Parametric Portfolio Associates LLC (Parametric or the Firm) is organized as a limited liability company under the laws of the State of Delaware. Parametric has been providing investment advisory services since its formation in 1987. Parametric is an indirect, wholly owned subsidiary of Morgan Stanley, a publicly held company that is traded on the New York Stock Exchange under the ticker symbol MS. Parametric’s direct owner is Eaton Vance Acquisitions LLC, a wholly owned indirect subsidiary of Morgan Stanley. Parametric is part of Morgan Stanley Investment Management, Inc. (MSIM) the asset management division of Morgan Stanley. Parametric is a leading global asset management firm providing various portfolio management services and investment strategies directly to institutional investors and indirectly to individual investors through financial intermediaries. Parametric’s investment decision-making processes utilize proprietary technology and are typically guided by structured, mathematical, and rules-based methodologies. Parametric’s portfolio management services and strategies assist clients in meeting their desired market exposure, risk management, tax management and return objectives in a cost-effective manner. These services may be tailored to meet specific client needs, which include but are not limited to systematic equity portfolios, tax- managed core equity portfolios for taxable investors, fixed-income, centralized portfolio management, futures and options-based overlay services for clients seeking to securitize cash, re-balance asset allocations, managed currency and duration exposure, and specialty index strategies. Parametric collaborates with clients and their advisers to design and implement customized solutions through the application of equity, fixed income and derivative programs. Clients may impose reasonable restrictions on investments in securities or types of securities and set additional investment guidelines as they deem necessary. Parametric provides investment management services through a variety of products and investment vehicles. These include but are not limited to discretionary and non-discretionary separate accounts for institutional and individual investors; U.S. registered investment funds such as open-end mutual funds, close-end funds (CEFs) and exchange-traded funds (ETFs) registered under the Investment Company Act of 1940 (1940 Act) sponsored by both affiliates and third parties; and U.S. and non-U.S. collectively managed funds such as private funds, collective investment trusts, commingled trust funds, and UCITS which may be sponsored by Parametric, affiliates, or third parties. Parametric offers a separately managed account program (the Platform) which is designed to provide financial intermediaries and their clients access to a broad array of investment strategies offered by Parametric, its affiliates, and third parties (each a Research Provider). Under the Platform, Research Providers provide non-discretionary model portfolios to Parametric. Clients may select one or more investment strategies on the Platform, which are implemented in client accounts by Parametric pursuant to Parametric’s normal trading practices. Parametric expects to deviate from a model provided by Research Provider to account for account specific considerations, such as tax-management. Parametric - Form ADV Part 2A – 03/28/2024 Page 2 Parametric provides portfolio management services through wrap fee programs, including programs sponsored by affiliates. Under these programs, the wrap program sponsor charges the client a bundled fee which includes trade execution, custody, and other services provided by the sponsor. Parametric typically receives a portion of the wrap/program fee collected by the program sponsor for advisory services provided by Parametric. As further detailed in Item 5 – Fees and Compensation below, Parametric negotiates its fee rates with the wrap program sponsor, and as such fees may differ across wrap fee programs sponsored by different parties. Wrap program sponsors are responsible for determining which Parametric strategies are available to participants in the wrap fee program. Wrap accounts are generally managed in the same or similar manner to other separately managed accounts, subject to specific restrictions, investment guidelines and or other parameters imposed by the wrap program sponsor or intermediary and reasonable restrictions a client may place on their account. As brokerage commissions and charges are generally included within the bundled/wrap fee a wrap fee program participant pays the sponsor, Parametric will frequently execute transactions through the sponsor to avoid costs associated with transacting through a third-party broker. Please see Item 12 – Brokerage Practices for additional information about Parametric’s brokerage practices for wrap fee program accounts. Parametric generally only receives information about a wrap fee program participant as necessary for Parametric to manage a wrap program participant’s account in the selected strategy. As such, the wrap program sponsor, and not Parametric, is responsible for determining the suitability of a particular Parametric strategy based on factors including the client’s objectives, risk tolerance and financial situation. A wrap program participant should consult their wrap fee program sponsor’s brochure for

more information about how Parametric’s fees are paid. Other non-institutional clients generally access Parametric strategies through an intermediary such as a broker-dealer, bank, family office, or registered investment adviser. Similar to wrap fee programs, Parametric commonly will enter into a sub-advisory agreement with the intermediary. In certain limited instances, Parametric will enter into a dual- or tri-party contract agreement directly with a client of an intermediary. Also similarly to wrap fee programs, the intermediary is responsible for determining what Parametric strategies are available to its clients and for conducting a suitability assessment for each of its client’s investing in a Parametric strategy. Parametric will frequently execute transactions through a client’s custodian, particularly if the custodian offers zero or low-cost commission trading. Clients of an intermediary should consult their intermediary for information about the particular arrangement the intermediary has with Parametric. Parametric provides investment advice through model portfolio delivery programs. Under such arrangements, Parametric provides third parties, which may include wrap fee program sponsors and other intermediaries, with a model portfolio. Unless otherwise agreed upon with a third-party model recipient, these model delivery arrangements are considered non-discretionary. The third party retains discretion to implement, reject, or adjust such model and the third party is responsible for executing any corresponding transactions on behalf of the third party’s underlying clients. Parametric does not affect or execute transactions for any underlying clients of the third party participating in the model delivery program. Parametric claims compliance with the Global Investment Performance Standards (GIPS®). For compliance with GIPS®, the “Firm” is defined and held out to the public as Parametric Portfolio Associates LLC. The Firm Parametric - Form ADV Part 2A – 03/28/2024 Page 3 provides rules-based investment management services to institutional investors, individual clients, and commingled investment vehicles, including Systematic Alpha and Income Strategies, Custom Core®, Centralized Portfolio Management, Customized Exposure Management, Volatility Risk Premium, Tax- Advantaged Bond Strategies and Taxable Bond Strategies. The Firm has complied with the GIPS® standards retroactive to January 1, 2000. To obtain a compliant presentation and or the Firm’s list of composite descriptions, prospective clients should contact us at 206-694-5575 or visit our website, www.parametricportfolio.com. Parametric operates several business locations from which it conducts its advisory business, all of which are integral divisions of the Firm. The locations are as follows:  Seattle, Washington  Minneapolis, Minnesota  Westport, Connecticut  Boston, Massachusetts  New York, New York  Alpharetta, Georgia Parametric’s investment strategies are managed by specific teams, each of which is subject to investment policies and procedures and strategy-specific investment processes. A particular team can manage one or more strategies offered by Parametric and different teams can, in certain instances, work together on implementing a strategy. Parametric has been granted registration as a Portfolio Manager in the Canadian provinces of Alberta, British Columbia, Manitoba, Nova Scotia, Ontario, and Quebec. The Firm has also been granted registration as a Commodity Trading Manager in Ontario. Parametric advises or sub-advises qualified institutional or “permitted” clients in Canada and does so in accordance with rules and regulations set forth in National Instrument (NI) 31-103. Pursuant to Section 13.4 of NI 31-103, Parametric is obligated to inform clients of all material conflicts of interest identified by the Firm. The nature and extent of material conflicts of interest identified by and known to Parametric are hereby disclosed in this Brochure. Pursuant to Section 14.2 of NI 31-103, Parametric is also required to deliver to clients all information that a reasonable investor would consider important about the client’s relationship with Parametric. This Brochure and the Non-Resident Registrant Disclosure Statement to Canadian Investors communicates to Canadian clients all information a reasonable investor would consider important to their relationship with Parametric. Parametric is registered as a Delegated Fund Manager by the Central Bank of Ireland. As detailed in Item 10—Other Financial Industry Activities and Affiliations, Parametric serves as a sub-adviser to certain affiliated, commingled funds registered with the Central Bank of Ireland. On May 1, 2023, the Fixed Income Managed Solutions (FIMS) team transitioned from MSIM to and became employees of Parametric. Accounts previously managed by the FIMS team are now managed by the FIMS team at Parametric. Parametric - Form ADV Part 2A – 03/28/2024 Page 4 Parametric Portfolio Associates LLC markets under the following names:  Parametric Portfolio Associates LLC  Parametric Portfolio Associates  Parametric As of December 31, 2023, Parametric held approximately $475.0 billion in total client assets under management (AUM). This is comprised of roughly $433.7 billion in discretionary AUM and $41.3 billion in non-discretionary AUM.