Firm Description Capital Research + Consulting LLC was founded in 1991 as a sole proprietor and then changed to a limited liability company in 1997. Capital Research + Consulting LLC provides personalized confidential investment advisory services to pension and profit-sharing plans organized under the Employment Retirement Income Security Act (“ERISA”) and to non ERISA Plans. Advice is provided through consultation with the client and to assist with mutual fund selection consistent with the client’s investment objectives considering relative degrees of risk and return. In seeking this objective, Capital Research + Consulting LLC generally advises clients in mutual funds of bonds, equities and money market funds. Capital Research + Consulting LLC is a fee-only financial consulting and investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The principals of Capital Research + Consulting LLC are also the principals of an affiliated firm, Capital Research Brokerage Services, LLC, a licensed broker/dealer. Investment advice is provided, with the client making the final decision on investment selection. Capital Research + Consulting LLC does not act as a custodian of client assets. The client or the plan administrator always maintains asset control. Capital Research + Consulting LLC also provides management of investment options for some clients. The client is made aware of any changes that will occur in the managed investment options. However, the firm has several client accounts that are managed on a discretionary basis. The clients are informed of any investment changes made by the firm. Quarterly investment analysis reports are prepared for clients to provide reminders of the specific courses of action that need to be taken. In some instances, a client will request that on a bi-annual report be prepared; however, this will be detailed in the Investment Advisory Contract the firm provides to the client. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. In providing investment advisory services, the sole standard of care of the Capital Research + Consulting LLC is to act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent Capital Research + Consulting LLC in a fiduciary capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. The Capital Research + Consulting LLC does not assume responsibility for the accuracy of information furnished by any third party to the client. Principal Owners John P Odell is a 100% stockholder effective April 1, 2017. Types of Advisory Services Capital Research + Consulting LLC provides investment management and consulting services by furnishing investment advice through consultations and issuing analysis reports about securities through charts, graphs, or other devices which the client may use to evaluate securities. As of December 31, 2022, Capital Research + Consulting LLC advises approximately $5.4 billion in assets for approximately 29 clients. Assets are managed on a non-discretionary basis or on a discretionary basis in accordance with the Advisory Contract established with the client. Tailored Relationships By their nature, all of our investment advisory services must be based on each client’s individual needs to have any useful validity. As a fiduciary, an investment adviser is to make only those recommendations that demonstrably are in the client’s own best interests, which means that they, too, must be based on an individual’s stated and/ or established needs, goals, risk tolerance and investment time horizon. The firm seeks to establish this personal dimension through a careful, fact-finding interview and discussions with each client. Clients may impose restrictions on investing in certain

securities or types of securities. In addition, the Advisory Contract will stipulate the functions Capital Research + Consulting will perform in their relationship with the client. Agreements may not be assigned without client consent. Types of Agreements The following agreements define the typical client relationships. Advisory Contract Most clients choose to have Capital Research + Consulting LLC provide investment consulting advice. All aspects of the client’s current plan are reviewed. Realistic and measurable goals are set and objectives to reach those goals are defined in the Investment Policy Statement. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. An Advisory Service Agreement includes investment consulting and/or management (including performance reporting), as well as assisting in the implementation of recommendations within each area with the plan administrator and/or custodian. The annual Advisory Service Agreement fee is based on a percentage of the investable assets and will be billed on a flat rate or fixed rate as negotiated. Said fees will be billed quarterly in advance or quarterly in arrears as determined by client agreement. The term “quarter” refers to a calendar quarter. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager in most cases may terminate an Agreement by providing 30 days written notice to the other party. In the event a client terminates prior to the end of the quarter, the unearned portion of the fee would be reimbursed to the client on a pro rata basis, or in the case where fees are paid in arrears, the client will be billed on a pro rata basis for the portion of the quarter completed. Current asset fee charged for consulting services is on an institutional basis of 0.05% to 0.35% annually, or as otherwise negotiated and will vary depending upon client asset size. Current asset fee charged on managed portfolio investment options can range from 0.10% to 0.50% annually, or as otherwise negotiated. Retainer Agreement In some circumstances, a Retainer Agreement is executed in lieu of an Advisory Contract Agreement when it is more appropriate to work on a fixed- fee basis. The fee for a Retainer Agreement would be negotiated depending on the scope of the work. Asset Management Assets are invested primarily in no-load or load waived mutual funds usually through fund companies and plan administrators. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Stocks and bonds may be purchased or sold through a brokerage account when appropriate and would not be available through Capital Research + Consulting LLC. The brokerage firm charges a fee for stock and bond trades. Capital Research + Consulting LLC does not receive any compensation, in any form, from fund companies. Investments included are mutual funds shares and U. S. government securities. Initial public offerings (IPOs) are not available through Capital Research + Consulting LLC. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by providing Capital Research + Consulting LLC with 30 days (or as otherwise agreed) written notice and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, Capital Research + Consulting LLC will refund any unearned portion of the advance payment. Capital Research + Consulting LLC may terminate any of the aforementioned agreements by providing 30 days (or as otherwise agreed) written notice to the client. If the client made an advance payment, Capital Research + Consulting LLC will refund any unearned portion of the advance payment.