan chooses its own third-party administrator to provide administrative and recordkeeping services. MAMC may make a referral to outside administrators if requested by the client; however, MAMC has no financial interest in and receives no compensation for such referrals. Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer's plan, if permitted, (ii) roll over the assets to the new employer's plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account ("IRA"), or (iv) cash out the account value (which could, depending upon the client's age, result in adverse tax consequences). If MAMC recommends that a client roll over their retirement plan assets into an account to be managed by MAMC, such a recommendation creates a conflict of interest if MAMC will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by MAMC. MAMC's Chief Compliance Officer, Paula Friedman, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. ERISA / IRC Fiduciary Acknowledgment: When MAMC provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way MAMC makes money creates some conflicts with client interests, so MAMC operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, MAMC must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that MAMC gives advice that is in the client’s best interest;
• Charge no more than is reasonable for MAMC’s services; and
• Give the client basic information about conflicts of interest. Assets Under Management. As of December 31, 2022, MAMC had $883,990,338 of assets under management, of which $877,686,293 are discretionary, and $6,304,045 are non-discretionary.