A. General description of the Firm Intelli�lo Advisers, Inc. (“Intelli�lo Advisers”) is a provider of TAMP Services via a managed accounts team and platform designed to help registered investment advisers (a “Firm” or “Firms”) service their client accounts by providing adviser ef�iciency tools, outsourced services, and portfolio administration. Intelli�lo TAMP Services are offered under the Intelli�lo Managed brand. Intelli�lo Advisers has been in business since 2008 and is an indirect subsidiary of Invesco Ltd., a publicly traded independent global investment management �irm dedicated to helping investors worldwide achieve their �inancial objectives. Invesco Group Services, Inc. is the direct owner of Intelli�lo Advisers; Invesco Ltd. is the ultimate parent company. Common stock shares of Invesco Ltd. are listed on the New York Stock Exchange under the symbol “IVZ.” Invesco Ltd. is a constituent of the S&P 500. Intelli�lo Advisers’ services are offered to Firms in accordance with the terms of a written service contract. Intelli�lo Advisers has no advisory relationship with any such Firm’s clients. B. Summary of Intelli�lo Advisers’ Advisory Services Intelli�lo TAMP Services is a managed account team and platform that provides outsourced services and other operational needs for managed accounts. We help Firms service their client accounts by providing adviser ef�iciency tools and portfolio administration under the Intelli�lo Managed brand. Intelli�lo Managed: a comprehensive wealth management platform that combines streamlined operational management of billing, performance reporting, account paperwork and third-party custodial relationships along with powerful trading and rebalancing capabilities; all of which can be con�igured to a Firm’s requirements.
• For Firms that engage our Intelli�lo Managed solution, Intelli�lo Advisers may serve as a sub- advisor to a client’s account. Intelli�lo Managed services are provided directly to Firms and a contractual relationship exists only between Intelli�lo Advisers and the Firm. Our Intelli�lo Managed solution offers overlay services including outsourced middle of�ice investment services such as daily allocation monitoring, rebalancing, trading, cashiering, billing and reporting to Firms. Intelli�lo Advisers has a contractual relationship with a Firm and does not have a direct relationship with an end investor. We rely entirely on the registered investment adviser to provide a client’s investment objective and strategy; to assess a client’s risk pro�ile; and to determine appropriateness of its investment advice to the client. Intelli�lo Advisers does not interact directly with a Firm’s clients nor does it offer �inancial advice to clients. Intelli�lo Advisers and Invesco have no obligation or advisory responsibility to a Firm’s client. This includes no obligation or responsibility (i) to provide individualized advice based on the goals or circumstances of a particular client, (ii) to determine the appropriateness or suitability of the model portfolios for any particular client, or (iii) to determine the appropriateness or suitability of any

security included in the model portfolio of any particular client. Through a power-of-attorney, Intelli�lo Advisers may have limited advisory discretion over a Firm’s client accounts. In practice, this means that we may have the authority to determine the holdings, amounts to be traded, and the spread or commission rates paid to broker-dealers. All such activity will be in line with the investment objective and guidelines of a client’s account (as communicated to us by a Firm). C. Firms elect which model investment portfolios to incorporate with Intelli�lo TAMP Services Intelli�lo TAMP Services is an open architecture platform. Firms may elect to use their own model portfolios, select from a range of available Invesco model portfolios and third-party model portfolios, or use a combination of such model portfolios within an account. Invesco model portfolios may include underlying registered investment companies (the “Invesco Funds”) advised by Intelli�lo Advisers’ af�iliated investment advisers, including, but not limited to, Invesco Advisers, Inc. or Invesco Capital Management LLC (collectively, “Invesco”). The inclusion of Invesco model portfolios, which may include Invesco Funds, creates a con�lict of interest for Intelli�lo Advisers because Invesco receives compensation when Firm clients invest in the Invesco Funds. Each Firm that contracts with Intelli�lo Advisers and elects to use Invesco model portfolios or products on its platform must acknowledge this con�lict of interest. Furthermore, Intelli�lo Advisers receives compensation from certain model providers, including Invesco Advisers, Inc. This compensation may be used to reduce fees charged to Firms that use these model portfolios. If a Firm chooses to participate in a model discount program offered by Intelli�lo Advisers and implements model portfolios that are eligible for a discount, thereby bene�itting from cost reductions offered by Intelli�lo Advisers, the Firm must agree to disclose this con�lict of interest to its clients in accordance with its regulatory obligations. Firms are responsible for (i) interposing their own judgment in making investment decisions for clients, (ii) implementing and trading the model portfolios and (iii) determining whether the model portfolios are suitable for their clients. Unless the Firm has engaged Intelli�lo Advisers for implementing and trading the model portfolios, the responsibility of rebalancing and trade execution is retained by the Firm. Intelli�lo TAMP Services can be con�igured to meet the needs and requirements of each speci�ic Firm. Intelli�lo Advisers may accommodate a Firm’s speci�ic rebalancing and tax harvesting rules and asset allocation models within reason. However, it is the responsibility of the Firm to ensure the models and any underlying securities included in the models, and the risk mapping associated therewith, are appropriate for each of its clients. D. Wrap Fee Programs Intelli�lo Advisers does not participate in wrap fee programs. E. Assets under management As of December 31, 2023, Intelli�lo Advisers managed a total $90,650,605 on a discretionary basis.