Fortigent, founded in November 2006, is owned by Fortigent Holdings Company, Inc., which is indirectly owned by LPL Financial Holdings, Inc. (“LPL Financial Holdings”) (NASDAQ: LPLA), as further detailed below in Item 10 “Other Financial Industry Activities and Affiliations.” Fortigent has announced that it is gradually winding down its operations and anticipates completion of this process could extend into 2024. It is continuing to work with Financial Intermediaries (as defined below) to transition client accounts to similar investment programs offered by other program sponsors by such time. Assets Under Management As of December 31, 2021, Fortigent managed approximately $3,451,348,607 on a discretionary basis within Access Overlay Program accounts. Fortigent also provides wealth management solutions and consulting services to approximately 8 Financial Intermediaries. Each of these services is described in this section below. Services to Financial Intermediaries Fortigent provides investment research, consulting, portfolio accounting, database, data processing and support services and reporting on a wholesale fee basis to investment advisory firms and banks (“Financial Intermediaries”) to assist such firms in providing manager recommendations, monitoring, and reporting services to the Financial Intermediaries’ Clients (“Financial Intermediary Clients”). Fortigent also provides customized due diligence project-based support for Financial Intermediaries. Fortigent does not provide investment recommendations directly to Financial Intermediary Clients as part of these services. The respective roles and responsibilities between Fortigent and Financial Intermediaries, and additional terms and conditions, are detailed in an Investment Services Agreement. Access Overlay Unified Managed Account Program Fortigent’s Access Overlay Program is a unified managed account program that is designed to provide clients who enroll in the program (“Client”) with the ability to maintain an actively managed and diversified investment portfolio, including access to individual securities, mutual funds, exchange traded funds or ETFs, separately managed accounts or SMAs (which are managed portfolios consisting of various securities in which the investor owns the individual securities), and tax efficient investment strategies, within a single “unified” account. The Access Overlay Program is a “discretionary” investment program under which the Client grants Fortigent authority to engage in securities transactions on its behalf, including its delegation of authority to the Overlay Manager (defined below) and other investment advisers and portfolio managers to act with discretion, and without requiring the Client’s pre-approval to purchase or sell investments in their program account. The Client’s Access Overlay Program account is maintained at a third party custodian selected by the Client in consultation with their Financial Intermediary as further detailed in Item 12 below. The specific responsibilities for management of accounts participating in the Access Overlay Program are divided as follows:
• Fortigent is the Access Overlay Program sponsor with responsibility for administering the program as a discretionary “Investment Manager” pursuant to the authorizations granted to it under the Access Overlay Investment Advisory Agreement entered with the Client. This includes conducting ongoing

investment product due diligence, selecting the universe of available SMAs, and providing oversight of the third party Overlay Manager that Fortigent delegates to implement and rebalance the model investment portfolios. In addition, Fortigent conducts due diligence on third party investment advisers referred to as “Research Providers” that are responsible for investment allocation and buy/sell decisions for the SMAs available through the program. Fortigent also retains the right to assume other responsibilities attributable to the Overlay Manager or Research Providers in the event such becomes necessary to ensure continuous servicing of Client accounts if those third parties become unable or unavailable to do so.
• The Overlay Manager is an investment adviser that is selected and delegated responsibility by Fortigent to implement the models and trading instructions received from the Financial Intermediary by exercising discretionary trading within a Client’s Access Overlay Program account, subject to any independent decisions by the Overlay Manager to delay or modify trading instructions consistent with the overall investment strategy. The Overlay Manager currently designated for the Access Overlay Program is Parametric Portfolio Associates, LLC (“Parametric”), an SEC registered investment adviser. In limited circumstances, Fortigent may assume or delegate this role to a replacement investment adviser, to avoid any lapse in portfolio management services if the designated Overlay Manager is unable or unavailable to perform these services. Clients will be notified of any changes to the designated Overlay Manager and may consult their Financial Intermediary or Fortigent to confirm the Overlay Manager that is servicing their account.
• The Financial Intermediary is responsible for recommending the Access Overlay Program to Clients, and providing each Client with personalized investment advice based on their particular financial situation and investment objectives, including determining which model(s) are suitable for investment by each Client. The Financial Intermediary may create a series of customized model investment portfolios, using the investment products and SMAs available through the designated custodian, to reflect a range of various investment asset allocations and risk profiles. The Financial Intermediary will provide the Client with periodic performance reports for their Access Overlay Program account, and acts as a liaison to Fortigent by managing and administering the Client relationship. Clients will typically be required to enter a separate agreement and will receive a disclosure brochure from their Financial Intermediary detailing the full scope of its services, fees and other important information. Clients are encouraged to carefully review this information and discuss any questions with their Financial Intermediary.
• LPL Financial LLC (“LPL”) is an affiliate of Fortigent that acts as a strategic partner for the Access Overlay Program by providing a range of services to Fortigent, including investment due diligence and analysis, operational and oversight support to the Access Overlay Program. LPL may also be appointed as the Overlay Manager or Research Provider by Fortigent at its discretion under limited circumstances as outlined above. Please consult Item 10 below for additional details regarding the interrelationship between Fortigent and LPL.