TAM is a limited liability company organized under the laws of Delaware. TAM as an entity was formed and has been in the investment advisory business since 2005 but is part of a business that has been in the investment advisory business since 1986. TAM is a wholly owned subsidiary of Thrivent Financial Holdings, Inc., which in turn is a wholly owned subsidiary of Thrivent Financial for Lutherans (“Thrivent”). Thrivent is a is a fraternal benefit society organized under the laws of the State of Wisconsin and is owned by and operated for its members. It has no stockholders and is not subject to the control of any affiliated persons. TAM provides investment advisory services to the Thrivent Mutual Funds, a registered investment company under the Investment Company Act of 1940 (the “Investment Company Act”) that is comprised of various mutual fund series. TAM also provides investment advisory services to Thrivent ETF Trust, which is a registered investment company comprising one exchange-traded fund (an “ETF”), Thrivent Small-Mid Cap ESG ETF. In managing Thrivent Small-Mid Cap ESG ETF, TAM’s investment process identifies companies that have sustainable long-term business models for the benefit of all primary stakeholders while driving financial success and risk management. TAM also provides investment advisory services to Thrivent Core Funds, which is a registered investment company that only offers its mutual fund series to Thrivent Mutual Funds and other Thrivent entities. In connection with its advisory services to the Funds, TAM and its affiliates receive advisory, administration, transfer agency, and distribution fees from the Funds, as applicable. Clients should carefully review the Funds’ prospectuses for more detailed information regarding the Funds to which TAM provides investment services. In addition, TAM provides model portfolios to managed account programs sponsored by other registered investment advisers, broker-dealers and other financial intermediaries, including affiliates (“program sponsors”). As a model portfolio provider, TAM designs, monitors and updates the model portfolios for the program sponsors. The program sponsors then offer the model portfolios to their clients. The program sponsors are responsible for implementing the models, making investment decisions, and performing other services and functions for their

clients. TAM does not have investment discretion to implement the models on behalf of a program sponsor’s clients and TAM does not have an advisory relationship with a program sponsor’s clients. TAM typically does not receive a fee from the program sponsors for providing the model portfolios, although it could receive such a fee. TAM does receive an advisory fee for the Funds it manages that are included within a managed account program. To the extent that this Form ADV Part 2A is delivered to clients of the program sponsors, or under circumstances where it is not legally required to be delivered, it is provided for informational purposes only. TAM is not responsible for overseeing the provision of services by a program sponsor. TAM provides its services in a variety of investment strategies, including in the broad categories of equities, fixed income, and asset allocation/mixed assets strategies. TAM may invest in a variety of securities and other investments, including derivatives, in its various investment strategies. It also utilizes various investment techniques, including fundamental, quantitative and technical methods to determine which investments to buy and sell. Certain strategies – including all the model portfolios for managed account programs – include an allocation to mutual funds, which may include the series of Thrivent Mutual Funds and Thrivent ETF Trust (“Affiliated Underlying Funds”). TAM currently offers four model portfolio programs: Thrivent SELECT Managed Portfolios (“SELECT”), Thrivent Faith-Based Managed Portfolios (“Faith-Based”), Thrivent Income-Focused Managed Portfolios (“Income-Focused”) and Thrivent Advantage Managed Portfolios (“Advantage”). The investment advisory services provided by TAM to the Funds are tailored to the investment strategies of the Funds described in each Fund’s prospectus and statement of additional information. The investment advisory services provided with the model portfolios to managed account programs are not tailored to the individual needs or restrictions of clients. As of December 31, 2023, TAM managed, on a discretionary basis, approximately $30.0 billion in assets. As of this date, TAM managed approximately $6.6billion in its managed account programs on a nondiscretionary basis, including assets in affiliated Thrivent Mutual Funds and third-party managed funds.