DESCRIPTION OF ADVISORY FIRM Mercer Advisors was founded in 1985 by Kendrick Mercer and started as a law practice focused on estate planning for professionals and families. In May of 2008 Mercer Advisors registered with the Securities and Exchange commission. Today, Mercer Global Advisors Inc. (“Mercer Advisors”) is a private company that is owned (indirectly through parent companies) by employees, as well as outside investors. Mercer Advisors is organized as a corporation. Mercer Advisors serves individuals, families, small business owners, plan sponsors, foundations, non-profits, and endowments. Mercer Advisors provides discretionary and/or non-discretionary investment advisory services on a fee basis. As of December 31, 2023, the firm provided discretionary investment management services on assets of $44.7 billion and non-discretionary advisory services on assets of $350 million. To the extent requested by a client, Mercer Advisors can also provide financial planning, tax planning, retirement planning, and estate planning consulting services, and tax preparation services. Planning and consulting services are offered to clients in varying combinations and with various corresponding fee arrangements depending upon the level and scope of the requested service(s) to be provided. If Mercer Advisors subsequently determines that the client requires additional and/or extraordinary planning and/or consultation services (to be determined in the sole discretion of Mercer Advisors), Mercer Advisors can determine to charge for such additional and/or extraordinary services, the dollar amount of which shall be set forth in a separate written notice to the client. INVESTMENT ADVISORY SERVICES Mercer Advisors provides discretionary investment advisory services on a fee basis. Mercer Advisors’ annual investment advisory fee includes investment advisory services, and to the extent specifically requested by the client and agreed upon by the applicable agreement, financial planning, and related services (e.g., tax, estate planning, etc.). If the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Mercer Advisors), Mercer Advisors can determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. Before engaging Mercer Advisors to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Mercer Advisors setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. In addition, the client must also enter into a separate custodial/clearing agreement with a designated broker-dealer/custodian. To commence the investment advisory process, Mercer Advisors will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Mercer Advisors thereafter provides ongoing supervision of the account(s). Mercer Advisors generally requires the client(s) to grant our firm discretionary authority to manage their account(s). Discretionary authorization allows Mercer Advisors to determine the specific securities to be purchased or sold for your account without the client’s prior consent. Mercer Advisors has a fiduciary duty to provide services consistent with the client’s best interest. Mercer Advisors will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, market conditions, factor exposure, asset class or style drift, account additions/withdrawals, and/or a change in the client’s investment objective, financial position, or tax situation. Based upon these factors, it is not uncommon that an extended period of time will pass where Mercer Advisors determines that changes to a client’s portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. 5 Mercer Global Advisors Inc. – ADV Part 2A TRUSTEE DIRECTED PLANS Mercer Advisors provides discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Mercer Advisors will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Mercer Advisors will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. PARTICIPANT DIRECTED RETIREMENT PLANS Mercer Advisors can also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Mercer Advisors and the plan. For such engagements, Mercer Advisors shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (this can include investment strategies devised and managed by Mercer Advisors), and, to the extent engaged to do so, can also provide corresponding education to assist the participants with their decision-making process. Mercer Advisors provides can also provide non-discretionary advisory services to ERISA retirement plans whereby the firm provides the Sponsor and the Plan with the recommended diversified investment options for the Plan from which Plan participants can choose. If allowed, Mercer Advisors can also create specific asset allocation models (the “Models”) comprised of any and/or all of the designated investment alternatives. The Sponsor maintains absolute discretion as to whether to accept any of the Adviser’s recommendations, including the Models. CLIENT RETIREMENT PLAN ASSETS AND ROLLOVER 401(k) plan. If requested to do so, Mercer Advisors can provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, Mercer Advisors shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Mercer Advisors’ ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Mercer Advisors will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Mercer Advisors of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by Mercer Advisors to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Registrant calculating its advisory fee. Mercer Advisors provides can also provide non-discretionary advisory services to ERISA retirement plans whereby the firm provides the Sponsor and the Plan with the recommended diversified investment options for the Plan from which Plan participants can choose. Retirement Rollovers. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Mercer Advisors recommends that a client roll over their retirement plan assets into an account to be managed by Mercer Advisors, such a recommendation creates a conflict of interest if Mercer Advisors will earn new (or increase its current) compensation as a result of the rollover. If Mercer Advisors provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Mercer Advisors is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to 6 Mercer Global Advisors Inc. – ADV Part 2A roll over retirement plan assets to an account managed by Mercer Advisors, whether it is from an employer’s plan or an existing IRA. CHARITABLE AND NON-PROFIT ORGANIZATIONS Mercer Advisors offers investment management and planning for charities and non-profits. To engage the firm for discretionary investment management an advisory agreement must be executed for Mercer Advisors to begin providing services. In addition to investment management, the organization can also engage Mercer Advisors for:
• Working with non-profit boards on investment policy statements and asset allocation strategy
• Planning for grants and other distributions; spending policy analysis
• Board education, particularly with respect to the fiduciary obligations of all parties
• Analysis of appropriate portfolio approaches, including environmental, social, and corporate governance (Cash Sweep) considerations. INVESTMENT STRATEGIES Mercer Advisors seeks to build globally diversified portfolios that are diversified across and within major global asset classes. Mercer Advisors’ investment strategies incorporate, as appropriate:
• Strategically weighted investments designed to systematically isolate, capture, and compound incremental return from academically validated factors including value, size, momentum, high profitability, quality, low-beta, dividend yield, term, and credit factors.
• Broad asset class and multi-factor diversification to help diversify risk.
• Where possible, we utilize low expense ratio vehicles such as ETFs, index funds, and institutional funds.
• Interval funds or private funds to invest in private asset classes such as private equity, private credit, real estate, real assets, infrastructure, or hedge fund strategies.
• Systematic rebalancing to maintain a targeted risk/return profile.
• Sophisticated tax and distribution management. Primarily through Envestnet Asset Management, Inc. (“Envestnet”) and Orion Advisor Services, Inc. (“Orion”), unaffiliated registered investment advisers that offers various services to independent investment advisers such as Mercer Advisors, we have access to a full range of fee-based investment offerings, research and due diligence on asset managers and funds, flexible online reporting on client accounts, and automation of essential back-office functions. Through Envestnet and Orion, we utilize web-based platforms to construct and rebalance client portfolios. For various reasons, including embedded taxable gains, clients transferred to Mercer Advisors from acquired firms may continue to maintain investment holdings, strategies, and managers acquired prior to their Mercer Advisors engagement. It is Mercer Advisors’ general intention to eventually transition such assets to appropriate Mercer Advisors offered investments and/or investment strategies. 7 Mercer Global Advisors Inc. – ADV Part 2A INVESTMENT PROGRAMS MARKET SERIES PROGRAM Harness the benefits of low-cost global diversification
• Globally diversified asset allocation portfolios are designed to provide broad, global asset class diversification.
• Flexible approach to portfolio implementation allows for use of any combination of approved, low-cost index mutual funds, index ETFs, or index-oriented Separate Account solutions (including direct indexing strategies and/or technologies).
• Tax-management solutions available for clients with low basis legacy positions.
• Broad range of risk-based allocations available. MULTIFACTOR SERIES PROGRAM Put academic research to work in your portfolio
• Globally diversified asset allocation portfolios are designed to provide broad global asset class diversification combined with tilts to academically identified factors such as value, profitability, quality, and momentum (among others).
• A flexible approach to portfolio implementation allows for the use of any combination of approved mutual funds, ETFs, or separate account solutions.
• As appropriate, it may include allocations to interval funds or private funds providing access to various private markets asset classes or alternatives strategies.
• Tax-management solutions available for clients with low basis legacy positions.
• Broad range of risk-based and US-only allocations available. INCOME SERIES PROGRAM Generate income to provide for retirement, education, and more
• Globally diversified asset allocation portfolios designed to provide broad global asset class diversification combined with an emphasis on income-oriented asset classes such as dividend-paying equities and non-investment grade bonds (among others).
• Flexible approach to portfolio implementation allows for use of any combination of approved mutual funds, ETFs, or separate account solutions.
• As appropriate, may include allocations to interval funds or private funds providing access to various private markets asset classes or alternatives strategies.
• Tax-management solutions available for clients with low basis legacy positions.
• Broad range of risk-based and US-only allocations available. ESG SERIES PROGRAM Align your portfolio with your values
• Globally diversified asset allocation portfolios designed to provide broad, global asset class diversification using mutual funds, ETFs, and Separate Account solutions focused on incorporating Environmental, Social, and Governance (“ESG”) considerations into portfolio construction and maintenance.
• Flexible approach to portfolio implementation allows for use of any combination of approved ESG-oriented mutual funds, ETFs, or Separate Account solutions.
• Overlay program allows clients to customize their portfolios, using approved separate account solutions and a variety of values-based screens provided by Envestnet|PMC.
• Tax-management solutions available for clients with low basis legacy positions.
• Broad range of risk-based allocations available. 8 Mercer Global Advisors Inc. – ADV Part 2A SMA PROGRAM & UMA PROGRAM Mercer Advisors can allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated Independent Managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager shall have day-to-day responsibility for the active discretionary management of the allocated assets. Mercer Advisors shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Factors which Mercer Advisors shall consider in recommending an Independent Manager include the client’s designated investment objective(s), management style, performance, reputation, reporting, pricing, and research. The fee paid to the selected managers will be in addition to the advisory fees paid to Mercer Advisors. The fee charged by the manager, terms of payment, and termination of service, is determined by the manager. Mercer Advisors Independent Manager Program provides clients (working through their advisor) the opportunity to invest, as appropriate, in any number of approved Separately Managed Accounts (SMA)
• SMA solutions are available for equities, fixed income (both taxable and tax-exempt), real estate, MLPs, preferred stocks, and covered call writing.
• Most approved SMAs are also UMA-compatible, allowing for their use in combination with other SMAs, mutual funds, and ETFs within a single account. Please Note The investment management fee charged by the Separate Account Manager[s] is separate from, and in addition to, Mercer Advisors’ investment advisory fee disclosed at Item 5 below. Clients of firms acquired through an acquisition could be invested in a proprietary SMA strategy administered by the acquired firm. At some point subsequent to acquisition, it is Mercer Advisors’ general intention to transition such acquired firm clients to corresponding appropriate Mercer Advisors offered investments and/or investment strategies. Mercer Advisors’ UMA programs provide clients—working through their advisor—the opportunity to build, as appropriate, customized portfolios using any combination of approved separate account solutions, mutual funds, and/or ETFs. In doing so, advisors work directly with the firm’s Investment Strategy Group (“ISG”) to build customize solutions uniquely tailored to clients’ individual goals, objectives, risk tolerances, and constraints. ANNUITIES Mercer Advisors offers access to no-load variable annuities. The investment selections for the variable annuities are limited to the choices offered through the specific products. Specifics regarding the annuities are found in the annuities’ prospectuses and application documents. Mercer Advisors can provide initial and ongoing advisory services regarding the allocation among, and monitoring of, the investment choices within the variable annuity product. Unless expressly indicated by Mercer Advisors to the contrary, in writing, the client’s variable annuity assets shall be included as assets under management for purposes of Registrant calculating its advisory fee. SCHWAB INSTITUTIONAL INTELLIGENT PORTFOLIOS For certain clients acquired through mergers and acquisitions, we offer an automated investment program (the “Program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds and mutual funds (“Funds”) and a cash allocation. The client can instruct us to exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with, sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact 9 Mercer Global Advisors Inc. – ADV Part 2A with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). Based on the information the client provides to us, we will recommend a portfolio via the System. The client can then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we make the final decision and select a portfolio based on all the client information. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. We do not pay SPT fees for the Platform as long as we maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or request that our clients with accounts not enrolled in the Program be maintained with CS&Co. While clients are required to use CS&Co. as custodian/broker to enroll in the Program, the client decides whether to do so and opens its account with CS&Co. by entering into a brokerage account agreement directly with CS&Co. We do not open the account for the client. If the client does not wish to place his or her assets with CS&Co., then we cannot manage the client’s account through the Program. ALTERNATIVE INVESTMENTS Alternative investments can add value to the portfolios of qualified high-net-worth clients. Mercer Advisors can recommend certain alternative investments for use as part of a diversified, Mercer Advisors-managed investment strategy. These investments carry risk and are designed for investors that meet qualified purchaser, qualified client, or an accredited investor requirements as defined by the Securities and Exchange Commission (“SEC”). Subscribing to a privately offered alternative investment is a legal contract that is enforceable by the fund sponsor. Clients should take their capital commitments seriously. Alternative investments are not liquid and cannot be readily sold or converted to cash or other securities. Clients should ensure they have adequate liquidity before choosing to invest. See additional important disclosure regarding Unaffiliated Alternative Investment Funds in the Miscellaneous section below. OTHER SERVICES FINANCIAL PLANNING SERVICES AND CONSULTING SERVICES Mercer Advisors can provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, divorce planning, etc.) to the extent specifically requested by a client. Financial planning or consulting fees are negotiable as described in Item-5 Fees and Compensation. Depending on the types of financial planning services requested, the client may be required to pay a separate fee in addition to the fees paid to Mercer Advisors for investment advisory services. per our standard Wealth Management Agreement. Mercer Advisors provides certain clients with access to an online platform hosted by eMoney Advisor Advisors, LLC (“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that Mercer Advisors does not manage (the “Excluded Assets”). Mercer Advisors does not provide investment management, monitoring, 10 Mercer Global Advisors Inc. – ADV Part 2A or implementation services for the Excluded Assets. The client can choose to engage Mercer Advisors to manage some or all Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Mercer Advisors and the client. The eMoney platform also provides access to other types of information and/or reports, including financial planning concepts. The generated information and/or reports are provided for educational purposes only and the client should not rely on it as the primary basis for insurance, investment, financial, or tax planning decisions. The generated report is not a recommendation of any investment strategy or transaction, rather it is a tool for Mercer Advisors and the client to collaboratively: (i) confirm the accuracy of the information on the client’s risk tolerance, investment objectives and other personal and financial information, and (ii) solicit the client’s input and feedback to refine the approach for the client’s financial future. Mercer Advisors shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without Mercer Advisors assistance or oversight. FAMILY WEALTH SERVICES The goal for many high-net-worth families is to maintain and enhance their family legacy over multiple generations. Centralized wealth management is fundamental to this long-term wealth preservation objective. The Mercer Advisors Family Wealth Services Team offers cohesive personalized solutions designed to help grow, protect, and transfer wealth across generations. Estate Planning services comprise complete estate planning review; extensive tax management, including exploration of the potential tax gaps between client intentions, existing plans, and ever-changing tax landscape; fraud protection for personal, business, and entity interests, and long-term care insurance analysis and recommendation. Mercer Advisors’ team integrates a variety of sophisticated estate planning tools, allowing for the strategic and purposeful distribution of family wealth across generations, as directed by each client’s family vision. Please Note: Mercer Advisors is not a law firm, it does not prepare estate planning documents, and no portion of its services should be construed as legal advice or services. See disclosures regarding ASLG and Tax Specialist below. ESTATE PLANNING Mercer Advisors offers clients estate planning document preparation and other legal services through the law firm Advanced Services Law Group, Inc. (“ASLG”). Estate Planning Strategists employed by Mercer Advisors in our Estate Planning group separately act as Counsel with ASLG to provide these legal services to clients that specifically engage ASLG for such services. Although

we recommend clients use the services of ASLG, clients are never obligated or required to use such services. The services of Mercer Advisors and ASLG are separate and distinct from one another, each with a separate agreement and compensation arrangement for services rendered. There is no common ownership between Mercer Advisors and ASLG. TAX PLANNING AND PREPARATION Mercer Advisors offers a proactive tax planning service. Tax specialists can assist clients at the beginning of the year to create and implement a customized tax plan that helps minimize tax liability throughout the year. As the year progresses, Tax Specialists can continue to analyze and support clients’ tax needs to maintain a well-organized tax plan. Mercer Advisors’ Tax Specialists can help forecast future client needs to implement long-term strategies aimed at helping reduce client tax liability in years to come. Mercer Advisors offers tax preparation services. Clients needing tax preparation may utilize our team of tax professionals and CPAs but are not obligated to do so. If you choose to engage us for tax preparation services, you will typically enter into a separate agreement and pay a separate fee in addition to the fees paid to Mercer Advisors for investment advisory or other services. Please Note: Mercer Advisors is not a certified public accounting (CPA) firm. 11 Mercer Global Advisors Inc. – ADV Part 2A RETIREMENT PLANNING DESIGN AND ADMINISTRATION Mercer Advisors offers fiduciary investment management and fiduciary investment advisory services to employer sponsored retirement plans. Mercer Advisors partners with third-party recordkeepers and third-party administrators to provide retirement plan design, documentation, and administration services to meet each plan’s unique objectives. Mercer Advisors‘ retirement plans, when optimally designed, can provide many advantages including, 100% deductible contributions made to a Qualified Plan (up to established limits), tax deferred investment income generated within the plan, benefit distributions not subject to FICA or other payroll-based taxes, tax-free loan options based on plan balance, and should a plan participant experience financial difficulties, his/her plan assets are creditor-protected – an added level of retirement asset protection. Mercer Advisors offers to provide a comprehensive analysis of the client’s unique business demographics, financial resources and core philosophies in order to design a retirement program — a single plan or multiple programs – that maximizes the sponsor’s retirement savings and tax advantages. Mercer Advisors works with third-party recordkeepers and third-party administrator service providers to provide retirement plans with tailored administration options, including Profit Sharing, 401(k), Cash Balance, and Defined Benefit plans. Each retirement plan offers a range of alternatives to fit the client’s needs, including flexible contribution, multiple vesting, and numerous investment options. Additionally, retirement plans are granted access to Mercer Advisors’ institutional-grade investment strategies. Clients also receive a quarterly newsletter and discounted plan administration (through Mercer Advisors’ recommended administrators). Professional unaffiliated third- party administrative staff perform all administrative functions for each client plan to help ensure its continued Retirement Plan status, is in compliance with all applicable federal regulations. DIVORCE SERVICES Mercer Advisors may be engaged to provide divorce planning consulting services per the terms and conditions of a separate agreement and fee (fee arrangement to be disclosed in the agreement). The objective of the service is to assist the divorcing clients, and their respective divorce counsel(s), to understand the financial implications of various financial planning scenarios related to their divorce case and settlement options. Mercer Advisors is not a law firm and does not provide legal services. No portion of its consulting services serves as a substitute for the engagement of qualified divorce legal counsel. Given that Mercer Advisors will be providing services to divorcing clients, Mercer Advisors’ engagement can present conflicts of interest, and all parties must be guided accordingly. No client is under any obligation to engage Mercer Advisors for such services. The clients are encouraged to address any such prospective divorce planning engagement with their respective legal counsel. WELLTHY – HEALTH CARE CONCIERGE SERVICES Mercer Advisors has partnered with Wellthy to offer care management concierge services to clients with at least $1MM in assets under management. Wellthy is an unaffiliated third-party vendor that offers a caregiving platform (the “Platform”) to help our clients address the logistical and administrative tasks of caring for the ones they love. Costs are determined by Wellthy and no referral fees are received by Mercer Advisors for clients who choose to utilize the Platform. Mercer Advisors will provide the first six (6) months of the service free of charge to a qualifying client. After six months, the client can choose to continue to utilize Wellthy at a cost of $450 per care project, charged directly to the specified client account. Although Mercer Advisors recommends Wellthy service, no client is under any obligation or requirement to use the Platform service as part of their Mercer Advisors’ relationship or continue to utilize this service after the initial six-month period. The services of Mercer Advisors and Wellthy are separate and distinct from each other, each with a separate agreement and compensation arrangement for services rendered. Clients can engage Wellthy directly, independent of Mercer Advisors, and could pay more or less for Wellthy than if they engage Wellthy through Mercer Advisors. In addition, the services provided by Wellthy may be available from other vendors at a higher or lower cost than that charged by Wellthy. 12 Mercer Global Advisors Inc. – ADV Part 2A Mercer Advisors does not provide health care concierge services and no portion of our services should be construed as such. IMPORTANT INFORMATION REGARDING THE ADVISORY BUSINESS INTERVAL FUNDS/RISKS AND LIMITATIONS Where appropriate, Mercer Advisors utilizes interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and will not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors can sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client can direct Mercer Advisors, in writing, not to employ any or all such strategies for the client’s account. SOCIALLY RESPONSIBLE INVESTING LIMITATIONS Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that maintain an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Mercer Advisors), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. MUTUAL AND EXCHANGE TRADED FUNDS Mercer Advisors uses mutual funds and exchange traded funds for its client portfolios. In addition to Mercer Advisors’ investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). USE OF DFA MUTUAL FUNDS Mercer Advisors utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate Mercer Advisors 13 Mercer Global Advisors Inc. – ADV Part 2A services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. CASH POSITIONS Mercer Advisors continues to treat cash as an asset class. As such, unless determined to the contrary by Mercer Advisors, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for the purposes of calculating Mercer Advisors’ advisory fee. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Mercer Advisors’ advisory fee could exceed the interest paid by the client’s money market fund. CASH SWEEP ACCOUNTS Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. UNAFFILIATED ALTERNATIVE INVESTMENT FUNDS Mercer Advisors also provides investment advice regarding alternative investment funds. Mercer Advisors, on a non- discretionary basis, recommends that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. Mercer Advisors’ role relative to unaffiliated alternative investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Mercer Advisors calculating its investment advisory fee. Mercer Advisors’ fee shall be in addition to the fund’s fees. Mercer Advisors’ clients are under no obligation to consider or make an investment in any private investment fund(s). Alternative Investments- Alternative investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity, constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associate with such an investment. Valuation- In the event that Mercer Advisors references alternative investment funds owned by the client on any supplemental account reports prepared by Mercer Advisors, the value(s) for all alternative investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if after the purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If after the purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected in the report until the fund provides a further updated value. Please Also Note: As a result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, Mercer Advisors shall calculate its fee based upon the lates value provided by the fund sponsor. SEPARATE ACCOUNT MANAGERS 14 Mercer Global Advisors Inc. – ADV Part 2A As indicated above, Mercer Advisors can allocate a portion of the client’s investment assets among unaffiliated separate account managers in accordance with the client’s designated investment objective(s). In such situations, the Separate Account Manager[s] shall have day-to- day responsibility for the active discretionary management of the allocated assets. Mercer Advisors shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that Mercer Advisors shall consider in recommending Separate Account Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The client is under no obligation to engage a Separate Account Manager[s]. Please Note The investment management fee charged by the Separate Account Manager[s] is separate from, and in addition to, Mercer Advisors’ investment advisory fee disclosed at Item 5 below. Clients of firms acquired through an acquisition could be invested in a proprietary SMA strategy administered by the acquired firm. At some point subsequent to acquisition, it is Mercer Advisors’ general intention to transition such acquired firm clients to corresponding appropriate Mercer offered investments and/or investment strategies. REPORTING SERVICES Mercer Advisors can also provide account reporting services, which can incorporate client investment assets that are not part of the assets that Mercer Advisors manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or his/her/its other advisors that maintain trading authority, and not Mercer Advisors, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, in writing, Mercer Advisors does not provide investment management, monitoring or implementation services for the Excluded Assets. The client can engage Mercer Advisors to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Mercer Advisors and the client. NON-DISCRETIONARY SERVICE LIMITATIONS Clients that determine to engage Mercer Advisors on a non-discretionary investment advisory basis must be willing to accept that Mercer Advisors cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Mercer Advisors would like to make a transaction for a client’s account, and client is unavailable, Mercer Advisors will be unable to affect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. In performing our services, Mercer Advisors shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Mercer Advisors if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. INVESTMENT RISK Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Mercer Advisors) will be profitable or equal any specific performance level(s). LIMITATIONS OF FINANCIAL PLANNING AND NON-INVESTMENT CONSULTING/IMPLEMENTATION SERVICES To the extent requested by the client, Mercer Advisors will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. Mercer Advisors will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur 15 Mercer Global Advisors Inc. – ADV Part 2A based upon assets under management, special projects, extraordinary events or circumstances, stand-alone planning engagements, etc. for which Firm charges a separate or additional fee). Please Note: Mercer Advisors believes that it is important for the client to address financial planning issues on an ongoing basis. Mercer Advisors’ advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Mercer Advisors. Please Also Note: Mercer Advisors does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Mercer Advisors does not prepare legal documents or sell insurance products. To the extent requested by a client, we will recommend the services of other professionals for non-investment implementation purposes (e.g., attorneys, accountants, insurance, etc.), including Mercer Advisors’ affiliates, Mercer Advisors Insurance Services, LLC (“Insurance” ) and Heim, Young &Associates, Inc. (“HYA”), in their separate capacities as licensed insurance agencies, and HYA’s separate capacity as an SEC registered and FINRA Member broker-dealer. In such capacities, Insurance and/or HYA can offer both insurance and securities- related advice and products on a commission compensation basis. Certain of Mercer Advisors’ representatives also serve as licensed agents and registered representatives of Insurance and HYA. In addition, some Mercer Advisors representatives offer insurance products on a commission compensation basis in their separate individual licensed capacities independent of Insurance or HYA, and as registered representatives of a broker-dealer other than HYA. The commission compensation earned by Insurance and or HYA and its agents/representatives is separate from, and in addition to, Mercer Advisors investment advisory fee. Please Note- Conflict of Interest: The recommendation by a Mercer Advisors representative that a client consider the purchase of an insurance product from Insurance or HYA presents a conflict of interest, as the potential receipt of an insurance or securities commission compensation by Insurance or HYA and its agent(s) provides an incentive for Mercer Advisors representatives to recommend insurance products based on compensation to be received by its affiliated entity and representative rather than on a particular client’s needs. No client is under any obligation to purchase any insurance product from a Mercer Advisors’ affiliated entity or from an employee of Mercer Advisors. Clients can purchase insurance and securities products through other, non-affiliated insurance agencies, agents, broker-dealers, and registered representatives. CUSTODIAN CHARGES-ADDITIONAL FEES As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Mercer Advisors generally recommends that Schwab, Fidelity, or Raymond James serve as the broker-dealer/custodian for client investment management assets. Broker-dealers charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab, Fidelity, and Raymond James do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that any of these custodians will not change their transaction fee pricing in the future. These fees/charges are in addition to Mercer Advisors’ investment advisory fee at Item 5 below. Mercer Advisors does not receive any portion of these fees/charges. PORTFOLIO ACTIVITY Mercer Advisors has a fiduciary duty to provide services consistent with the client’s best interest. Mercer Advisors will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, 16 Mercer Global Advisors Inc. – ADV Part 2A but not limited to, investment performance, market conditions, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Mercer Advisors determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Use of Pontera Platform: Mercer Advisors uses an investment platform made available by Pontera Solutions, Inc. (“Pontera”), a third-party online platform, to assist with management of clients’ “held-away” accounts, including 401(k)s, 403(b)s, annuities, and 529 education savings plans. The Pontera platform permits advisers to manage held- away assets without having to reflect that it has custody of such assets on Part 1 of Form ADV. The advisory fee charged by Mercer Advisors for the management of held-away assets is established in the client’s Investment Advisory Agreement. Pontera charges Mercer Advisors an annual fee based upon the percentage of assets managed in the held- away accounts. Other than Mercer Advisors’ advisory fee, clients do not pay any additional fee to Pontera or to Mercer Advisors in connection with the use of the Pontera platform. SUB-ADVISORY/REFERRAL ARRANGEMENT WITH AFFILIATE, REGIS ACQUISITION INC. Sub-Advisory: Mercer Advisors has engaged its affiliated SEC registered investment adviser, Regis Acquisition Inc.(“Regis”) to assist Mercer Advisors with the management of client accounts per the terms and conditions of a written Sub-Advisory Agreement. The sub-advisory service is intended for clients who have assets under management of at least $25 million. Mercer Advisors shall maintain both the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client suitability for the corresponding investment strategies. As part of its sub-advisory services, Regis shall assist Mercer Advisors with due diligence, monitoring, and reporting services pertaining to unaffiliated private investment funds, including new private investment funds owned by Mercer Advisors’ client for which the client desires to receive Regis’ sub-advisory services. Mercer Advisors' engagement of Regis for sub-advisory services shall not result in the client paying an additional fee. Rather, Mercer Advisors shall compensate Regis with a portion of the investment advisory fee that Mercer Advisors receives from its clients. All assets subject to the Regis sub-advisory arrangement shall be billed by Mercer Advisors and payable by the client on a quarterly, in arrears, basis (a portion of which quarterly fee shall then be remitted by Mercer Advisors to Regis.) Mercer Advisors shall provide its affected clients with a copy of Regis’ written disclosure Brochure as set forth on Part2A of Form ADV; and Referral Arrangement: In addition to the sub-advisory arrangement, Mercer Advisors and Regis could introduce clients to the other in return for referral compensation. Such referral arrangement shall not result in the client paying an additional fee. Rather, the referred-to adviser entity shall compensate the introducing adviser with a portion of the investment advisory fee that the referred-to adviser receives from the introduced client. See disclosure pertaining to referral arrangement at Item 14 below.