Firm Description Park Avenue Securities LLC (“PAS”) is a dually registered broker-dealer and investment adviser that provides investment advisory services through investment adviser representatives (each, an “IAR”). PAS has been registered with the SEC as an investment adviser since November 13, 2000. Additional information about PAS is available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about persons who are registered as IARs of PAS. Principal Owners PAS is a wholly owned subsidiary of The Guardian Life Insurance Company of America (“GLIC”), a New York mutual life insurance company. GLIC and its affiliates sell their products through a system of insurance agents, most of whom are also registered representatives and IARs of PAS. Types of Advisory Services Offered PAS offers proprietary investment advisory programs (each, a “PAS Proprietary Program”) and select third- party investment advisory programs (each, a “Third-Party Investment Advisory Program”), together the “Programs.” In addition, certain IARs offer financial planning, consulting, business planning and education services to clients. Understanding your Relationship with PAS PAS is subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and as a registered investment adviser, PAS, along with its IARs, have a fiduciary duty to you. This generally means that PAS and its IARs will act in your best interest when providing investment advice under the Advisers Act and will disclose or avoid all material conflicts of interest. Throughout the various sections of this Brochure PAS has identified material conflicts of interest where you see such language bolded or within specific sections identified as discussing material conflict of interest. Within the advisory programs described in this Brochure, PAS provides services as an investment adviser under the Advisers Act. In providing investment advice, your PAS Investment Adviser Representative (IAR”) can select from different products and programs. This includes advisory programs described in this brochure and other advisory programs described in PAS Wrap Fee Brochures. Your IAR can also act in his or her capacity as a registered representative of PAS providing securities recommendations in a PAS brokerage account. This includes the recommendations and sales of products such as mutual funds, variable annuities, variable life, or individual stocks and bonds, if appropriately licensed. In each of these scenarios, your IAR provides different services and will be paid differently depending on the account type, product or program selected. There are important differences within these types of accounts/products in terms of ongoing services provided, costs and the obligations of your IAR and PAS. You should discuss with your IAR the benefits and costs associated with the different advisory programs available at PAS as well as what relationship may be best for you. This should include a discussion about the benefits and costs associated with a brokerage versus an advisory relationship, the products offered within each relationship and the IAR’s ongoing obligations when acting as an IAR versus a registered representative. An advisory account may not be appropriate for low volume trading activity, if you have a long term buy-and- hold investment strategy or if you direct PAS to execute a significant amount of trades on your behalf. In these instances, a transaction-based brokerage account may be more appropriate. Trading activity and the costs and expenses associated with an investment product, among other things, should be considered when deciding whether an advisory account is appropriate for you. Based on the following scenarios, a brokerage relationship may be right for you, if:  You want an adviser to provide occasional advice and recommendations on certain investments and 6 (3/2024) execute on your investment decisions;  You plan to buy only a few securities and follow a buy-and-hold strategy over a long time period without the need for ongoing advice from an adviser; and/or  You wish to pay fees based on each transaction that you place and not for ongoing advice. As a broker-dealer, PAS offers a variety of financial products and services and can render advice as to the value and/or advisability of purchasing or selling securities without receiving special compensation where such advice is solely incidental to the conduct of its business as a broker-dealer. In certain situations, PAS may offer general, impersonal investment advice in the form of publications and other services. PAS will not be deemed to be providing investment advisory services unless it has entered into a contract with the client for that purpose. If you are seeking one or more of the following scenarios, an investment advisory relationship may be right for you:  Discretionary management of your investment portfolio;  Ongoing advice and investment services;  Trading and rebalancing of your portfolio on a periodic basis; and  An annual fee that is based on the amount of assets managed and is not tied to the number or type of transactions in the account. In some cases, an investment advisory relationship may cost you more than a brokerage relationship and vice versa. You should periodically discuss the various options with your IAR. PAS IARs are compensated for servicing and providing investment advice for the Programs. The compensation paid to IARs for each of the Programs is generally comparable, except for VestWiseTM, the digital advisory program offered by PAS, which has a lower fee structure. This compensation may be more than what the IAR would receive if you pay separately for investment advice, brokerage, and other services. Under PAS Proprietary Programs, clients must establish an account through PAS with Pershing LLC (“Pershing”). Pershing acts as the clearing firm and custodian for client assets within PAS Proprietary Programs. Accordingly, all trading activity under PAS Proprietary Programs will be processed through client accounts with Pershing. In its capacity as a clearing and custodial firm Pershing performs centralized custody, bookkeeping and execution functions. Pershing handles the delivery and receipt of securities purchased or sold on behalf of PAS clients, receives, and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers, and redemptions. Pershing sends statements of account activity no less often than quarterly. Rollovers and Fiduciary Acknowledgement When PAS and its IARs recommend to a) participants in ERISA-covered retirement plans to roll over assets into an IRA or b) owners of IRAs to roll over or transfer assets to another IRA, PAS and its IARs are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean PAS and its IARs are acting as fiduciaries for purposes of other applicable laws. This acknowledgement of fiduciary status does not confer contractual rights or obligations on you, PAS, or the IARs. With respect to rollover transactions, certain portions of this Firm Brochure disclosure are intended to comply with requirements under the U.S. Department of Labor’s Prohibited Transaction Exemption 2020-02, specifically; (i) information regarding the scope of services provided by PAS and its IARs, (ii) the fiduciary acknowledgement above, and (iii) the description of the material conflicts of interest under which PAS and your IARs are operating. Rollovers PAS and your IAR get paid when you engage in a rollover transaction. PAS can recommend that you rollover assets from your workplace retirement plan or from an existing IRA into an IRA account with 7 (3/2024) PAS. When you engage in a rollover to an IRA, PAS and your IAR will receive compensation in connection with the investments you will acquire for your IRA account and hold in the account. This compensation incentivizes PAS and your IAR to make a rollover recommendation. Transferring an Existing Account to PAS Programs There may be instances in which you have chosen to open a Program account that requires you to liquidate existing investment assets or accounts and transfer the proceeds to the Program in which you wish to participate. In making the request to liquidate assets and transfer your proceeds, you may experience costs due to the requested liquidation. These costs can include, but are not limited to, account termination charges, contingent deferred sales charges, surrender charges, and commissions on the sale of stocks, bonds, exchange traded funds, closed end mutual funds, limited partnership shares or any other securities you hold in these accounts. If you redeem, surrender, or sell existing assets to fund an account you should carefully consider the costs and benefits of the transaction including any tax liability. You should also ask your IAR if the sale of the assets used to fund your Program account will benefit your IAR in the form of a commission or fee payable to them and take that into consideration before you initiate the liquidation of any assets to fund your Program account. The liquidation of any investment may trigger taxable gains or losses, could trigger the Alternative Minimum Tax (AMT) and may require additional quarterly estimated tax payments. Neither PAS nor your IAR provide tax advice or tax management services. You are responsible for any taxable events. You should always consult with your tax advisor for specific tax advice. Tailored Client Relationships For programs other than VestWiseTM, the digital advisory program offered by PAS, your IAR will request information from you regarding your financial background, investment experience, investment objectives, risk tolerance, and any reasonable restrictions that you wish to impose on investing in certain specific securities and types of securities and will provide important disclosures to you. Your IAR will work with you to help you determine your investment goals and will assist you in selecting one of the PAS Proprietary Programs or a Third- Party Investment Advisory Program. As your goals and objectives change over time, your IAR will update your records and client file and may provide new recommendations and advice that fit your needs. You should notify your IAR promptly if there are any changes in your financial situation, risk tolerance, investment objectives or account restrictions. Your IAR will periodically review performance and other periodic reports provided to you and will offer to meet with you at least annually to review your financial situation and investment objectives. Client Advisory Agreement If you select a PAS Proprietary Program, you will sign a client agreement which consists of a Statement of Investment Selection and Terms and Conditions (the “Client Agreement”). The Client Agreement will detail all of the important information pertaining to your account, including the management fee and the termination provisions. You are encouraged to read all of the terms of the Client Agreement. In a Third-Party Investment Advisory Program, you will sign an investment advisory agreement directly with the third-party investment adviser or, in certain circumstances, a tri-party agreement with PAS and the third- party investment adviser, as described below under “Third-Party Investment Advisory Programs.” Financial Planning and Consulting Certain IARs are authorized by PAS to offer financial planning and consulting services. For these services, the IAR may negotiate a fee based upon the overall experience of the IAR, a client’s financial needs and investment objectives, the time necessary to develop a plan and the complexity of a plan. If you engage an IAR for financial planning or consulting services, at the beginning of the relationship your IAR will provide you with a Financial Planning or Consulting Agreement, which will detail all the important terms and conditions pertaining to the financial plan or consultation, including the fee. 8 (3/2024) Fee-based financial planning is a service that considers many different aspects of your financial circumstances, typically by utilizing a financial planning software program to create an overall plan that is designed to meet your goals and objectives. Financial consulting is an open architecture process that requires your IAR to collect information from you and develop customized recommendations that are delivered to you within the parameters of an agreed upon scope of consulting services. The financial planning and consulting services provide for ongoing consultation with your IAR, typically through a series of personal meetings and telephone calls. The services provided may include follow-up meetings with you and your other advisors (e.g., attorneys, accountants, etc.). Depending on your needs and pursuant to the agreement with your IAR, your formal written financial plan or consultation recommendations may cover:  General Financial Planning  Goal Planning (e.g., Education Planning)  Retirement Planning  Risk Management  Cash Flow Planning  Wealth Transfer Planning  Business Succession and Exit Planning   Investment Analysis  Your written financial plan or consultation will consist of observations, assumptions, strategies, and recommendations. You will have the opportunity to renew the agreement and update your plan at least annually, or as your circumstances change. You may choose to implement all or any part of the financial plan or consultation recommendations through PAS, or through any other broker-dealer, investment adviser or service provider of your choice. Please note if you choose to implement all or part of the financial plan through PAS, your IAR will receive additional compensation for any product purchases or additional investment advisory services. Subscription Based Financial Planning Certain IARs are authorized by PAS to offer on-going financial planning services via Subscription-Based Financial Planning. The subscription arrangement will provide you with the ability to engage your IAR for financial planning services by paying an annual fee on either a monthly or quarterly basis. Your agreement will renew annually unless you choose to terminate the agreement. Your IAR will provide you with analysis, recommendations, and ongoing monitoring based on your current financial situation and goals. On an annual basis you will receive a written summary of the terms of the engagement which will include an outline of your goals, both accomplished and future, a summary of the meetings with your IAR, your fee arrangement, and a reminder of the termination option within the agreement. Listed below is an overview of the services that may be provided through the Subscription-Based Financial Planning Program. Included with the services is access to your IAR throughout the subscription period. A full description of each service can be found within the Subscription-Based Planning Agreement. Core Services:  Initial Consultation, including obtaining and organizing essential documents  Obtaining essential documents  Organizing documents  Cash Flow and Debt Planning Analysis 9 (3/2024)  Net Worth Statement  Investment Analysis  Risk Analysis  Access to your Advisor throughout the subscription period Advanced Planning:  Charitable Planning  Wealth Transfer Planning  Goals-based Planning  Education Planning and Funding  Retirement Planning  Tax Planning Strategies  Life Events  Business Planning It is important to note that if your IAR provides advice related to a separate brokerage account, advisory account, or other investment as part of this engagement, the Subscription-Based Financial Planning fee will be in addition to any fees or commissions associated with those accounts. However, the advice provided within the Subscription-Based Financial Planning arrangement cannot solely be comprised of existing PAS accounts. Additionally, if you choose to implement recommendations from your IAR as part of this engagement, the fees or commissions associated with products purchased or sold will be in addition to your Subscription-Based Financial Planning fee. Fiscalyze When providing financial consulting services to business clients, certain IARs may utilize the services of The Advanced Practice Network LLC, doing business as Fiscalyze (“Fiscalyze”), a third-party vendor who provides services to PAS IARs. Fiscalyze charges a fee for these services which is in addition to the fee that a client pays for the financial consulting services provided by the PAS IAR. The services that Fiscalyze provides are not investment advice and consist of the following, all of which are offered through the PAS IAR when providing financial consulting services to a client:  Inventory and Organization of Documents  Annual Review of Objectives  Personal & Family Checklist  Enterprise Checklist  Capital & Cash Flow Priorities Worksheet  Personal & Family Concerns Assessment  Enterprise Concerns Assessment  Business Continuity Analysis to explore the most likely interruptions to the business.  Qualified Plan Insights  Executive Benefits and Carve-out Insights  Employee Benefits Insights  Professionally Adjusted Business Valuation (Enterprise Drivers) Reports.  Margin Analysis (Profit Drivers)  Cash Cycle Analysis (Cash Drivers)  Lender Analysis  Forecasting Analysis  Capital Analysis  Comprehensive Gap Analysis  Industry Benchmarking Analysis  An inventory of strategies which tracks progress over time. 10 (3/2024) Fiscalyze is owned by Kelly Kidwell, Eric McDermott, and Matthew Shipman (the “General Agents”). The General Agents also own Pacific Advisors, LLC (“Pacific Advisors”). Pacific Advisors is a general agency of The Guardian Life Insurance Company of America (“GLIC”), and as such has entered into contracts with GLIC and PAS, pursuant to which the General Agents supervise and may influence the PAS IARs associated with Pacific Advisors. These contracts also provide for compensation, in the form of a certain percentage of the financial consulting fee (an “override”) that is charged to clients on the financial plans provided by PAS IARs who are associated with Pacific Advisors, to be paid to the General Agents. In addition to that override compensation, as owners of Fiscalyze, the General Agents also receive compensation directly from Fiscalyze when a PAS IAR uses the Fiscalyze tool to provide financial consulting services to a client. Thus, in the event a PAS IAR who is associated with Pacific Advisors uses Fiscalyze, these General Agents will receive two types of compensation, overrides based on the financial consulting fee and a portion of the fee that is paid to Fiscalyze for its services. Fiscalyze Subscription Based Business Financial Consulting Certain IARs are authorized by PAS to offer on-going Subscription-Based business financial consulting services utilizing Fiscalyze. The subscription arrangement will provide you with the ability to obtain ongoing financial consulting services for your business by paying an annual fee on either a monthly or quarterly basis. Your agreement will renew automatically on an annual basis unless you choose to terminate the agreement. Your IAR will provide you with analysis, recommendations, and ongoing monitoring based on the current financial situation and goals for you and your business. On an annual basis you will receive a written summary of the terms of the engagement which will include an outline of your goals, both accomplished and future, a summary of the meetings with your IAR, your fee arrangement, and a reminder of the termination option within the agreement. Listed below is an overview of the services that may be provided through the Subscription Based Business Financial Consulting Program. Included with the services is access to your IAR throughout the subscription period. A full description of each service can be found within the Subscription Based Business Financial Consulting Agreement. Personal Services  Review of Personal Financial Objectives  Personal & Family Concerns Assessment  Capital & Cash Flow Priorities Assessment  Personal & Family Inventorying and Organization of Documents  Personal Balance Sheet and Cashflow Insights  Personal Protection Insights  Personal Investment Insights  Sufficiency Insights  Personal Insights Briefing, Debriefing, and Follow-Up Coordination  An inventory of personal financial strategies which tracks progress over time Enterprise Services  Annual Review of Enterprise Financial Objectives  Enterprise Inventorying and Organization of Documents  Enterprise Concerns Assessment  Business Continuity Analysis  Enterprise Financial Performance Insights  Census-Driven Insights  Enterprise Insights Briefing, Debriefing, and Follow-Up Coordination  An inventory of enterprise financial strategies which tracks progress over time 11 (3/2024) Fiscalyze Get Organized and Take Control Financial Consulting Certain IARs are authorized by PAS to offer on-going consulting services to assist clients with organization and taking control of their finances. Your IAR will assist you with identifying the services needed, sourcing personal and business data to be analyzed and assist you with using the analysis to evaluate business risk and business decisions. In providing the Get Organized and Take Control Financial Consulting services, your IAR will also utilize the reports and services of The Advanced Practice Network LLC, doing business as Fiscalyze. Listed below is an overview of the services that may be provided through the Get Organized and Take Control Financial Consulting program. A full description of the services can be found in the Get Organized and Take Control Financial Consulting Agreement. Get Organized and Take Control Services: Essential Services  Inventory & Organization of Documents  Annual Review of Objectives  Cash Flow Analysis  Personal Balance Sheet Population  Organizing Tax Forms (Single Household/Single Entity Filings (1-2 Tax Returns Per Year)  Organizing Estate Documents (Basic Wills and Living Trusts)  Organizing Business Owners (Lifestyle Business/One Entity no Enterprise Value) Advanced Services (all of the above in addition to the following)  Organizing Tax Forms (Multiple Household/Entity filings (more than 1-2 Tax Returns across Household, Business & Trusts)  Organizing Estate Documents (Multiple/Complex Trusts such as Irrevocable, Dynastic Trusts)  Organizing Business Owners (Enterprise Business or Multiple Entities)  Annual Personal Financial Sufficiency Report and Specialist Consult You and your IAR will meet for an initial consultation at no cost. If, at the end of the initial consultation you wish to retain the services of your IAR, you will execute an agreement. By signing the agreement, you agree to pay the disclosed fee for the analysis and/or recommendations produced by your IAR. The fee is based on the service you selected, essential or advanced which includes a one-time set up fee and an ongoing annual fee that you may elect to pay monthly or quarterly. The fee range is between $250 to $25,000. Corporate Financial Education Services Certain PAS IARs can work with business clients to provide group financial education seminars for the employees of such businesses. Business Exit Consulting Certain IARs will analyze the financial situation of your business for the purpose of establishing business exit planning strategies and recommendations. Your IAR will coordinate with your accounting and legal advisors as well as other professionals you deem appropriate or that your IAR recommends. These professionals are selected, retained, and paid for by you. Any advice provided by these outside professionals is separate and distinct from the advice provided by your IAR and any fees paid to outside professionals are separate and distinct from the fee charged as part of the Business Exit Consulting Agreement. You may choose either a Comprehensive Exit Plan or a Focused Exit Plan. A Comprehensive Exit Plan is a 12 (3/2024) written action plan for accomplishing your objectives with regards to the growth of your business, the preservation and realization of maximum business value, and your ultimate departure from the business within established timelines and terms. In a Focused Exit Plan, you will select your objectives from the following list:  Business Valuation  Incentive Planning  Ownership Transfer Planning  Business Continuity Planning  Personal Wealth Management Planning  Wealth Transfer Planning Once the objectives have been established, the IAR will collect the requisite information to create the focused plan. Please note that a Focused Exit Plan cannot solely be made up of the Personal Wealth Management Planning or Wealth Transfer Planning. All of these components are more fully described within the Business Exit Consulting Client Agreement. Retirement Plan Consulting Services (Investment Advisory) PAS may enter into an agreement with an employer sponsored qualified retirement plan to provide investment advisory services to the plan. PAS, through its authorized IARs, will assist the named plan fiduciary in determining the investment lineup available to the plan's participants. Only appropriately credentialed IARs specifically approved by PAS are authorized to provide these services to plan sponsors. A summary of the services is provided below. Plan sponsors should refer to their written agreement with PAS for more details regarding the specific services to be provided as well as the fees charged. Investment Option Recommendations – The PAS IAR will analyze the list of available investment options for the qualified plan and provide the plan sponsor with a recommended list of core asset classes that, when combined, constitute an investment lineup for a qualified plan seeking a basic level of complexity. The IAR will also provide definitions of additional asset classes/categories that, when combined with core asset classes, will constitute investment lineups for those plan sponsors seeking more sophisticated levels of complexity. The IAR will identify for the plan sponsor's consideration one or more investment options from each asset class/category that are appropriate for long-term strategic asset allocations and will evaluate the investment options, including comparing their performance to appropriate benchmarks and peer group(s). The IAR will provide the plan sponsor with a "core list" of recommended investment options within each of the core asset class groups, as well as supplemental asset classes/categories and provide some general guidelines as to how many and what management type (active or passive) of investment options are appropriate to select with respect to each of the asset class groups to assist the plan sponsor in making its final investment option selections. Monitoring of Investment Options – The IAR reviews investment option performance on a quarterly basis or on such other agreed-to basis. Each investment option will be reviewed, and investment options that do not meet the identified criteria will be placed on a watch list. The placement of an investment option on the watch list does not mean that it will be recommended to be removed from the plan’s investment options lineup, but rather triggers further due diligence on the investment option. The purpose of the due diligence is to determine if the original reasons for selecting the investment option are still valid. The IAR shall provide the plan sponsor with a report summarizing its review. Once an investment option is on the watch list, it will remain on there until further due diligence indicates that it should be removed from the watch list or it is or it is recommended for removal as an investment option. To be removed from the watch list, certain qualitative and quantitative measures must be met. If, after further due diligence, the IAR determines that the investment option no longer meets the criteria for remaining on the core list, the IAR will, to the extent available on the platform, identify one or more suitable replacements for the plan sponsor to select from. Additional Provisions – PAS and its IAR will not exercise any discretion or authority regarding the plan sponsor's 13 (3/2024) selection of the specific securities, mutual funds, institutional funds, or funds available through group annuity contracts and mutual funds that may be eligible investment options under the qualified plan. Furthermore, neither the IAR nor PAS will have any discretion over plan assets in any capacity. It is the sole responsibility of the plan sponsor or named fiduciary to review, approve and implement the recommendation of the IAR for the following items:  the investment policy statement for the qualified plan.  the selection and retention of service providers (e.g., (without limitation) investment provider(s), investment managers and advisers, a plan record-keeper and a third-party administrator). It is also the plan sponsor or named fiduciary’s sole responsibility to supervise the performance of such providers.  the determination of the appropriate mix and number of asset classes to be included in the investment options available under the qualified plan.  to the selection of the specific mutual funds, institutional funds, or funds available through group annuity contracts that will be investment options under the qualified plan. If a qualified plan contains a company stock or self-directed brokerage investment option, the IAR shall not be required to take such investment options into account with respect to its determinations or recommendations. The plan sponsor shall retain sole fiduciary responsibility with respect to such company stock or self-directed brokerage option. The plan sponsor will agree to review at least annually and to advise the IAR of any changes in the investment options that may be available under the qualified plan or any changes to the demographic or other information previously provided to the IAR regarding the qualified plan. In providing these services to plan sponsors, PAS and its IARs must utilize the software and other tools provided by Envestnet Retirement Solutions, LLC (“ERS”). PAS, its affiliates and IARs are not affiliated with or under common ownership, control, or operation with ERS. PAS agreements with plan sponsors for plan investment advisory services do not include services provided by other PAS IARs, who may work separately with plan participants in their individual capacity, including the provision of advice regarding rollovers. This Brochure also constitutes the disclosure required to be provided to plan sponsors under the regulations promulgated by the United States Department of Labor pursuant to Section 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The fee charged for these services and other important information relating to the fees for the investment advisory services shall be contained within the Plan Services Agreement for Investment Advisory Services under Section 3(21) of ERISA (“Plan Services Agreement”). Please see the section entitled “ERISA Section 408(b)(2) Disclosure to Responsible Plan Fiduciaries of ERISA-Covered Qualified Retirement Plans” later in this Brochure for further information. In addition to the program described above, in limited circumstances, certain PAS IARs may enter into joint work arrangements whereby such professionals refer plans to other PAS IARs who are credentialed to provide such plan investment advisory services. In such instances, the credentialed IAR will serve as the primary client contact. The referring IAR may receive initial and ongoing compensation for the referral. Please contact your IAR for more details. Investment Advice to Retirement Plan Participants Certain IARs are authorized by PAS to offer investment advice to participants of ERISA retirement plans. These services will consider aspects of your financial circumstances and the investment options allowed and selected by the retirement plan fiduciary for use by its participants. At the beginning of the relationship your IAR will provide you with the Retirement Plan Participant Investment Advice Client Agreement, which will detail the terms and conditions pertaining to the services, including the fee. In addition, you will be required to complete a risk tolerance questionnaire. Upon completion and review of a risk tolerance questionnaire, your IAR will provide you with a recommendation regarding the selection of your investment options and allocation of your plan assets best suited to your goals and risk tolerance. On at least a semi-annual basis, your IAR will develop and provide you with a report, detailing investment recommendations which shall be limited to the investments available within your retirement plan investment line up selected by the 14 (3/2024) retirement plan fiduciary. Retirement Plan Services (Non-Investment Advisory) PAS may enter into an agreement with an employer sponsored qualified retirement plan to provide certain non- investment advisory services to the plan. The PAS IAR will assist in assessing, analyzing, and addressing the needs of the plan. Below are the services made available to the plan sponsor and/or the plan participants. Plan Governance and Committee Education  Reviewing retirement plan committee structure and requirements  Assisting plan sponsor to determine plan objectives  Reviewing participant education and communication strategy  Assisting with responding to participant requests for additional information. Assisting the plan sponsor to develop and maintain a fiduciary audit file  Coordination of data and plan design with the designated third-party administrator Plan Service Provider Selection/Review and Vendor Management  Assisting plan sponsor with his/her determination of the appropriate funding vehicle for the Plan  Providing periodic benchmarking of fees and services to assist review for reasonableness  Assisting the plan sponsor to generate and evaluate service provider requests for proposals (RFPs) and/or requests for information (RFIs)  Assistance with service provider transition and/or plan conversion Services to be provided to the Plan Participants: Employee Investment Education and Communication  Providing group enrollment and investment education meetings for employees  Providing periodic updates, upon request or via newsletter  Assisting participants with retirement readiness PAS Proprietary Investment Advisory Programs PAS is the sponsor of the PAS Proprietary Programs. PAS Proprietary Programs offer a range of investment strategies, from conservative to ultra-aggressive growth. The following description applies to all PAS Proprietary Programs other than VestWiseTM, the digital advisory program offered by PAS. An IAR will analyze your individual financial situation and make recommendations as to an appropriate program based on your individual needs and investment objectives. Prior to funding a PAS Proprietary Program account, your PAS IAR will help you complete an account application, a client questionnaire and/or other forms in order to determine your investment objectives and risk tolerance, also known as the Investor Risk Rating. The Investor Risk Rating is the level of risk a client is willing to take with their investments based upon questions asked within the client questionnaire. Your IAR will provide you with recommendations in the form of a proposal (“Proposal”) based on the information you provide. Your Proposal includes your recommended PAS Proprietary Program, which may include load-waived and no-load mutual funds, exchange- traded funds (“ETFs”), closed-end funds, stocks, and bonds as well as separately managed accounts. PAS Proprietary Programs include both discretionary and non-discretionary programs. In a discretionary program, PAS (for VestWiseTM), your IAR (for Park Avenue Signature PortfolioSM) or the applicable third- party strategist, investment manager, or overlay manager (in all other discretionary Proprietary Programs), manages your assets within the parameters of the program and model portfolio you select. Each discretionary Proprietary Program also allows PAS, the applicable IAR, strategist, investment or overlay manager to place trades for your account at its discretion without requiring your prior approval. This gives PAS, the applicable IAR, strategist, investment or overlay manager the authority to determine, without obtaining your specific consent, the securities 15 (3/2024) to be bought or sold, and the amount of the securities to be bought or sold for your account. In a discretionary program, you have the ability to impose any reasonable restrictions or modify any existing restrictions on the management of your account. The non-discretionary Proprietary Program Park Avenue Portfolio SelectSM has been designed to give you, the client, flexibility to use your account as you deem appropriate within certain prescribed limits. Your IAR shall make recommendations for portfolio transactions within the parameters of your strategy and within but not exceeding, your Investor Risk Rating, and must obtain your permission prior to effecting any transactions in your account. For all PAS Proprietary Programs, either PAS or your IAR is available on an ongoing basis to assist you in evaluating your portfolio strategy and asset allocation. Your IAR will provide you with advice and guidance that is based on the information you provide at the time you open your PAS Proprietary Program account and as you update or amend it from time to time. To assist you in managing your account assets, PAS will provide you with:  Periodic performance reports showing the performance of your PAS Proprietary Program account assets; and  Opportunities for you to engage in periodic account reviews with your IAR to address progress toward asset allocation and your investment objectives. You may transfer securities from outside accounts into your PAS Proprietary Program account; however, your IAR may recommend that you sell some or all of the securities if he or she believes that holding such securities is not appropriate for the current recommended investment strategy. Any securities held in your account that are classified as Unsupervised Assets are not managed by PAS or your IAR. These may include securities transferred into your PAS Proprietary Program account from outside accounts that your IAR has identified to you as not appropriate for your current investment strategy for the particular account. These assets may remain in the account at your discretion but shall be classified as Unsupervised. Unsupervised Assets are not included in the periodic performance reports for your PAS Proprietary Program account. PAS and your IAR do not provide investment advisory services of any kind with regard to Unsupervised Assets, do not charge an advisory fee on such assets and do not have any responsibility with respect to the management of any holdings classified as Unsupervised Assets. PAS, your IAR, Strategist or Investment Manager do not consider Unsupervised Assets when providing investment advice for your PAS Proprietary Program account. Your account can be managed in a tax-sensitive manner; however, neither PAS nor your IAR may provide tax advice or tax management services. You are responsible for any taxable events in all instances. You should always consult with your tax advisor for specific tax advice. Envestnet Asset Management, Inc. PAS has contracted with Envestnet Asset Management, Inc. (“Envestnet”), an SEC registered investment adviser, to provide a technology structure for PAS and its clients through Proprietary Programs other than VestWiseTM to efficiently connect with third-party asset managers referred to as Investment Managers or Strategists and to act in some Programs as co-adviser to clients. Envestnet provides overlay management services on a discretionary basis administering model portfolios developed by the Investment Manager or Strategist and taking directions from the Investment Manager or Strategist to adjust asset allocations, add, remove, or replace securities in the account, and rebalance the account as it deems necessary. Envestnet also provides advice related to program design and support, including the structure and design of asset allocation portfolios and underlying investment research on Separately Managed Accounts (“SMAs,” which are portfolios of individually owned securities managed by an asset manager), mutual funds, and Exchange- Traded Funds (“ETFs”) that may be available within certain of the PAS Proprietary Programs. However, Envestnet is not responsible for the specific investment choices made with respect to the portfolios developed and maintained by the Strategist or Investment Manager. The IAR in consultation with their client is required to fill out a client questionnaire. Once the client questionnaire is completed, Envestnet will be responsible for determining the suggested target asset mix. 16 (3/2024) For all PAS Proprietary Programs, you have the ability to impose any reasonable restrictions or modify any existing restrictions on the management of your account. Clients may impose new, or change any existing, investment restrictions at any time by contacting their IAR. The following is a description of each of the PAS Proprietary Programs: Park Avenue Portfolio SelectSM Program  The Park Avenue Portfolio SelectSM program is a non-discretionary program where your selected IAR advises and may recommend to you various investment vehicles, such as mutual funds, ETFs, stocks, and bonds, in accordance with your investment objectives and Investor Risk Rating, utilizing model portfolios for a range of investment objectives. Although your IAR will furnish you with advice and guidance, all transactions in your Park Avenue Portfolio SelectSM account will take place only upon your specific approval. You assume full responsibility for all trading decisions.  Based upon your investment objectives, your IAR will recommend a model portfolio that is constructed with a variety of investments to fulfill your recommended strategic risk/return strategy. When building your portfolio, your IAR may recommend investments from a wide array of investment options, including mutual funds, ETFs, equity securities, exchange-listed securities, over-the-counter securities, securities of foreign issuers (including American Depository Receipts (“ADRs”), European Depository Receipts (“EDRs”), and Global Depository Receipts (“GDRs”), corporate debt, commercial paper, certificates of deposit, United States government securities, and municipal securities. You are under no obligation to accept such recommendations or to authorize transactions through PAS or the IAR. A mutual fund-only option is also available under the program. Any purchase or sale of securities in your account may cause the account to vary from your initial asset allocation and investment objectives.  Client-Initiated Transactions – You may request your IAR to execute transactions that are initiated solely by you without a recommendation from your IAR (client-initiated transactions). These client-initiated transactions are solely your responsibility. PAS will not be responsible for the performance of these client-initiated transactions; however, PAS will include such assets in the Total Client Fee calculation. The advice of your IAR is a key service of the Park Avenue Portfolio SelectSM program. A pattern of client-initiated transactions may indicate that this program is no longer appropriate for you as you would not be utilizing the advice of your IAR.  If you have completed a client-initiated transaction and have acquired a security without the advice of your IAR, so long as you hold the position in your Park Avenue Portfolio SelectSM account, PAS will take that asset into consideration: - as part of the overall account assets; - when PAS gives you periodic asset allocation advice; - when PAS values your account holdings; and - when PAS provides analyses and reports on the account’s performance.  PAS may also recommend that you consider selling the asset if, and when PAS deems it appropriate. Park Avenue Portfolio Select typically assesses ticket charges to clients for the purchase and sale of certain securities in a client’s account. The ticket charges are retained by PAS and are not shared with your IAR. IARs may elect to pay the ticket charges on a client’s behalf. Park Avenue Portfolio Select clients should understand that their IAR may elect to pay ticket charges for the accounts of some but not all of their clients. If your IAR elects to pay your ticket charges, you should understand that the annual fee you pay may be higher than what you would otherwise pay if your IAR did not elect to pay ticket charges for your account, and your IAR may have a financial incentive to trade less for your account. Clients who choose to open a Park Avenue Portfolio Select account should carefully consider these factors and discuss the costs and benefits of whether they or their advisor should pay ticket charges. 17 (3/2024) PAS Wrap Fee Programs FoundationsSM, Quantitative InnovationsSM, Park Avenue Strategist SelectSM, Park Avenue Strategist Select PlusSM, Park Avenue Separately Managed Account SelectSM, Park Avenue Unified Managed Account Select℠, Park Avenue Signature PortfolioSM and VestWiseTM are PAS wrap fee programs. Under a wrap fee program, you pay a single asset-based fee for investment advisory services and execution of your transactions. Unless otherwise noted, administrative and investment advisory fees, along with transaction fees, are “wrapped” into one comprehensive fee, which is paid quarterly. A portion of the wrap fee is used to pay PAS and your IAR for investment advisory services. Wrap fee program portfolio managers may employ “trading away” practices, in which they use a broker other than PAS to execute trades for which a commission or other transaction-based fee is charged, in addition to the wrap fee. Although transaction fees are usually included in the wrap program fee, sometimes you will pay an additional transaction fee for investments bought and sold outside the wrap fee program. For more information regarding trade away practices, please go to www.parkavenuesecurities.com. Each PAS wrap fee program has its own Wrap Fee Brochure which describes in detail the investment options and services for each program. To obtain a Wrap Fee Brochure for one of the programs listed, please request the brochure from your IAR or call PAS at (800) 600-4667. Below is a brief description of each PAS wrap fee program. FoundationsSM and Quantitative InnovationsSM Programs The Foundations and Quantitative Innovations programs are discretionary investment advisory programs sponsored by PAS that provide clients with access to model portfolios managed by Integrated Capital Management, Inc. (“iCM”), a third-party investment manager that has been retained by Envestnet Asset Management, Inc. (“Envestnet”). Envestnet provides overlay management of the iCM investment models by performing administrative and trading services, such as directing the rebalancing of the portfolios invested in the models. By executing the Client Agreement (which includes the Statement of Investment Selection), you grant Envestnet the discretionary authority to invest, reinvest, and otherwise rebalance your account assets at Envestnet’s discretion. Model portfolios are created and managed by iCM, which allocates the portfolios across investment asset classes to create a blend that fits your investment objectives and Investor Risk Rating. Envestnet performs administrative and/or trading duties at the direction of iCM via a licensing agreement between Envestnet and iCM. The portfolios are managed pursuant to one of the model portfolios created and maintained by iCM in a single account allocated among different mutual funds and/or ETFs. iCM provides ongoing management that includes the ability to adjust asset allocations, add, remove, or replace securities in the account, and rebalance the account as it deems necessary. The Foundations program consists of mutual fund only portfolios (both standard and tax-sensitive), representing various investment styles and asset classes. The Quantitative Innovations program utilizes diversified model portfolios (both standard and tax-sensitive), composed of selected mutual funds and ETFs representing various investment styles and asset classes. iCM will continually monitor the portfolios, and at times make adjustments to the asset class percentages of the models as well as to the mutual fund and ETF allocations within each asset class in each model portfolio. The programs employ multiple model portfolios which are designed to reflect risk and volatility levels that range from conservative to ultra-aggressive. Park Avenue Strategist SelectSM and Park Avenue Strategist Select PlusSM Programs The Park Avenue Strategist Select and Strategist Select Plus programs are discretionary investment advisory programs sponsored by PAS that provide clients with access to third-party investment advisory firms, referred to as Strategists, that have been retained by Envestnet. These programs offer single asset allocation portfolios created and managed by the Strategist using mutual funds and ETFs. Envestnet provides overlay management of the investment models developed and maintained by the Strategist by performing administrative and trading services, such as directing the rebalance of the portfolios invested in the models. The Park Avenue Strategist Select Plus program offers additional Strategists that use individual securities in separately managed accounts as well as mutual funds and ETFs to create portfolios. 18 (3/2024) Park Avenue Separately Managed Account SelectSM Program (SMA Select) The SMA Select Program is a discretionary investment advisory program sponsored by PAS that provides clients with access to the investment strategies of third-party investment managers and advisory firms referred to as Investment Managers that have been retained by Envestnet. Envestnet provides SMA Select Program clients with the ability to access one or more Investment Managers, either directly using a separately managed account for each Investment Manager where the Investment Manager trades directly for the account or indirectly through the use of an investment strategy model created and maintained by the selected Investment Manager but administered by Envestnet by providing overlay management of the investment models through the performance of administrative and trading services. An SMA Select Program account will contain one Investment Managers’ held in a separate custodial account. Park Avenue Unified Managed Account SelectSM Program (UMA Select) The UMA Select Program is a discretionary investment advisory program sponsored by PAS that provides clients with access to the investment strategies of third-party investment managers and advisory firms, referred to as Investment Managers, that have been retained by Envestnet. The UMA Select Program provides recommended asset allocation models which consist of asset allocation targets or sleeves across various asset classes and investment strategies. Based upon your investment objectives and Investor Risk Rating, your IAR will recommend Investment Manager(s) who may invest in mutual funds, ETFs, as well as individual stocks and bonds to fulfill your asset allocation targets based on the risk/return strategy. Your IAR may also recommend a Strategist portfolio from the Strategist Select/Strategist Select Plus program to populate an asset allocation sleeve. You will complete the UMA Select Program account by selecting which Investment Manager strategies to populate within each asset allocation sleeve. Envestnet acts as the overlay manager and administers the UMA Select Program by implementing the model portfolios provided and maintained by the individual Investment Manager(s) selected (an “Investment Model”) by you. An UMA Select Program account may contain one or multiple Investment Models investing in different asset classes according to the selected portfolio allocation strategy. The UMA Select Program account may also contain mutual funds, ETFs, individual stocks, bonds, or strategist model portfolios to complete the strategy. The securities within the selected Investment Models, as well as any mutual funds, ETFs, or individual stocks and bonds outside of the Investment Models, will be held in a single custodial account. Your IAR has the ability to make

changes to the Program Account within your Investor Risk Rating and upon your approval by removing or replacing one Investment Manager with another. By executing the Client Agreement, you grant Envestnet the authority to buy and sell securities and investments for the account pursuant to the direction of the Investment Manager and perform rebalancing or other such discretionary authorities you agree upon. In certain cases, the Investment Manager may directly trade client assets within the UMA Select Program instead of providing an Investment Model to Envestnet. In those instances, Envestnet shall be authorized to delegate the investment discretion described above to the Investment Manager. Park Avenue Signature PortfolioSM Program The Signature Portfolio Program is a discretionary investment advisory program whereby investment management services and advice are offered on a fully discretionary basis through the PAS IAR you select. You authorize PAS through your IAR to purchase and sell securities according to your investment objectives on a discretionary basis. Based upon your investment objectives and Investor Risk Rating, your IAR will build a model portfolio that is constructed with a variety of investments to fulfill your risk/return strategy. When building your portfolio, your IAR may select investments from a wide array of investment options, including mutual funds, ETFs, equity securities, exchange-listed securities, over-the-counter securities, securities of foreign issuers (including American Depository Receipts (“ADRs”), European Depository Receipts (“EDRs”), and Global Depository Receipts (“GDRs”), corporate debt, commercial paper, certificates of deposit, United States government securities, and municipal securities. Your IAR will have your permission to buy or sell securities, in quantity, price and at the time that your IAR sees fit without your prior consent in accordance with the investment 19 (3/2024) objectives selected by you. Any purchase or sale of securities in your account may cause the account to vary from your initial asset allocation and investment objectives. Envestnet performs administrative and/or trading duties at the direction of your PAS IAR via a licensing agreement between PAS and Envestnet. VestWiseTM VestWise™ is the branded name for the PAS automated or digital (i.e., internet/web-based) investment advisory solution. The VestWise program consists of Model Portfolios whose underlying holdings consist of a series of individual Exchange Traded Funds, (“ETFs”). Franklin Advisers, Inc. (“Franklin Advisers”), an investment adviser registered with the SEC, provides PAS with the Model Portfolios for the VestWise program, which are periodically updated by Franklin Advisers acting in the role of a “Model Provider.” PAS acts as the sponsor and the discretionary investment manager for this program, which means PAS is provided the authority to manage the securities held in your VestWise account without seeking prior trading approval from you. If you elect the recommended VestWise strategy (“Model Portfolio”) and open an account, PAS uses this discretion to make changes to the holdings within the account over time consistent with the selected Model Portfolio. The technology platform being utilized by PAS to provide the VestWise program is offered by AdvisorEngine, an affiliate of Franklin Advisors. PAS pays AdvisorEngine an annual technology fee that is calculated based on the assets under management on the platform. The VestWise program is intended to be a hybrid of a digital adviser (i.e., internet/web-based adviser) and a traditional human adviser. Your IAR will be available to assist you with the following:  Reviewing the Model Portfolio VestWise has recommended for you; and  Providing you with advice and guidance, upon your request, based on the information provided at the time you opened your VestWise account and as you update or amend it from time to time. PAS will provide you with:  Discretionary investment management of your VestWise account;  Periodic performance reports showing the performance of VestWise account assets;  Opportunities for you to engage in periodic account reviews to address progress toward your investment objectives and goals for the account; and  Automated quarterly rebalancing at the end of each calendar quarter using rebalancing rules established by PAS. Lending Services Non-Purpose Loan Program You may apply for a non-purpose loan from Pershing LLC through the PAS Non-Purpose Loan Program using an eligible securities account as collateral. These eligible securities accounts may include one or more of your PAS Proprietary Program accounts. In order for PAS Proprietary Program accounts to be eligible to serve as collateral for a non-purpose loan, the account may not serve as collateral for any margin lending or reinvestment into any securities or insurance products. You will be required to open a brokerage account to support the loan and will receive a separate statement for this account. If you participate in the Non-Purpose Loan Program, you will pay interest to Pershing LLC and PAS on the loan value in addition to any Program advisory fees charged in the PAS Proprietary Program account being used as collateral. PAS IARs do not receive any portion of the interest paid by clients for non-purpose loans. Securities Based Line of Credit (“SBLOC”) through Tri-State Capital Bank (“Tri-State”) You may apply for a Securities Based Line of Credit (“SBLOC”) from Tri-State using an eligible securities account as collateral. These eligible securities accounts may include one or more of your PAS Proprietary 20 (3/2024) Program accounts. In order for PAS Proprietary Program accounts to be eligible to serve as collateral for a non- purpose loan, the account may not serve as collateral for any margin lending or reinvestment into any securities or insurance products. If you participate in SBLOC, you will pay interest to Tri-State and PAS on the loan value in addition to any Program advisory fees charged in the PAS Proprietary Program account being used as collateral. PAS IARs do not receive any portion of the interest paid by clients for non-purpose loans. Investment Credit Line High net worth investors may apply for the BNY Mellon, N.A. Investment Credit Line program (ICL), a flexible line of credit that provides liquidity for personal or business needs. The ICL is secured by qualifying liquid assets held in your investment account(s) custodied at Pershing, LLC. Many forms of collateral are accepted, such as bonds, domestic equities, mutual funds, and government securities. The minimum credit line size is $1,000,000 requiring assets valued at least $1,500,000 in Pershing accounts. Interest is paid only on the funds borrowed. For additional information about this program speak with your IAR. Mortgage Program High net worth clients may apply for mortgage programs provided by BNY Mellon, N.A. The minimum loan amount is $500,000. Qualified borrowers may borrow up to 100% of the home’s value by pledging qualifying assets held in accounts at Pershing, LLC in lieu of a cash down payment. Financing may be used for the purchase of single-family, primary and vacation homes, condos, and co-ops but not investment properties. For additional information about this program speak with your IAR. Important Considerations relating to Lending Services In certain circumstances, your IAR may recommend, and PAS may approve Lending Services in your advisory account. Your IAR will benefit from recommending Lending Services because you do not have to liquidate assets in your account to pay for items with cash, which would diminish the assets held in the account and the potential fees and commissions that could be earned by your IAR from holding or engaging in future transactions with those assets. For example, with a fee-based account, by recommending a Non-Purpose loan to fund some purchase or financial need rather than liquidate securities, PAS and your IAR continue to earn fees on the full account value. PAS will also receive a portion of the loan interest when you participate in the Pershing Non-Purpose Loan and / or the Tri-State SBLOC Programs. Furthermore, there are conflicts of interest associated with the various lending programs as PAS does not earn interest on the Investment Credit Line, therefore creating an incentive to recommend the Pershing and/or Tri-State lending programs in which PAS does share in the interest payments with the lender but which may have higher interest rates than the Investment Credit Line program. You may also seek lending services using your advisory account as collateral through third- party banks which do not have a relationship with PAS and which may offer more competitive interest rates. You must meet certain eligibility requirements and complete loan documentation prior to applying for Lending Services. Specifically, you will be required to execute loan documents with Pershing and/or BNY Mellon depending on the Lending Services being sought. Funds borrowed and proceeds from any recommended Lending Service may not be used to purchase securities or fund brokerage accounts. The decision to use PAS Proprietary Program account assets as collateral rests with you and should only be made if you understand:  the risks of borrowing and the impact of the use of borrowed funds on advisory accounts; 21 (3/2024)  how the use of loans may affect your ability to achieve investment objectives;  the risk that you may lose more than your original investment; and  the possibility you may not benefit from collateralizing your account for a loan in a Program account if the performance of your account does not exceed the interest expense being charged on the loan plus the additional advisory fees incurred by your account as a result of the deposit of the loan proceeds. Due to the fact your PAS Proprietary Program account will be pledged to support any loans extended under the lending services program; you will not be permitted to withdraw any of the assets from the account unless there is a sufficient amount of collateral otherwise supporting the loan (as determined by PAS, Tri-State, or Pershing in their sole discretion). If the market value of the collateralized account depreciates, you may be required to deposit additional funds. Failure to promptly meet a request for additional collateral or repayment or other circumstances (e.g., a rapidly declining market) could cause PAS, in our discretion, to liquidate some or all of the collateral account(s) to meet the loan requirements. Depending on market circumstances, the prices obtained for the securities may be less than favorable. Any required liquidations may disrupt your long-term investment strategies and may result in adverse tax consequences. PAS does not provide legal or tax advice; you should consult your legal and tax advisors regarding the legal and tax implications of borrowing and using securities as collateral for a loan. You are personally responsible for repaying the loan in full, even if the value of the collateral is insufficient. Neither PAS nor its IARs will act as investment adviser to you with respect to the liquidation of securities held in a PAS Proprietary Program account to meet a loan demand. Those liquidations will be executed in PAS’ capacity as broker- dealer and creditor and may, as permitted by law, result in executions on a principal basis in your account. In addition, as creditors, PAS may have interests that are adverse to your interests. Additional limitations and availability may vary by state. Defaults – Non-purpose loans, SBLOC, investment credit lines and the 100% financing mortgage option are full recourse, demand loans and clients with collateralized loan accounts may need to deposit additional cash or collateral or repay part or all of the loan if the value of the portfolio declines below the required loan-to-value ratio. Repayment may be demanded at any time. There are substantial risks associated with the use of securities as collateral for a loan. For further information, clients should carefully read the application and disclosure information provided for the program selected. Margin Loans A margin loan is created when you borrow funds from your account using your security investments as collateral to purchase additional securities or withdraw funds. Not all securities are eligible to be used for collateral (considered “marginable”) and not all customers are eligible for a margin loan. When a margin loan is created, accounts are charged interest on the loan amount in addition to other fees in your account. The interest is charged by PAS’ clearing firm Pershing LLC with rates based upon the Federal Funds Target Rate, plus an additional percentage charge depending on the size of the loan. The additional percentage charge above the Federal Funds Target Rate may be as high as 8%. PAS will retain a portion of the additional percentage rate charged above the Federal Funds Target Rate. Margin loans can increase potential losses. As previously stated, marginable investments in a portfolio provide the collateral for a margin loan. While the value of that collateral fluctuates according to the market, the amount borrowed stays the same or will increase due to interest charged. If the value of the margined securities decline to the point where they no longer meet the minimum equity requirements for the margin loan, there will be a margin call. When this happens, PAS or Pershing LLC will request that more cash or marginable securities be deposited into the account to meet the minimum equity requirement and satisfy the margin call. Failure to meet a request for additional cash or securities deposit could cause PAS or Pershing, at their discretion, to liquidate 22 (3/2024) some or all of the securities in your account to satisfy the margin call. Various risks are associated with margin loans. Clients should carefully review disclosures regarding risks, fees, and other considerations appearing in margin account agreements prior to establishing a margin loan. Important Considerations Relating to Margin Loans PAS will earn revenue on margin loan interest. This revenue, which increases based on the amount of the margin loan held in your account, represents a conflict of interest as PAS has a financial incentive to recommend or maintain a margin loan. This compensation is retained by PAS and is not shared with your IAR however, your IAR has a conflict when recommending a margin loan as it will maintain or increase the assets under management within the account which is the basis of the overall advisory fee paid to your advisor. This conflict occurs because your advisory fee is based on the total market value of the securities and cash balances in your account. When initially creating a margin loan, the total market value of your account will either increase if additional securities are purchased to create the loan or, be retained if a withdrawal is taken to create the loan. Alternative Investments and Institutional Capital Network, Inc. PAS has contracted with Institutional Capital Network, Inc. (“iCapital”) to utilize iCapital’s alternative investment technology platform. iCapital and its affiliates receive asset based and other fees for providing advisory and other services to the alternative investments that they issue and/or manage, including alternative investments made available through its platform. iCapital therefore, will have an incentive to include one or more affiliated alternative investments through the platform. The alternative investments offered by PAS issue multiple share classes to investors. The share classes offered in PAS advisory programs will contain no up-front sales charges or ongoing distribution and/or servicing fees payable to PAS. Customers that agree to invest in an alternative investment will be subject to the eligibility requirements of the issuer; details of such eligibility requirements may be found in the product prospectus or offering documents. The Alternative investments offered in PAS advisory programs require investors to qualify as a Qualified Purchaser or an Accredited Investor. Your IAR will review and verify your qualification status prior to any purchase of an alternative investment in your account. Certain PAS IARs are granted access to the iCapital platform whose alternative investments may be purchased in the PAS Signature Portfolio and Portfolio Select programs. Only PAS approved alternative investments may be purchased in the program which include Private Equity, Private Credit, Real Estate, and Hedge funds. PAS makes available alternative investment funds issued by HPS Investment Partners, LLC (“HPS”). PAS’ parent company, The Guardian Life Insurance Company of America (“GLIC”), owns a minority stake in HPS. This minority ownership creates a conflict as customer investments into HPS funds positively impacts GLIC’s investment in HPS. Neither PAS nor GLIC will share profits from GLIC’s HPS investment with your IAR therefore, your IAR does not have a financial incentive to recommend an HPS product. Common Risks Associated with Alternative Investments Alternative investments, which are generally defined as anything other than traditional stock or bonds and not traded on an exchange or a public market, often referred to as private markets, involve a higher degree of risk and complexity than traditional investments. As such, alternative investments are not suitable for all investors. A prospectus or offering document that discloses all risks, fees and expenses, and risk factors associated with a particular alternative investment may be obtained from your IAR and must be read carefully before investing. 23 (3/2024) Investments in alternatives investment strategies can expose you to certain specific risks. The following is a non- exhaustive list of the risks and considerations associated with alternative investments:  Transparency: Alternative investments may not offer the same level of transparency as traditional investments which are required to provide frequent and full disclosure;  Liquidity: Alternative Investment are highly illiquid and are difficult to sell or be transferred. You may not be able to redeem your investment for an extended period;  Fees: Alternative investment fees are generally higher than those associated with traditional investments;  Valuation: Alternative Investment are highly illiquid and are difficult to sell or be transferred. If your IAR purchases an Alternative Investment for your account, it will be included for purposes of calculating PAS’ advisory fee. PAS relies on the issuer and Pershing to provide a good faith, fair market value. The timing and process for fair market valuation of Alternative Investments is not as reliable as valuations of publicly traded securities. Depending on the size of the fee and the market value of the Alternative Investment over the life of the investment, PAS and your IAR could earn more revenue than if the same investment was held in a brokerage account or directly with the issuer. Therefore, to earn these ongoing advisory fees, PAS and your IAR have an incentive to recommend that you purchase interests through your advisory account instead of in a brokerage account.  Investment strategies which may be employed by Alternative Investments: o Concentration: Alternative investment strategies may be highly concentrated in a few funds or holdings. o Leverage: The use of borrowing (leverage) exposes an investor to additional levels of risk including greater losses from investments than would otherwise have been the case without borrowing; margin calls or changes in margin requirements may force premature liquidations of investments; and losses on investments where the investment fails to earn a return that equals or exceeds the cost of the leverage. o Lack of diversification: The portfolio may not generally be as diversified as other investment vehicles. Accordingly, investments may be subject to more rapid change in value than would be the case if the portfolio were required to maintain a wide diversification among types of securities, geographical areas, issuers and industries. Accordingly, a loss in a single position could have a materially adverse impact on a portfolio. o Event-driven trading: Event-driven trading involves the risk that the event identified may not occur as anticipated or may not have the anticipated effect, which may result in a negative impact upon the market price of securities held in the portfolio. Donor-Advised Funds A donor-advised fund (DAF) works like a charitable investment account, for the sole purpose of supporting charitable organizations you care about. The DAF is a separately identified account that is maintained and operated by a sponsoring 501(c)(3) charitable organization. When you contribute cash, securities, or other assets to a DAF you are generally eligible to take an immediate tax deduction. Then those funds can be invested for tax-free growth and you can recommend grants to virtually any IRS-qualified public charity. Once the donor makes the contribution, the sponsoring organization has legal control over it. However, the donor retains privileges with respect to the distribution of funds and the investment of assets in the account. Through Pershing, PAS makes available three DAF options. American Endowment Foundation and Renaissance Charitable Foundation both allow clients to select their IARs to manage their charitable assets in accounts custodied at Pershing. The BNY Mellon Charitable Gift Fund offers various investment strategies through the fund’s investment manager, BNY Mellon, N.A. Each DAF sponsor provides donor support services and a portal that enables clients to recommend grants and view fund activity history. The American Endowment Foundation and Renaissance Charitable Foundation Funds are for clients who wish to make a charitable contribution but continue working with their PAS IAR to manage contributed assets in accounts held at Pershing. These accounts will be invested in either the Park Avenue Strategist Select Program or the Strategist Select Plus Program. PAS and the IAR will receive advisory fees from accounts invested in these Programs as described within the Statement of Investment Selection. 24 (3/2024) If the donor selects the BNY Mellon Charitable Gift Fund, the donor can choose from several investment options using BNY Mellon N.A. as investment manager and the assets are custodied away from Pershing. The Gift Fund offers five diversified investment strategies and a cash reserve option. The PAS IAR will not act in the capacity of Authorized Representative on the account and neither PAS nor the IAR will receive any compensation from this arrangement. The donor advised fund options pose a conflict of interest in that IARs have an incentive to recommend the DAF which pays advisory fees to the IAR over the option with no compensation. Third-Party Investment Advisory Programs PAS offers various Third-Party Investment Advisory Programs in which PAS, unless otherwise noted, acts as a solicitor for an unaffiliated Third-Party Investment Adviser (each, a “Third-Party Investment Adviser”) and receives a fee. In these programs, you will sign an investment advisory agreement directly with the Third- Party Investment Adviser or a tri-party agreement which shall include both PAS and the Third-Party Investment Adviser. Your IAR will provide you with the Third-Party Investment Adviser’s Form ADV Part 2, which you are encouraged to review as it contains important information such as the program fees and expenses and any conflicts of interest of the Third-Party Investment Adviser which may exist. Following the approval of your application, the Third-Party Investment Adviser shall allocate your funds in accordance with the model portfolio you select. Depending upon the program, the Third-Party Investment Adviser shall provide one or more of the following: (i) construct model portfolios with various investment objectives; (ii) select and monitor mutual funds, ETFs, money managers and/or other securities as permitted, for inclusion in the program; and (iii) allocate, manage and, in some programs, rebalance assets in accordance with the model portfolio selected. Please be aware that similar to any type of securities investing, when investing in a model portfolio developed by a Third- Party Investment Adviser, there is no assurance that your investment objectives will be achieved. In its role as a solicitor, your IAR will work with you to select an appropriate Third-Party Investment Advisory Program based on a number of factors, including but not limited to your financial needs, preferences, and cost. Once you have selected a Third-Party Investment Advisory Program, your IAR will gather information about your investment objectives, risk tolerance and other pertinent information through a client questionnaire typically provided by the Third-Party Investment Adviser to assist you in the selection of a model portfolio. You may accept or reject your IAR’s recommendation of a Third-Party Investment Advisory Program or model portfolio. Your IAR will answer all questions about the program and the Third-Party Investment Adviser and will educate you about the features, advantages, disadvantages, risks, and costs associated with the Third-Party Investment Advisory Program selected. Your IAR will also assist you in completing the application and paperwork required by the Third-Party Investment Adviser and shall initiate the steps necessary for your participation in the Third- Party Investment Advisory Program. Your IAR will forward to PAS all account opening documentation and information, including any reasonable investment restrictions requested by you. PAS will then forward such documentation to the Third-Party Investment Adviser for review and approval. The Third-Party Investment Adviser is solely responsible for reviewing, accepting, or rejecting and implementing any reasonable investment restrictions imposed by you. If you have granted the Third-Party Investment Adviser discretion under an applicable Third-Party Investment Advisory Program, you have the ability to add or modify any previously requested investment restrictions imposed on the Third-Party Investment Adviser. Your IAR, on an ongoing basis, shall review and discuss your participation in the Third-Party Investment Advisory Program(s) and model portfolio(s) and shall communicate changes in your financial situation to the Third-Party Investment Adviser, as necessary. PAS will forward any updated information it receives from you to the Third-Party Investment Adviser for review and assist you in making any appropriate changes to your account, if necessary. PAS does not serve as a broker-dealer for your Third-Party Investment Advisory Program account and does not place trades in connection with the securities held in your account. 25 (3/2024) Securities-Backed Lines of Credit Offered Through Third-Party Investment Advisory Programs You may be eligible to use your Third-Party Investment Advisory Program account as collateral for a Securities- Based Line of Credit (“SBLOC”). If you participate in an SBLOC program, you will pay interest to on the loan value in addition to any advisory fees charged in the Third-Party Investment Advisory Program account being used as collateral. Neither PAS nor its IARs receive any portion of the interest paid by clients for SBLOC services. To determine if your Third-Party Investment Advisory Program account is eligible for SBLOC services, please consult with your PAS IAR. Important Considerations relating to SBLOC services In certain circumstances, your IAR may recommend, and your account may be approved for SBLOC services. Your IAR will benefit from recommending SBLOC services because you do not have to liquidate assets in your account to pay for items with cash, which would diminish the assets held in the account and the potential fees and commissions that could be earned by your IAR from holding or engaging in future transactions with those assets. For example, with a fee-based account, by recommending an SBLOC loan to fund some purchase or financial need rather than liquidate securities, PAS and your IAR continue to earn fees on the full account value. There are substantial risks associated with the use of securities as collateral for a loan such as:  the risk of borrowing and the impact of the use of borrowed funds on advisory accounts;  the risk that you may lose more than your original investment;  the possibility you may not benefit from collateralizing your account for a loan in a Third Party Advisory program account if the performance of your account does not exceed the interest expense being charged on the loan plus the additional advisory fees incurred by your account as a result of the deposit of the loan proceeds; &  the risk of being required to deposit additional funds into your Third-Party Investment Advisory Program account if the account depreciates in value. For more information about SBLOC services through your elected Third-Party Investment Advisor, inclusive of any potential conflicts the Advisor may have in offering these services, please review the Advisory Brochure of your Third-Party Investment Advisor. If you elect to, and are approved for SBLOC services, it is important you understand these risks and carefully read the application and disclosure information provided when applying for SBLOC services. The following is a list of Third-Party Investment Advisory Programs available through PAS, where PAS acts as a solicitor, or in some instances, as adviser or co-adviser: Third-Party Investment Advisers  SEI Investment Management Corp.  AssetMark, Inc.  Matson Money, Inc.  Morningstar Investment Services, Inc.  BNY Mellon  Stonebridge Capital Management*  Gould Asset Management, LLC*  Silvercrest Asset Management Group, LLC* 26 (3/2024)  Orion Portfolio Solutions, LLC  Efficient Advisors, LLC Please note that from time to time one or more of the above-listed programs may not be available to new clients. Additional information about these Third-Party Investment Advisory Programs is available through your IAR, or you may access the Form ADV for each of these advisers via the SEC’s website at www.adviserinfo.sec.gov. The primary Third-Party Investment Advisory Programs PAS offers are summarized below. *Noted Third-Party Investment Advisory Programs are only offered through specific IARs of PAS. Please contact your IAR if you have questions regarding the programs offered through these firms SEI Investment Management Corporation SEI Investment Management Corporation (“SIMC”) sponsors and is adviser to the SEI programs, which are offered through PAS for investment by its clients, such as high net worth individuals, trusts, endowments and foundations, and institutions. PAS offers two types of programs through SEI: (i) the SEI Asset Management Program which is an institutional mutual fund asset allocation program; and (ii) the SEI Managed Account Solutions program which is a wrap fee program that charges a bundled fee that includes advisory, brokerage and custody services. SEI Asset Management Program (closed to new clients as of April 2, 2018) For the SEI Asset Management Program, your IAR will assist you in the establishment of your account, which is custodied at SEI Trust Company. The relationship between you and SEI Trust Company is governed by a separate custodial agreement. Under the SEI Asset Management Program, you grant PAS limited authority with respect to reallocations in your account based on changes made by SIMC to the asset allocation models. PAS will direct SEI Trust Company to allocate your investments in accordance with the asset allocation policy adopted by you. You have the ability to impose any reasonable restrictions or modify any existing restrictions on the management of your account. SEI Managed Account Solutions Under the SEI Managed Account Solutions Program, SIMC enters into a tri-party investment advisory agreement with you and PAS, which provides for the management of your assets in accordance with the terms of the Investment Management Agreement. Pursuant to the Investment Management Agreement, you appoint PAS as your investment adviser for the purpose of assisting you in selecting an appropriate asset allocation strategy and selecting available sub-advisers that have been assigned to the strategy by SIMC. You appoint SIMC, through its manager-of-managers structure, as your investment adviser to manage the assets in each Managed Account Solutions portfolio in accordance with the strategy selected by you with the assistance of PAS. You may elect to invest in one or more of the Portfolios. Portfolios may include: (i) allocations to one or more asset classes managed through your selection of specific Portfolio Managers; (ii) allocation to investment models consisting solely of investments in SEI Funds (“SEI Fund Models”) or exchange traded funds or (iii) an allocation to a DFS Strategy, which are portfolios of SEI Funds or ETFs intended for investors in or near retirement. You have the ability to impose any reasonable restrictions or modify any existing restrictions on the management of your account. Under the SEI programs, PAS is responsible for gathering information about your current financial situation, risk tolerance, time horizon, and asset class preference. PAS uses tools made available by SEI, including SEI’s proprietary proposal tools, to develop the appropriate asset allocation strategy for you. Based upon your information, you will work with PAS to select from one of several asset allocation models developed by SEI, which may be composed of SEI mutual funds. SEI may provide PAS with assistance in developing client investment proposals using SEI mutual funds or managed accounts. Your IAR will continue to review the account for program suitability and your IAR will retain responsibility for an annual review of your account. Any securities in your SEI account that are not managed under the SEI programs described above will be held in 27 (3/2024) Client Directed Portfolios. Securities which are held in Client Directed Portfolios are not included in the periodic performance reports of the SEI program portfolio you have selected. PAS, SIMC and your IAR do not provide investment advisory services of any kind with regard to Client Direct Portfolios, do not charge an advisory fee on such assets and do not have any responsibility with respect to the management of holdings within Client Directed Portfolios. SEI does not take holdings held within Client Directed Portfolios into consideration when providing investment advice for your SEI program account. SEI Institutional Program PAS IARs are compensated for referrals to the SEI Institutional Group. SIMC offers investment management and investment advisory services directly to institutional clients through SEI’s business segment called Institutional Investors (the “Institutional Group”). SIMC’s Institutional Group delivers integrated retirement and non-profit investment solutions to institutional clients including, but not limited to, corporate and union sponsored pension plans, public plans, defined contribution plans (including 401(k) plans), endowments, charitable foundations, and hospital organizations (each a, “Client” and together the “Clients”). All investment advisory services regarding the Client’s SEI Institutional Group will be provided by the SEI Institutional Group pursuant to an agreement between the Client and SEI Institutional Group. Please review the Fee Disclosure Statement or contact your representative at SEI for more information on SEI’s respective investment advisory practices. AssetMark, Inc. AssetMark, Inc. (“AssetMark”) is the sponsor and adviser of the AssetMark investment advisory programs (“AssetMark Platform”) and works with PAS to implement the AssetMark Platform for PAS clients. As part of its services, AssetMark provides account administration and has developed internet-based software, which provides PAS and its IARs with the ability to directly monitor client accounts, download information concerning changes in the AssetMark Platform, and access current information relating to the AssetMark Platform. To establish an account on the AssetMark Platform, you will enter into a Client Services Agreement with AssetMark and PAS. In establishing your account, you may complete a questionnaire, or otherwise provide information to PAS, to enable you and PAS to identify your risk tolerance and investment objectives. You may be asked to provide information concerning your investment experience, anticipated need for liquidity, potential timing of the need for retirement funds, and other investment needs and parameters. This information will assist you and PAS in selecting the risk/return profile that is most closely aligned with your investment goals. AssetMark makes a number of different investment options available to clients through the AssetMark Platform. These include Mutual Fund Accounts, ETF Accounts, Guided Portfolios, Privately Managed Accounts and Unified Managed Accounts. AssetMark’s Custom GPS Select – This product is available to eligible PAS IARs who are Series 7 licensed. Your IAR has the ability to make changes to the asset allocation and /or investment selection of the Custom GPS Select portfolio selected within your prescribed risk profile and investment objectives upon your approval. AssetMark retains responsibility for the management of your account and will confirm changes made to a pre- existing Custom GPS Select portfolio by your IAR to ensure any new allocation continues to align with your risk profile and investment objectives. Your IAR will continue to review the account for program suitability and will retain responsibility for an annual review of your account. Matson Money, Inc. Matson Money, Inc. (“Matson”) sponsors and is adviser to the Matson Money Fund Platform, which is offered through PAS for investment by its clients. To establish an account through the Matson Money Fund Platform, you 28 (3/2024) enter into an investment management agreement with Matson and PAS under which Matson is granted discretionary authority to invest your assets and PAS acts as the soliciting adviser. Under the Matson Money Fund Platform, you respond to a client questionnaire that assesses your risk tolerance and investment objectives. Based on your responses to the questionnaire, Matson will assign you to one of its various model portfolios. Each model portfolio is composed of mutual funds managed by Matson, currently the Free Market U.S. Equity Fund, Free Market International Equity Fund and Free Market Fixed-Income Fund (the “Matson Funds”). Each Matson Fund is a “fund of funds,” which invests primarily in shares of no-load mutual funds managed by Dimensional Fund Advisors (“DFA”) which, as sub-adviser to each Matson Fund, selects the underlying DFA mutual funds based on the investment characteristics specified by Matson and described in the Matson Funds prospectus. Each Matson Fund is designed to target specified percentages of certain asset classes in the Matson Fund’s applicable investment category to seek maximum portfolio diversification, enhanced return potential and diminished portfolio volatility. Matson reserves the right, in its sole discretion, to create, and allocate assets in client accounts to, additional Matson Funds in the future. Matson may also invest your assets in unaffiliated cash sweep vehicles for temporary or other defensive purposes. More complete information is available in the Matson Funds prospectus. IARs who wish to offer the Matson Money advisory programs are required to pay a fee to Matson in the amount of $10,000. The fee includes educational and training courses, some of which are required by Matson prior to permitting participation as a solicitor. Matson also requires IARs to solicit at least $100,000 of client assets within the first year of acting as a solicitor. If this minimum is not met, Matson reserves the right to terminate its relationship with your IAR. As the amount of assets referred to Matson by your IAR increases, the amount of marketing assistance provided to your IAR also increases, at no additional cost. Therefore, IARs who offer the Matson advisory programs have an incentive to select Matson over another program. Your IAR will continue to review the account for program suitability and will retain responsibility for an annual review of your account. Morningstar Investment Services, LLC Morningstar Investment Services LLC (“Morningstar”) is the sponsor and adviser to the Morningstar Managed Portfolios Program (the “Morningstar Program”) which is offered through PAS for investment by its clients. The Morningstar Program consists of multiple investment strategies with multiple portfolios intended for a range of clients based on such factors as age, financial situation, time horizon, risk tolerance, and any reasonable restrictions that you may place on the portfolio selected for your account. The Morningstar Program includes various strategies consisting of mutual funds, exchange-traded funds, and equity securities; Morningstar or an affiliate provides discretionary management for the Morningstar Program strategies. To establish an account, you enter into an investment management agreement with Morningstar under which Morningstar is granted discretionary authority to invest your assets. Your IAR will assist you with filling out a client questionnaire to assist in your selection of an appropriate investment strategy from those available within the Morningstar Program (i.e., mutual fund strategies, stock basket strategies and exchange-traded funds strategies) and in determining whether any reasonable restrictions on the investment of your account assets should be imposed. This information will be provided to Morningstar before your account is opened including, when applicable, your basis for selecting a portfolio other than the one identified by the Morningstar Program questionnaire/proposal system. PAS will continue to review the account for program suitability and your IAR will retain responsibility for an annual review of your account. 29 (3/2024) This program is also available through Park Avenue Strategist SelectSM. Orion Portfolio Solutions, LLC Orion Portfolio Solutions, LLC (“Orion”) is the sponsor and adviser to the Orion Strategist Program (as defined below) which is offered through PAS for investment by its clients. Through this program Orion provides a fee- based platform for PAS IARs to utilize Orion’s selected institutional portfolio strategists (the “Orion Strategist Program”) that are vetted and monitored by Orion. For the Orion Strategist Program, Orion retains third party investment managers that are not affiliated with OPS (“Strategists”), to design and manage model portfolios that IARs can recommend to clients for management of client assets. To establish an account through Orion you must enter into an investment management agreement with Orion and PAS under which Orion is granted discretionary authority to invest your assets and PAS acts as a solicitor. Your IAR will continue to review the account for program suitability and will retain responsibility for an annual review of your account. Certain Orion programs are also available through Park Avenue Strategist SelectSM. Efficient Advisors, LLC PAS IARs may refer ERISA qualified plan assets to Efficient Advisors, LLC (“Efficient”). Efficient acts as an investment manager and controls the investment of plan assets. Efficient provides investment–related services to qualified plan assets as an investment adviser registered under the SEC and provides these services in its capacity as a fiduciary within the meaning of § 3(38) of ERISA. Efficient provides the following services:  Construct, maintain and monitor model asset allocation portfolios (Models) for Plan participants.  Develop or assist with the development of an investment policy statement (IPS) for the Plan.  Exercise full investment discretion with regard to buying, managing, and selling assets held in Models.  Monitor investment options.  Meet with plan sponsor on a periodic basis to discuss the reports and the investment recommendations.  Select a qualified default investment alternative under ERISAsection404(c)(5).  Communicate to the plan's investment committee all significant changes pertaining to the assets it manages or the investment management firm itself. PAS IARs may provide the following services to the plan sponsor:  Assisting plan sponsor with completing all appropriate documentation to support plan implementation.  Conducting enrollment meetings with participants and providing investment education services to plan participants. ManagedPlan™ Program The ManagedPlan™ program is available on the Envestnet Wealth Management Technology platform and is a comprehensive retirement plan solution whereby Envestnet Retirement Solutions, LLC (“ERS”) will perform implementation services with the retirement plan record-keeper, PCS Retirement, LLC (“PCS”). ERS provides investment related services to qualified plans such as 401(k), 403(b) and 401(a) plans, profit sharing plans, defined benefit pension plans and cash balance plans, and acts in the capacity as a fiduciary within the meaning of Rule 3(38) of ERISA. When acting as a fiduciary, ERS acts in accordance with the Investment Advisers Act of 1940, as amended (“Advisers Act”) and for Plans subject to the Employee Retirement Income Security Act of 1974, as amended, (“ERISA”), in accordance with ERISA Title I rules. In providing Plan Sponsor Services, ERS acts with the care, skill, prudence, and diligence that a prudent person, acting in the same 30 (3/2024) capacity and with the same information, in a similar situation would utilize. ERS provides an investment strategy (“Strategist Model”) of a non-affiliated third-party investment manager (“Third Party Strategist”), whereby the Third-Party Strategist, acting as an investment model provider, constructs an asset allocation and selects the underlying investments for each portfolio. The Strategists are American Funds, Blackrock, and Orion. The Plan Sponsor is responsible for selecting the Third-Party Strategist that it wishes to make available to its Plan. Acting as the “investment manager” (as defined in Section 3(38) of ERISA), ERS performs overlay management of the Strategist Model by monitoring the investment strategy and, in certain cases, facilitating the routing of trade orders to the recordkeepers for execution, and periodically updating and rebalancing each Strategist Model pursuant to the direction of the Third-Party Strategist. ERS may, from time-to-time, replace existing Third-Party Strategists and cannot guarantee the continued availability of Strategist Models. ERS retains final decision-making authority with respect to removing and/or replacing investments in the core lineup, and communicates instructions to the appropriate third-party, including the Plan’s record keeper, custodian, and/or third-party administrator to facilitate investment changes. PAS IARs may refer qualified plan assets to ERS to invest in the ManagedPlan™ program and may provide the following services to the plan sponsor:  Assisting plan sponsor with completing all appropriate documentation to support plan implementation.  Conducting enrollment meetings with participants and providing investment education services to plan participants. The annual fee for the referral and ongoing services provided by your PAS IAR ranges from 50bps to 175bps, a portion of which is retained by PAS. The fee does not include recordkeeping or individual participant fees, which are fully disclosed in the client agreement and proposal. The fee also excludes other related charges such as custody and clearing, Third Party Administrator (TPA) fee, and 3(38) services provided by ERS. BNY Mellon Wealth Management PAS IARs may refer ultra-high net worth clients to BNY Mellon Wealth Management for Investment advisory services while also providing ongoing client services in a co-advisory capacity. The investment management of the client’s BNY Mellon account will be provided by BNY Mellon pursuant to an agreement between the client and BNY Mellon. BNY Mellon provides the following services to clients:  Strategically designed platform of investment solutions tailored for private clients.  Actively managed investment strategies across a range of asset classes and styles.  Customized objective-based allocation recommendations. A separate agreement between PAS and you govern the services the PAS IAR will provide as it relates to the BNY Wealth Management program. The services your PAS IAR will provide are:  Ongoing holistic advice and guidance across your overall investment portfolio;  Interviewing you prior the introduction to BNY Mellon’s services to ascertain your financial position, investment goals and objectives, investment limitations, reasonable restrictions (if any) and risk tolerance.  Determining the suitability of the introduction to BNY Mellon and determining whether the BNY Mellon services may be suitable.  Contacting you at least annually to determine whether there has been a change in your financial situation or investment objectives.  Participate in the BNY Mellon annual review process with you. Please review the fee disclosure document or your PAS IAR for more information on BNY Mellon’s respective investment advisory practices. 31 (3/2024) Stonebridge Capital Management Certain PAS IARs are compensated for referrals to Stonebridge Capital Management (“Stonebridge”). All investment advisory services regarding the client’s Stonebridge account will be provided by Stonebridge pursuant to an agreement between the client and Stonebridge. Stonebridge may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Managers”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets. Stonebridge shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Stonebridge shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please review Stonebridge’s Form ADV Part 2A or contact your representative at Stonebridge for more information on Stonebridge’s respective investment advisory practices. Gould Asset Management LLC Certain PAS IARs are compensated for referrals to Gould Asset Management LLC. (“Gould”). Gould provides investment management services, primarily through individually managed accounts for individuals and institutions. Unless otherwise noted, Gould constructs portfolios primarily or exclusively using mutual funds, including traditional open-end, exchange-traded, and closed-end funds. Such mutual funds may be primarily or exclusively index or index-like funds, depending on the investment strategy. Gould’s management agreement with the client generally provides Gould with authority to act on a discretionary basis with client assets. Please review Gould’s Form ADV Part 2A or contact your representative at Gould for more information on Gould’s respective investment advisory practices. Silvercrest Asset Management Group LLC Certain PAS IARs are compensated for referrals to Silvercrest Asset Management Group LLC (“Silvercrest”). Client accounts are generally managed on a fully discretionary basis where Silvercrest makes all decisions as to which securities are bought or sold and/or the total amount bought or sold. Silvercrest tailors its advisory services to the individual needs of its clients. Silvercrest's portfolio managers apply specific objectives and guidelines for each client portfolio which they are responsible for managing. Please review Silvercrest’s Form ADV Part 2A or contact your IAR for more information on Silvercrest’s respective investment advisory practices. Assets Under Management As of December 31, 2023, PAS maintained $11,881,593,369 of Regulatory Assets Under Management of which, $10,134,454,678 were managed on a discretionary basis and $1,747,138,691 were managed on a non- discretionary basis. In its capacity as a solicitor or co-adviser, PAS maintained assets under administration of $8,997,671,211.