Firm Description Garcia Hamilton & Associates, L.P. (“GH&A” or the “Firm”) is a Houston, Texas based investment management company that was founded in 1988. The Firm is a 100% employee-owned limited partnership. Principal Owners The Firm is owned by employee partners with ethnic minority and female partners representing 88% of Firm ownership. Listed below are the Firm’s principal partners (i.e., those individuals controlling 25% or more of the partnership). Gilbert Andrew Garcia, CFA, Managing Partner Types of Advisory Services Garcia Hamilton & Associates, L.P. provides continuous and regular investment management services with respect to client accounts.
• Separate Account Portfolio Management
• Mutual Fund Portfolio Management (Sub-Adviser)
• Commingled Fund Portfolio Management (Sub-Adviser)
• Collective Investment Trust Portfolio Management The Firm has offered additional investment management services with respect to client accounts and is able to do so again in the future.
• Model Portfolio Management (Sub-Adviser) Separate Account Portfolio Management Separate Account Portfolio Management provides continuous investment management services of client funds in separate account portfolios. The Firm manages these advisory accounts in a discretionary manner, taking into account individual client needs, if any, set forth in the client’s Investment Management Agreement or other written investment policy or guidelines provided by the client. Investment teams and individual portfolio managers often manage multiple accounts according to the same or a similar investment strategy. Types of Investments The Firm’s investment strategies incorporate domestic, high-quality fixed income securities in single asset class portfolios and will generally include the following securities either traded on an exchange or in the over-the-counter market:
• United States government securities
• Corporate debt securities (rated at a minimum of single A- or better by at least two rating agencies)
• Agency debentures
• Agency Mortgage-backed securities Certain short enhanced cash portfolios will generally also include the following securities:
• Agency discount notes
• Asset-backed securities (collateralized by auto, credit card and equipment lease receivables)
• Commercial Paper
• Money Market Funds Tailored Relationships Clients can impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. GH&A will discuss with a client or client’s representative any guideline or policy that may limit management of the funds in line with the strategy selected by the client. Mutual Fund Portfolio Management (Sub-Adviser) Mutual Fund Portfolio Management provides continuous investment management services as a sub-adviser to registered investment companies. The Firm manages these advisory accounts in a discretionary manner. Mutual Fund Portfolio Management is designed to meet a particular investment goal. Types of Investments The Firm’s investment strategies incorporate domestic, high-quality fixed income securities and will generally include the following securities which may be exchange traded or traded over-the-counter:
• United States government securities
• Corporate debt securities (rated at a minimum of single A- or better by at least two rating agencies)
• Agency debentures
• Agency Mortgage-backed securities Tailored Relationships The sponsoring investment adviser to the registered investment company to which GH&A provides sub- advisory services may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. GH&A will discuss any guideline or policy

restrictions with the adviser that may limit management of the funds in line with the strategy selected by the investment adviser. Commingled Fund Portfolio Management (Sub-Adviser) Commingled Fund Portfolio Management provides continuous investment management services as a sub- adviser. The Firm manages these advisory accounts in a discretionary manner. Types of Investments The Firm’s investment strategies incorporate domestic, high-quality fixed income securities and will generally include the following securities which may be exchange traded or traded over-the-counter:
• United States government securities
• Corporate debt securities (rated at a minimum of single A- or better by at least two rating agencies)
• Agency debentures
• Agency Mortgage-backed securities Tailored Relationships The sponsoring investment adviser to the registered investment company to which GH&A provides sub- advisory services may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. GH&A will discuss any guideline or policy restrictions with the adviser that may limit management of the funds in line with the strategy selected by the investment adviser. Collective Investment Trust Portfolio Management Collective Investment Trust Portfolio Management provides continuous investment management services. The Firm manages these advisory accounts in a discretionary manner. Types of Investments The Firm’s investment strategies incorporate domestic, high-quality fixed income securities and will generally include the following securities which may be exchange traded or traded over-the-counter:
• United States government securities
• Corporate debt securities (rated at a minimum of single A- or better by at least two rating agencies)
• Agency debentures
• Agency Mortgage-backed securities Tailored Relationships The sponsoring investment adviser to the registered investment company to which GH&A provides sub- advisory services may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. GH&A will discuss any guideline or policy restrictions with the adviser that may limit management of the funds in line with the strategy selected by the investment adviser. Model Portfolio Management (Sub-Adviser) Model Portfolio Management provides continuous investment management services of funds in model portfolios as a sub-adviser in programs where another manager serves as the discretionary investment manager. GH&A may, in the future, manage these advisory accounts in a non-discretionary manner. For Model Portfolio Management, GH&A maintains broad authority with respect to the timing of providing recommendations. Model Portfolio Management is designed to meet a particular investment goal. Types of Investments The Firm’s investment strategies incorporate domestic, high-quality fixed income securities and will generally include the following securities which may be exchange-traded or traded over the counter:
• United States government securities
• Corporate debt securities (rated at a minimum of single A- or better by at least two rating agencies)
• Agency debentures
• Agency Mortgage-backed securities Tailored Relationships The discretionary investment manager can impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. GH&A will discuss with the discretionary investment manager any guideline or policy that may limit management of the funds in line with the strategy selected by the investment adviser. Amount of Managed Assets As of 12/31/2023, we were actively managing $20,236,727,145 of clients' assets on a discretionary basis.