Old Glory Asset Management, LLC is a female owned and operated investment advisory firm that has been in business since April of 2003. The firm is owned by Mary Jean Dougherty, Chief Executive Officer/Co-founder and John Dougherty, President/Co-founder. As of December 31, 2023, Old Glory managed discretionary client assets valued at $459,965,766. Old Glory provides advisory and consulting services to an additional $28,922,473 of client assets. Total company assets under management and advisement are $488,888,239. The company offers the services described below. Portfolio Management Services Old Glory provides investment management services to institutional investors "Clients". Old Glory offers investment products in several categories, including U.S. Equity and U.S. Fixed Income. Old Glory utilizes a highly skilled team of sub-advisers to manage client portfolios. Old Glory is a “manager or managers” responsible for the marketing and client service of Old Glory clients’ portfolios while the unaffiliated sub-advisers are doing the actual investing in the stock and bond markets. Client portfolios are built strictly adhering to each plans specific investment guidelines as written in the client’s Investment Policy Statement. The sub-advisers have the ability to screen portfolios for AFL- CIO boycotted stocks and can vote proxies based on the AFL-CIO guidelines. Old Glory utilizes both quantitative and qualitative screens to select the stable of sub-advisers. The sub- advisers utilized by Old Glory are evaluated on certain criteria, including performance, investment philosophy and process, low turnover of investment professionals, and strong business fundamentals. Old Glory visits the offices of the sub- advisers periodically to perform due-diligence checks. Old Glory is in frequent contact with the sub-advisers via phone, email, and facsimile. Old Glory continuously reviews the investment performance, organizational and personnel

stability of the unaffiliated sub-advisers. Any significant, detrimental change in these factors would result in Old Glory taking steps to reevaluate the sub-advisory relationship and as needed, notify the client. At the client level, portfolios and performance are monitored by Old Glory generally on a quarterly basis. In addition, the sub-advisers are required to complete a quarterly questionnaire which indicates the status of compliance with the client’s investment guidelines. Old Glory reviews client accounts and addresses deviations from the client’s investment guidelines. Equitable Structured Capital Strategies Old Glory provides institutional clients access to the Equitable (Formerly AXA) Structured Capital Strategies Variable Annuity Products. Structured Capital Strategies offers investors participation in the equity markets combined with some downside protection. Structured Capital Strategies products are offered in a 1, 3 or 5 year term. Investment performance of the products is tied to market indices and is capped at a stated rate. Downside protection of the products is set at 10, 20 or 30%. Financial Institution Consulting Services Old Glory may contract directly with and receive payments from broker/dealers, insurance companies, investment companies, and other registered investment advisers to provide investment advisory consulting services to those contracted financial institutions. Such contractual engagements do not include assuming discretionary authority over brokerage accounts or the monitoring of securities positions. Services offered to financial institution clients may include a general review of client investments holdings, which may or may not result in Old Glory investment adviser representatives making specific securities recommendations or offering general investment advice. Old Glory neither participates in, nor sponsors a wrap fee program.