1. About Our Company Associated Investment Services, Inc. (“the Firm,” “AIS,” “we,” “our”), is an indirect wholly-owned non-bank affiliate of Associated Banc-Corp (“AB-C”), a bank holding company. AB-C is a diversified bank/financial services holding company headquartered in Green Bay, Wisconsin. AIS traces its history as a broker-dealer back to 1923 through its predecessor firm. AIS began its advisory business in 2004. In July 2010, AIS became a federally-registered investment adviser with the SEC. The Firm also is registered with the SEC and 50 states as a broker-dealer, is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”), and is an insurance agency. As a broker-dealer and an insurance agency, the Firm receives compensation through commissions/sales charges on transactions. Associated Bank, N.A. (“ABNA”), a nationally chartered bank, Associated Trust Company, N.A. (“ATC”), a nationally chartered trust company, and Kellogg Asset Management LLC (“KAM”), a federally registered investment adviser, are affiliated with AIS. All are under the common control of AB-C. By agreement with ABNA, AIS provides its brokerage and advisory services to ABNA customers and the public on and through ABNA branch offices. All Financial Advisors are licensed insurance agents of AIS, and Senior Financial Advisors also are officers of ATC. Insurance products are the obligations of the issuing insurance companies. ABNA and AB-C provide administrative and operational support to AIS that is material to AIS’s advisory business. Support includes office space and equipment, financial, audit and accounting services, executive management, marketing, and legal and compliance services. 2. Types of Advisory Services We Offer We want clients to understand the role of AIS in their advisory accounts and to understand how their accounts work. The following summary is intended to help provide that understanding. (a) Introduction and General Information AIS offers advisory account programs developed by BlackRock Investment Management, LLC or one of its affiliates (collectively, “BlackRock”), Envestnet Asset Management, Inc. or one of its affiliates (collectively, “Envestnet”), Fidelity Institutional Wealth Adviser LLC or one of its affiliates (collectively, “Fidelity”), Innealta Capital, LLC (“Innealta”), KAM, Pacific Investment Management Company LLC (“Pimco”), Russell Investment Management Company (“Russell”), Vanguard Advisers, Inc. (“Vanguard”), and Wilshire Associates Incorporated (“Wilshire”), all of which are delivered through National Financial Services LLC, an affiliate of Fidelity (“NFS”). Those programs are each referred to herein as “Advisory Programs,” and AIS is the Program Sponsor. In addition to offering advisory account programs, Envestnet also provides a technology and service platform more fully described below that is integrated with NFS’s platform. Collectively, these are referred to as the “Program” throughout this document. Fees paid to Envestnet and NFS for operating the Program are included in the Program fees described below. Envestnet initiates a deduction of the fee from the client’s Advisory Program account from the cash position maintained in the account to meet this requirement. If the cash position is insufficient at the time the fees are deducted from the account, assets will be liquidated to cover the fee and a fee deduction will be made after the liquidated shares are settled. Envestnet then pays AIS, NFS, and any program manager utilized as part of one of the programs per agreements with each party. NFS has a technology service agreement with Envestnet to access the Envestnet platform via its managed accounts solution interface. AIS has a master clearing agreement with NFS. AIS has a tri-party agreement for its managed accounts solution with NFS and Envestnet. Separately, BlackRock, Fidelity, KAM, Pimco, Russell, Vanguard, and Wilshire each has an agreement with Envestnet to make their models available on the Envestnet platform. In addition, AIS and KAM have an intercompany service agreement that, among other things, enables AIS to offer the ASAP Program to its clients. AIS’s advisory relationship begins when the client meets with an AIS Financial Advisor. The client and the Financial Advisor gather the client’s personal and financial information and determine which type of Advisory Program, if any, is appropriate for the client. Utilizing the Envestnet platform tools, the Financial Advisor recommends an appropriate investment strategy based on the client’s needs, objectives, investment time horizon, risk tolerance, and any other pertinent factors. After an account is approved, BlackRock, Envestnet, Fidelity, Innealta, KAM, Pimco, Russell, Vanguard, or Wilshire, as the case may be, manage their models as they deem appropriate. They do not provide individualized investment advice for any particular client. Each Advisory Program option is described below. (b) Description of Associated Select Advisor Portfolio (ASAP) Program The ASAP program is managed by KAM, an affiliate of AIS. KAM uses third-party mutual funds to build diversified portfolios that can meet a variety of investment objectives and risk tolerances. The ASAP program offers six investment strategies that range from aggressive growth to conservative balanced, as described below. KAM considers a number of factors when evaluating the mutual funds included in the ASAP portfolios, including evaluating fund managers’ relative performance in the context of their respective styles. Other factors that are considered when selecting funds for inclusion in the ASAP models are as follows: quality and length of portfolio managers’ experience, as well as confidence that the current manager will remain in place; a consistently applied investment methodology; demonstrated success as a result of employing this methodology; analysis of current fund performance within the context of ongoing market dynamics; the compatibility of the fund’s asset size with its objective; consistency is favored over “hit or miss” results; and reasonable expenses. There is a $50,000 account minimum for the ASAP Program. (c) Description of the Russell Strategist Models The Russell Strategist Models are managed by Russell Investment Management Company and distributed by Russell Financial Services, Inc. (collectively “Russell”), and both are subsidiaries of Frank Russell Company. The Russell Strategist Models are a series of broadly diversified multi-asset portfolios delivered through Envestnet as multi-manager mutual fund portfolios. The portfolio model strategies span the risk return spectrum including a conservative, moderate, balanced, growth, and equity growth models in core and tax managed versions, depending on investor needs. Each portfolio is constructed as a diversified portfolio of Russell funds with Russell acting as an overlay manager and distributor of each. Russell evaluates and selects from a global group of portfolio managers to manage discrete portions of each of the funds in the portfolio. Russell itself directly manages one or more of the discrete portions if appropriate. Russell emphasizes broad manager diversification and will select from managers globally in each asset class and sub-class. There is a $50,000 account minimum for the Russell Strategist Model Program. (d) Description of Vanguard Strategist Models The Vanguard Strategist Models are managed by Vanguard Advisers, Inc. (“Vanguard”). Vanguard produces model portfolios (the “Vanguard Portfolios”) comprised of Vanguard mutual funds (“Vanguard Funds”) or exchange traded funds (“Vanguard ETFs”). The Vanguard Portfolios are designed and balanced to help ensure that their returns are in line with those of the respective benchmarks chosen for the Vanguard Portfolios. Vanguard administers the Vanguard Portfolios in accordance with pre-determined allocations that may be adjusted from time to time. The investment strategies offered through the Vanguard Portfolios are limited to allocations in Vanguard Funds and Vanguard ETFs. Vanguard does not manage assets on behalf of individual financial advisors or individual clients and does not tailor the Vanguard Portfolios to meet the needs of individual clients. There is a $50,000 account minimum for the Vanguard Core Strategist Model Program. (e) Description of Wilshire Strategist Models The Wilshire Strategist Models are managed by Wilshire Associates Incorporated (“Wilshire”). Wilshire is a privately held firm that uses a combination of actuarial science and investment principles to design portfolios. The Wilshire Strategist Models are several multi-asset portfolios designed around total allocation, diversified alternatives, global ETF strategies, income, and tax-free themes. Each portfolio is constructed as a diversified portfolio with Wilshire acting as the portfolio manager and distributor of each. Wilshire has the discretion to hire and terminate investment managers and rebalance portfolio assets as deemed necessary. Delegate consulting may be used at Wilshire’s direction to adjust asset allocations to meet ranges determined by the specific strategic model. There is a $50,000 account minimum for the Wilshire Strategist Model Program. (f) Description of the Innealta Dynamic ETF Portfolios The Innealta Dynamic ETF Portfolios are a series of ETF portfolios that are constructed using a quantitatively driven, tactical asset allocation

approach, making tactical shifts in allocation to try to capitalize on performance expectations of the various investment options. The Innealta Dynamic ETF Portfolios are managed by Innealta Portfolio Advisors, LLC, a quantitative consulting and advisory firm located in Charlottesville, VA. The portfolios are actively traded based on macroeconomic, fundamental risk, and technical variables caused by market movements to take advantage of long-term market imbalances relative to fixed income levels. The Innealta Dynamic ETF Portfolios offering includes “Tactical Core” balanced (equity/fixed income) portfolios, a Tactical Fixed Income portfolio, a Sector Core Rotation portfolio, and a Country Core Rotation portfolio. There is a $100,000 account minimum for the Innealta Dynamic ETF Portfolios. (g) Description of Envestnet Programs AIS offers several Advisory Programs made available through Envestnet (collectively, “Envestnet Advisory Programs”), as described in the detail below. All of Envestnet’s Advisory Programs, except for the Envestnet SMA Program, are managed by Envestnet PMC (“PMC”), a registered investment adviser and division of Envestnet. (i) American Funds PMC Active Core Portfolios PMC and American Funds have strategically constructed a set of mutual fund portfolios designed to combine the legacy of investment management at American Funds with the research, portfolio consulting, and management experience of PMC. The Active Core Portfolios emphasize selecting active managers that have both higher manager ownership and lower expense ratios. They are built primarily with an active management core of American Funds. They also can include other active managers that rank within the top percentiles versus their style group peers in terms of investing in their own funds and expense ratios. The portfolio types cover the risk/return and risk tolerance spectrum: capital preservation, conservative, conservative growth, moderate, moderate growth, growth, and aggressive. There is a $50,000 account minimum for the American Funds PMC Active Core Program. (ii) Envestnet SMA Program For the Envestnet SMA Program (aka “Manager Select”), the Financial Advisor uses Envestnet platform tools to assist the client in establishing an investment advisory account. Unlike a mutual fund, where the funds are commingled, a separately managed account is a portfolio of individually-owned securities that can be tailored to fit the client’s investing preferences. The client is offered access to a manager of an actively-managed investment portfolio chosen from a variety of disciplines (each a “sub-manager”). Envestnet retains the sub‐ managers for portfolio management services in connection with the Envestnet SMA Program through separate agreements entered into between Envestnet and the sub‐manager on terms and conditions that Envestnet deems appropriate. For certain sub‐managers, Envestnet has entered into a licensing agreement with the sub‐manager whereby Envestnet performs administrative and/or trade order implementation duties pursuant to the direction of the sub‐ manager. In such situations, the sub‐manager is acting in the role of a model provider whereby the sub‐ manager constructs an asset allocation and selects the underlying investments for each portfolio. Envestnet performs overlay management of the third-party models by implementing trade orders and periodically updating and rebalancing each third-party model pursuant to the direction of the model provider. Envestnet may, from time to time, replace existing model providers or hire others to create third-party models and cannot guarantee the continued availability of third-party models created by any particular model providers. There is a $100,000 account minimum for the Envestnet SMA Program. Each sub-manager has a minimum as well, some as high as $500,000. (iii) Envestnet SIGMA Program The SIGMA portfolios provide a disciplined and diversified approach to investing for the long-term. Choose from 7 levels of risk to design an appropriate balance of risk vs. potential return. PMC seeks top managers among all asset classes and fashions a strategic mix with institutional access and pricing for cost-effective portfolio management. There is a $50,000 account minimum for the SIGMA Program. (iv) PMC Strategic ETF Portfolios The PMC Strategic ETF Portfolios are discretionary strategy models constructed using ETFs. The portfolio strategies span the risk/return spectrum for investors who have risk profiles that vary from capital preservation to aggressive. The objective of the PMC Strategic ETF Portfolios is to provide clients with a long-term and diversified beta exposure through a series of low-cost and highly-liquid ETF portfolios. There is a $50,000 account minimum for the PMC Strategic ETF Portfolios. (h) Description of the BlackRock Models BlackRock develops and maintains model portfolios that are typically (often exclusively) comprised of BlackRock-affiliated mutual funds and/or ETFs. The models also may include mutual funds and/or ETFs that are not affiliated with BlackRock but do pay fees to BlackRock for providing management, administrative, or other services. The BlackRock ETF Target Allocation Portfolios incorporate an actively managed approach from one of the most well-known asset managers in the industry. Their target allocation portfolios offer 11 different models with equity/fixed income exposure available in 10% increments. There is a $50,000 account minimum for the BlackRock Model Program. (i) Description of the Pimco Models Pimco develops and maintains model portfolios that are typically (often exclusively) comprised of Pimco- affiliated mutual funds and/or ETFs. The model portfolios aim to provide exposure to investment strategies that collectively reflect Pimco’s investment outlook. The Pimco Fixed Income Portfolios are mutual fund portfolios that offer 3 taxable and 3 tax-aware strategies from one of the leaders in the fixed income space. There is a $50,000 account minimum for the Pimco Model Program. (j) Description of the Associated Wealth Builder Offerings The Associated Wealth Builder Offerings are generally available through the AIS Guidance Center to investors with up to $50,000 to invest. It includes portfolios across the risk spectrum from Fidelity’s Target Allocation Index Focused portfolios. There is a $5,000 account minimum for the Associated Wealth Builder Offerings. (k) Information on Services and Fees in Advisory Programs Offered by AIS (i) AIS Services and Client Meetings Each account is opened and initially funded based on the client’s needs, goals, time horizon, risk tolerance, and other factors, as discussed between the client and the Financial Advisor. For each Advisory Program, the Financial Advisor has the authority to recommend, and the client may agree, to invest in a portfolio model that is one level above, in terms of risk and investment objective, the model suggested through the system. There are no restrictions on how many levels below, in terms of risk and investment objective, that a Financial Advisor can recommend. Envestnet has limited discretion to develop and revise the various models and model portfolios and to select investment managers for inclusion in their programs. In the Envestnet SMA Program, day-to-day portfolio management is exercised by the particular investment sub-managers clients select. Clients are encouraged to contact their Financial Advisor whenever they have a question, periodically as part of a regular communication plan, or in the event of any material changes to their investment objectives or financial circumstances. Each client is expected to review such circumstances and their advisory account with their Financial Advisor at least annually. In support of this, the Financial Advisor will contact the client at least annually to conduct an account review. Clients may impose specific, reasonable restrictions concerning the types of securities that may be purchased for their account when an Advisory Program is chosen, during an account review, or at any other time. In addition, clients may make changes to their account(s) at any time in consultation with their Financial Advisor. (ii) General Information on Fees and Client Assets AIS receives a portion of the total fees billed and collected directly from the account, as a percent of the client’s assets under management. Client assets under management include all assets within an Advisory Program. The base fee for AIS services is set forth below in “Item 5 – Fees and Compensation.” Item 5 also includes information on the timing of fee calculations and payments. Fee discounting is available and is subject to senior management approval. (iii) AIS Assets Under Management AIS’s regulatory assets under management are calculated at approximately $862,552,767 as of December 31, 2023, all of which is managed on a nondiscretionary basis. (l) Financial Planning AIS began offering financial planning services in 2010 through Financial Advisors chosen by AIS in its discretion. Currently, there are no separate charges or fees for such financial planning services. AIS, however, may determine at any time to begin charging fees for its financial planning services. Such fees will be in amounts separately agreed to by the client and AIS. Financial planning services are delivered using software obtained through a vendor selected as the corporate standard for AB-C.