A. Operational and Organizational Information Commerce Street Investment Advisor (“CSIA”) is a Texas limited liability company, dba Commerce Street Investment Management (“CSIM”) and dba Commerce Street Peak Advisors (“CSPA”). CSIA is a wholly owned subsidiary of Commerce Street Holdings, LLC (“CSH”), a Texas limited liability company. CSIA is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). CSIA was formed in January of 2008. CSH is the sole member of CSIA. Dory A. Wiley and William D. “Tex” Gross are the sole members of CSH. Commerce Street Investment Advisor II, LLC (“CSIA II”) is a Delaware limited liability company and wholly owned subsidiary of CSH. CSIA II is a relying advisor of CSIA, as recognized under the SEC umbrella registration guidance. CSIA II was formed in mid-2020 to be the investment manager of a single fund, Commerce Street Financial Partners II, LP, as discussed below. CSIA and CSIA II are referred to collectively herein as the “Firm.” B. Types of Advisory Services Offered The Firm provides investment management services to the Funds (defined below), which operate as private equity funds, private equity fund of funds, or hedge funds, through applicable investment management agreements or similar documents. Please review the investment guidelines for a particular Fund as described in the respective Fund’s private placement memorandum. CSIA offers consulting and advisory services to clients who are federally insured depository institutions. These consulting and advisory services include the review and evaluation of a client’s current investment portfolio and its Asset/Liability Management processes and systems. The Firm assists clients in assessing, identifying, and managing the institution’s overall interest rate risk, advising about investment selection, credit exposure from investments, and finding and intermediating negotiations for the best execution of trades for the investment portfolio on a non- discretionary basis. CSIA is also a provider of independent fee-only investment management fiduciary and non-fiduciary services as defined under ERISA for qualified retirement plans. For no additional compensation, CSIA may also have an arrangement with the plan to create and/or manage the model portfolios. CSIA may provide independent plan investment advisory services to plan fiduciaries of employer-sponsored retirement plans to assist the plan fiduciary in selecting and monitoring investment options for the plan. CSIA may also provide professionally managed risk-based portfolios to the plan participants having full discretion to supervise and direct the asset allocation with respect to each managed portfolio designed by CSIA. Further, CSIA offers similar independent fee-only investment management services to individual Separately Managed Accounts (“SMAs”), for institutions and accredited individuals seeking to invest in the model portfolios. The model portfolios are described below in Item 4.B.5. 1. Private Funds The Firm provides investment management services and sponsorship to privately offered investment vehicles (each a “Fund” and collectively the “Funds”). Typically, the Funds are closed- end limited partnerships in which investors subscribe for interests. Each Fund typically has an affiliated general partner (each a “General Partner” and collectively the “General Partners”). a. Commerce Street Carlyle Private Equity Fund I, LP (“CPE I”), a Delaware limited partnership, is a fund-of-funds that seeks to provide investors with long-term capital appreciation through exposure to a portfolio of underlying private equity funds (the “Carlyle Funds”) sponsored by Carlyle Investment Management L.L.C. and its affiliates (collectively, “Carlyle”). Through investing all or substantially all of its assets in the Carlyle Funds, the Partnership’s investment objective is to provide investors with attractive exposure to private equity investment opportunities across multiple geographies, including the U.S., Asia, and Europe. b. Commerce Street Financial Partners II, LP (“CSFP II”) a Delaware limited partnership, is a private equity fund which seeks to realize income and capital appreciation primarily through making direct, non-control equity investments in U.S. banks and bank holding companies with strong management teams, solid core deposit funding, minimal asset quality issues, and significant growth prospects. The General Partner, on behalf of CSFP II, has contracted with CSIA II to conduct portfolio management, due diligence, financial analysis, and back-office accounting services. 2. Consulting Services CSIA offers consulting and advisory services to clients, who are federally insured depository institutions through Commerce Street Investment Management Services, a separate business line of CSIA. 3. Independent Participant Investment Advice CSIA provides independent fee-only investment management fiduciary services as defined under the Employee Retirement Income Security Act of 1974 (“ERISA”) for qualified retirement plans. We offer a full range of services, such as providing low cost professionally managed risk-based portfolios, lower management fees, assistance in creating investment policy statements, providing participant education, and selection of plan service providers. We can act in the capacity of a 3(21) Investment Consultant or a 3(38) Discretionary Investment Manager and in most cases will act as both. CSIA may also have an arrangement with an ERISA qualified plan to create and/or manage the model portfolios. CSIA is an independent investment adviser and does not receive any compensation from those who provide or manage investments that are available through a qualified plan. CSIA charges a fee that is based upon a percentage of plan assets. Retirement Accounts – DOL Disclosure We are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“Code”), as applicable, when we provide investment advice regarding portfolio assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by ERISA, or a plan described in Section 4975(e)(1)(A) of the Code (collectively referred to sometimes herein as (“Retirement Accounts”). To ensure that CSIA will adhere to fiduciary norms and basic standards of fair dealing, we are required to give advice that is in the "best interest" of the retirement client. The best interest standard has two chief components, prudence and loyalty. Under the prudence standard, the advice must meet a professional standard of care and under the loyalty standard, our advice must be based on the interests of our retirement clients, rather than the potential competing financial interest of CSIA. To address the conflicts of interest with respect to our compensation, we are required to act in your best interest and not put our interest ahead of yours. To this end, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest. o Charge no more than is reasonable for our services; and o Give you basic information about conflicts of interest. 4. Independent Plan Investment Advice CSIA may provide independent plan investment advisory services to plan fiduciaries of employer- sponsored retirement plans to assist the plan fiduciary in selecting and monitoring investment options for the plan. The plan fiduciary is solely responsible for the selection of the investment platform, recordkeeping and other services for the plan. Based upon the investments available to the plan, CSIA will assist the plan fiduciary in selecting and monitoring investment options, which are consistent with the asset classes selected by the plan fiduciary in the plan’s

Investment Policy Statement, to make available to plan participants. CSIA will act as a fiduciary under the Act and section 3(21)(A)(ii) of ERISA, and the plan fiduciary will retain sole discretion and responsibility as to whether to implement the recommendations with the plan’s record-keeper or third-party administrator. 5. Professional Risk-Based Portfolios CSIA may provide professionally managed risk-based portfolios to the plan participants. In providing these services, CSIA will have full discretion and authority, without further approval by the plan fiduciary, to supervise and direct the asset allocation with respect to each managed portfolio designed by CSIA. CSIA will act as a fiduciary “investment manager” under section 3(38) of ERISA, but the plan fiduciary shall be responsible for determining whether to implement the initial recommendations required to create the managed portfolios. Once the plan fiduciary elects to implement the initial advice, CSIA will be primarily responsible for monitoring the managed portfolios, and the plan fiduciary’s responsibility will be limited to monitoring the performance of CSIA as an investment manager to the plan. CSIA will communicate investment instructions directly with the plan’s record-keeper or third-party administrator and will provide quarterly reports and/or information as the plan fiduciary may reasonably request to assist the plan fiduciary in meeting its responsibilities to monitor the performance of CSIA as an investment manager to the plan. As the discretionary 3(38) investment manager, CSIA shall only be responsible for the investment options it selects and shall not have any responsibilities or potential liabilities in connection with other investments (e.g., employer securities, unallocated accounts, mutual fund windows, self- directed brokerage accounts, guaranteed investment contracts, target date funds, etc.) offered by the plan. a. Peak Moderate Balanced Model (Benchmark: 60% MSCI ACWI / 40% Barclays Aggregate Index) This portfolio invests roughly 60% in stocks and 40% in bonds. The portfolio’s benchmark is 60% MSCI ACWI Index (global equity) and 40% Barclays US Aggregate Index (US bonds). This portfolio strategically allocates to assets classes that the investment manager believes offer better risk reward metrics relative to its benchmark over an appropriate investment period. The portfolio’s broad diversification is important, because one or two holdings should not have a sizeable impact on the portfolio. Investors with a long-term time horizon who want growth and some income and who are willing to accept stock and bond market volatility may wish to allocate to this portfolio. b. Peak Equity Model (Benchmark: 100% MSCI ACWI) This portfolio invests in companies of various sizes from all over the globe and the United States. The portfolio’s benchmark is the MSCI ACWI Index (global equity), and the portfolio is made up of 800-plus stocks from more than 20 countries. In addition to stock market risk, the fund is subject to currency risk and country risk. Long-term investors seeking global equity exposure and who are comfortable with the added volatility in international investing may wish to consider this fund. The portfolio over-weights to US midcap equities and international small cap equities and under-weights large cap international developed equities relative to its benchmark. c. Peak Moderately Conservative Model (Benchmark: 40% MSCI ACWI / 60% Barclays Aggregate) This portfolio invests roughly 40% in stocks and 60% in bonds. The portfolio’s benchmark is 40% MSCI ACWI Index (global equity) and 60% Barclays US Aggregate Index (US bonds). This portfolio strategically allocates to asset classes that the investment manager believes offer better risk reward metrics relative to its benchmark over an appropriate investment period. The portfolio seeks to provide current income and low to moderate capital appreciation. The portfolio’s broad diversification is important, because one or two holdings should not have a sizeable impact on the portfolio. The portfolio has a bias to high‐quality low‐duration fixed income investments and high‐quality dividend paying US large cap stocks relative to its benchmark. Investors with a long‐term time horizon who can accept modest movement in share price and can tolerate the risk that comes from the volatility of the stock and bond markets may wish to allocate to this portfolio. d. Peak Moderately Aggressive Model (Benchmark: 80% MSCI ACWI / 20% Barclays Aggregate) This portfolio invests roughly 80% in stocks and 20% in bonds. The portfolio’s benchmark is 80% MSCI ACWI Index (global equity) and 20% Barclays US Aggregate Index (US bonds). This portfolio strategically allocates to asset classes that the investment manager believes offer better risk reward metrics relative to its benchmark over an appropriate investment period. The portfolio over‐weights US Midcap equities and international small cap equities and underweights large cap international developed equities relative to its benchmark. In addition to stock market risk, the fund is also subject to currency risk and country risks. Investors with a long‐term time horizon seeking growth of principal over time and who can accept stock market volatility may wish to allocate to this portfolio. e. Peak Aggressive Allocation Model (Benchmark: 90% MSCI ACWI / 10% Barclays Aggregate Index) This portfolio offers investors an easy, cost‐effective way to gain exposure to mainly stocks with minimal exposure to bonds. The portfolio invests roughly 90% in stocks and 10% in bonds. The portfolio’s benchmark is 90% MSCI ACWI Index (global equity) and 10% Barclays US Aggregate Index (US bonds). This portfolio strategically allocates to asset classes that the investment manager believes offer better risk reward metrics relative to its benchmark over an appropriate investment period. The portfolio over‐weights US Midcap equities and international small cap equities and underweights large cap international developed equities relative to its benchmark. In addition to stock market risk, the fund is also subject to currency risk and country risks. Investors with a long‐term time horizon seeking growth of principal over time and who can accept stock market volatility may wish to allocate to this portfolio. C. Client Investment Guidelines and Parameters Advisory services include, among other things, providing advice regarding asset allocation and the selection of investments. Decisions relating to investment advice are based on an analysis of the merits and risks of the investment involved and on the investment guidelines and restrictions of the client. The methods of analysis, investment strategies and risk of loss for each Fund are described in the private placement memorandum related to each Fund. The Firm does not tailor advisory services to the needs of individual retail or non-accredited investors. When applicable for federally insured depository institutions as defined in Part 1 of Title 12, Code of Federal Regulations as it applies to acceptable investments for banks, CSIA follows the investment parameters set forth in each client’s board approved Investment and Asset-Liability Committee (“ALCO”) Policies and Procedures as further refined by updated minutes from each Board’s Investment Committee and ALCO Committee. In such instances, securities transactions are non- discretionary and the final investment decision rests with the client’s designated Investment Officer. All transactions are for “delivery versus payment” at the client’s designated clearing and safekeeping agent. CSIA neither purchases, nor sells, nor accepts or makes delivery or takes custody of client securities, cash, or cash equivalents. D. Wrap Fee Programs The Firm does not participate in wrap fee programs. E. Client Assets Under Management (All amounts rounded up to the nearest $100,000) As of December 31, 2023, Total Assets Under Management (“AUM”) = $745,146,120 1. Discretionary AUM: $214,137,212 2. Non-discretionary AUM: $531,008,908