Description of Firm Mill Creek Capital Advisors, LLC (“MCCA”) provides investment supervisory services to high net-worth individuals, pooled investment vehicles, pension plans, endowments, 401(k), 403b and similar institutions, among other types of clients. MCCA has been registered as an investment adviser with the SEC since September 2006. MCCA is primarily owned by SG Management, LLC, an employee owned holding company. Joshua Gross, Chief Executive Officer and Richard Lunsford, President are the principal owners of MCCA. Assets Under Management As of December 31, 2022, we manage nearly $ 7.9 billion in regulatory assets. Of this total, approximately $7.8 billion is managed on a discretionary basis, while $73 million is managed on a non-discretionary basis. In addition, we provide advisory or non-continuous management services for approximately $514 million in client assets. Advisory Services Acting as your investment adviser, we build custom investment programs. We collaborate with you to develop objectives within suitable risk/reward parameters relative to your financial circumstances, and then develop an appropriate asset allocation strategy. We begin with a model portfolio constructed for each specific investment strategy MCCA offers, and then tailor the model for each client taking into account its individual needs, including client requested restrictions, cash needs, tax considerations, and other items, while generally remaining consistent with the MCCA model for that strategy. There may be an opportunity to employ client requested restrictions on a case-by-case basis; any proposed client requested restrictions should be provided to MCCA in writing in advance for its consideration. MCCA will also consider allowing clients to impose restrictions on investing in certain securities or types of securities. MCCA offers several investment strategies that include equity and fixed income allocations in varying percentages; some of these strategies include hedging and/or private equity components. MCCA selects third party investment advisory organizations (“Specialist Managers”) to handle the selection of specific investments consistent with the overall asset allocation strategy developed. Specialist Managers are selected based on our overall evaluation of the investment advisory organization involved, including that organization’s performance against selected benchmarks, investment style within a particular asset

class and related factors. MCCA receives a fee for providing the overall asset allocation strategy in addition to other services. We will also negotiate the fees payable to the Specialist Managers on your behalf and communicate client restrictions, if any, applicable to portfolio investments and/or expense management to Specialist Managers. Access to Specialist Managers will be provided by establishing a separate account with a Specialist Manager or through the use of pooled vehicles, including mutual funds and exchange traded funds. Our ability to negotiate fees with Specialist Managers and communicate client restrictions is limited with respect to mutual funds and exchange traded funds. MCCA monitors the performance of Specialist Managers, including their adherence to investment style and continuing suitability with respect to your overall asset allocation strategy, as well as overall expense levels. As part of this monitoring process, we employ the services of various outside consulting and research providers to obtain performance measurement, including index and peer group comparisons, and/or other services. We continuously monitor the capital markets and various asset classes. Periodically, we may recommend that you make tactical changes to your strategic asset allocation in seeking to avoid risk or attract returns associated with investment opportunities. MCCA utilizes various custodians and back-office service providers to obtain detailed transaction statements on a monthly basis, as well as quarterly and annual performance reports. These custodians and back-office service providers also provide access to your account information through secure, access-controlled websites. MCCA will also work with custodians and service providers that you select. IRA Rollover Recommendations We may recommend the rollover of assets from retirement plans to individual retirement accounts (IRAs). This creates an inherent conflict of interest, as the rollover can result in increased fees and expenses for clients, which may result in higher compensation for our firm. We acknowledge and understand these conflicts of interest and strive to always act in the best interest of our clients. We adhere to a fiduciary standard of care, which means that we are legally and ethically obligated to put our clients' interests ahead of our own. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.