Janney Montgomery Scott LLC (“Janney”, the “firm”, “us”, “we” or “our”) was established in 1832 and is an indirect wholly owned independent subsidiary of The Penn Mutual Life Insurance Company. Janney is based in Philadelphia, Pennsylvania and is organized as a limited liability company under the laws of Delaware. As of December 31, 2023, Janney manages approximately $54,649,177,208 of Client assets on a discretionary basis and approximately $31,245,993,217 of Client assets on a non-discretionary basis. As a dually registered broker-dealer and investment adviser, Janney provides brokerage and investment advisory services to a broad range of Clients. The investment advisory services offered to Clients include advice on asset allocation and investment strategies, the selection of investment managers, portfolio management, investment policy development, portfolio analysis, portfolio rebalancing, portfolio performance monitoring, financial planning, and consulting services. Clients may negotiate other investment advisory services with the Firm. As a full-service broker-dealer and investment adviser, Janney is engaged in a broad range of activities including individual and institutional brokerage transactions; origination of, and participation in, underwritings of corporate and municipal securities; market making and trading activities in corporate securities and municipal and governmental bonds; distribution of mutual funds shares; options transactions; and research services. Janney offers investment advisory services primarily through its Wealth Management Department. The investment advisory services generally fall within one of four broad business lines: (A) wrap fee programs (programs that typically provide investment advice, brokerage trading and custody and reporting for a fee); (B) financial planning services; (C) retirement plan investment advisory services; and (D) consulting services. The Wealth Management Department works closely with the firm’s Private Client Group, including the firm’s Financial Advisors (“FA(s))”, in providing investment advisory services to Clients. We provide investment advisory services on a discretionary and non-discretionary basis. There can be no assurance that any particular strategy will be successful in achieving the Client’s investment goals and objectives. Any investment in the securities markets involves risk, including the realization of investment loss. None of the services described herein are intended as, or meant to be a substitute for, legal, accounting, actuarial or tax advice. All such matters should be discussed with your legal, accounting, actuarial and tax advisors. Wrap Fee Programs Janney currently offers eleven (11) fee-based advisory “wrap” programs that are broadly characterized as professional money management, asset allocation and internal portfolio management services (each a “Program” and collectively, the “Programs”). Clients within the Advisory Programs generally pay one all- inclusive fee that is not based on transactions executed in the account. Services provided include investment management, custody, reporting, performance-monitoring and trade execution services. JANNEY MONTGOMERY SCOTT LLC PAGE - 6 Janney offers the following Programs, which are described in greater detail below: Professional Money Management Asset Allocation Internal Portfolio Management Adviser’s Keystone Discretionary Partners Advisory Adviser’s MSP ETF Advantage Compass Classic Janney Goals-Based Portfolio Solutions (GPS) Investors Select (formerly FIED) Janney Capital Management Direct Pioneer Professional Money Management Adviser’s Under the Adviser’s Program, a Janney Financial Advisor will recommend one or more investment strategies of Third-Party Managers (each a “Strategy” and collectively, the “Strategies”) based on a Client’s investment objectives, risk tolerance and specific needs. Janney may add or terminate a Strategy; Clients with assets in a Strategy are notified when the Strategy is terminated. Depending on our arrangement with the Third-Party Manager, a Strategy may be implemented and traded directly by the Third-Party Manager (“Manager-Traded Strategy”), or Janney may implement the Strategy and conduct all trading in the account pursuant to the Third-Party Manager’s recommendations (“Model- Based Trading Strategy”). Manager-Traded Strategies For Manager-Traded Strategies, Janney has entered into a sub-advisory agreement with each Third-Party Manager, which governs the advisory services and responsibilities to be rendered by the Third-Party Manager. Janney completes initial and ongoing due diligence for each Third-Party Manager in the Adviser’s Program, described in detail in the Portfolio Manager Selection & Evaluation section of this Brochure. The Third-Party Manager for a Manager-Traded Strategy assumes full discretionary portfolio management responsibilities over each account invested in the Strategy. Each Third-Party Manager is responsible for determining the securities to be bought and sold for the Strategy, and for directly implementing those decisions for the accounts invested in the Strategy. Depending on the Manager- Traded Strategy selected, purchases and sales may be made by the Third-Party Manager on behalf of Client in different types of securities including, but not limited to, corporate bonds, common or preferred stocks, options, warrants, rights, or government bonds or notes, unless otherwise restricted by Client. It is understood that all or a portion of the account may be held in cash. A Third-Party Manager is permitted to place trades through Janney in its capacity as a broker-dealer, or through other broker-dealers if the Third-Party Manager determines that such other broker-dealer is providing best execution in light of all applicable circumstances. If a Third-Party Manager executes a trade through a broker-dealer other than Janney, there will most likely be a commission or mark-up on the trade that wouldn’t have been charged if the trade was executed through Janney. Please see the Brokerage Practices Section for further information regarding Step-Out trades. JANNEY MONTGOMERY SCOTT LLC PAGE - 7 Model-Based Strategies With respect to Model-Based Strategies, each Third-Party Manager has entered into an agreement with a Third-Party Model Provider utilized by Janney that governs the provision of the investment recommendations to Janney for each of the Third-Party Manager’s Strategies. Janney implements the Strategies for Janney clients, executes all trades in the Accounts invested in the Model-Based Strategy and has investment discretion over the Accounts. Adviser’s MSP Under the Adviser’s MSP Program, Janney offers clients the ability to invest in strategies managed by Third-Party Managers, Janney model portfolios created and managed by Janney’s Wealth Management Research Department (“WM Research”), mutual funds and/or exchange-traded products, such as exchange-traded funds and exchange-traded notes (collectively, “ETPs”) in one Janney Account under different “sleeves.” Janney provides overlay portfolio management services for Adviser’s MSP Program Accounts including assigning the investment amount to be managed in each sleeve and executing the investment strategy assigned to such sleeves. Janney also provides investment advice, brokerage and trade execution, custody and other services with respect to the Account. Janney utilizes the Third-Party Model Provider to facilitate the strategy offerings in the Adviser’s MSP Program. The Third-Party Model Provider has contracted with the Third-Party Managers and Janney to collect, provide and maintain strategies for the Adviser’s MSP Program. Janney will provide discretionary investment management services to the Account by utilizing the Third-Party Model Provider’s overlay management and technology processes to access the Third-Party Manager’s strategies, along with the ETPS or mutual funds designated by the Client or Janney, as appropriate. Janney, and not the Third-Party Managers, will manage the Account under the Adviser’s MSP Program. Janney will be solely responsible for investing all securities and cash within each assigned sleeve. Clients appoint Janney to provide overlay management and to act as the Client’s agent and attorney-in-fact with discretionary power to manage the investment and reinvestment of assets including, but not limited to, transactions involving the purchase and sale of registered investment company(ies) shares, including ETPs, and any other securities for the Account in the Client’s name consistent with Client’s stated investment objectives and risk tolerance, as provided by the Client to Janney. There are two options available to Clients for each account under the Adviser’s MSP Program. Under the Client Discretion option, the information Clients provide to Janney is used, in consultation with the Client, to develop an individualized investment strategy. The Client, with the assistance of the Janney Financial Advisor, will select a mix of third-party investment managers, Janney WM Research models, ETPs and/or mutual funds that is consistent with the Client’s stated investment objectives and risk tolerance, as provided by the Client in the risk tolerance questionnaire, subject to minimum investment requirements and the value of the Advisory Account. Under the Advisor Discretion option, the Client delegates full responsibility to the Janney Financial Advisor to develop an individualized investment strategy for asset allocation and investment selection using the mix of third-party investment managers, Janney WM Research models, ETPs and/or mutual funds that is consistent with the Client’s stated investment objectives and risk tolerance, as provided by the Client in the risk tolerance questionnaire, subject to minimum investment requirements and the value of the Advisory Account. JANNEY MONTGOMERY SCOTT LLC PAGE - 8 Your Janney Financial Advisor may replace a strategy, model, ETP and/or mutual fund selected by the Client without prior notice to Client in the event a strategy, model, ETP or fund is no longer recommended or made available as an investment option by Janney. Janney will provide Client with notice of any such change. Where the particular strategy adopted with respect to any Account may comprise only a portion of the Client’s investment and tax strategy and may not, in and of itself, be consistent with the Client’s overall stated investment objectives and risk tolerance. Janney shall use its best efforts in managing the Account to attain the stated investment objective of the Account. Each strategy, model portfolio, ETP and mutual fund will represent a “sleeve” of the Account. Clients have the right to impose reasonable investment restrictions on the Account, including restricting investments in specific securities or industry sectors. Such restrictions and inclusions must be communicated to Janney and are subject to the specific approval of Janney or the relevant Third-Party Managers in their sole discretion. In accommodating restrictions of a specific security or type of security to be included in the Account, Janney or the Third-Party Managers may, in lieu of acquiring any such restricted securities: (i) select a security from a list of alternatives provided by Janney or the Third-Party Managers; (ii) select a comparable security in its discretion; or (ii) select no substitute security and instead either (A) increase the amount of other securities included in the investment portfolio or (B) place or invest the funds allocated to the rejected security in a money market account or money market mutual fund. Client may amend or modify the restrictions on the Account by contacting Janney either in writing (including e-mail) or verbally. Restriction changes are subject to acceptance by Janney or the Third-Party Manager. The Third-Party Manager and Janney shall be entitled to rely upon written clarifications, supplements and modifications to the investment restrictions from the Client. Reasonable interpretations of the investment restrictions made in good faith by the Third-Party Manager and Janney shall be binding upon the parties. Classic In the Classic Program, Third-Party Managers selected by the Client provide portfolio management services for assets held in a Janney account. In many cases, the Client has a pre-existing relationship with the Third-Party Manager and seeks to continue that relationship after transferring their account to Janney. If the Client selects this Program, the Client is responsible for setting up the portfolio manager relationship with the Third-Party Manager, including executing an investment advisory agreement directly with the Third-Party Manager. Janney’s initial and ongoing due diligence of such Third-Party Managers is limited in comparison to the due diligence process performed for the Third-Party Managers in the Adviser’s and Adviser’s MSP Programs. Janney does not recommend or select the Third-Party Manager and we assume no responsibility for the Client’s selection or termination of the Third-Party Manager or for the investment decisions, performance, compliance with applicable laws, or any other matters involving the Third-Party Manager. As the investment advisor of the account, a Janney Financial Advisor will offer investment advice to the client with respect to the assets managed by the Third-Party Manager and whether they are consistent with the Client’s stated investment objectives and risk tolerance, as provided by the Client. Janney has the right to terminate any Third-Party Manager under the Classic Program at Janney’s sole discretion. Janney Capital Management Direct Janney Capital Management LLC (“Janney Capital”) is a wholly owned subsidiary of Janney and an SEC- registered investment adviser. Under the Janney Capital Management Direct Program, Janney Capital JANNEY MONTGOMERY SCOTT LLC PAGE - 9 provides portfolio management services on a discretionary basis. A Janney Financial Advisor will assist the Client in selecting an investment strategy of Janney Capital through the Client’s stated investment objectives and risk tolerance. Janney Capital’s portfolio management services may employ equity-only, balanced, fixed income-only and asset allocation strategies. Typically, individual securities, municipal bonds, corporate bonds, preferred securities, exchange-traded funds, exchange-traded notes and mutual funds are used to execute the strategies. When appropriate to the needs of the Client, Janney Capital may recommend the use of short- term trading (securities sold within 30 days), government securities, short sales, margin transactions or options writing. Because these investment strategies involve certain degrees of risk, they will only be recommended when consistent with the Client’s stated tolerance for risk. In addition to the strategies discussed above, Janney Capital offers the Dynamic Asset Strategy and the Dynamic Income Strategy (collectively, the “Dynamic Strategies”). Under these strategies, Janney Capital establishes an asset allocation by assessing an asset class’s comparative attractiveness given current and expected market conditions. The Dynamic Strategies seek competitive total returns compared to the overall capital markets and do not have a predetermined asset class mix. Accounts invested in the Dynamic Strategies may be invested actively across asset classes but may also be concentrated in specific asset classes that Janney Capital believes offers the best opportunity for capital appreciation or above average income generation. Such flexibility in portfolio construction has the risk of exposing Client accounts to decreases in value due to concentration in certain securities or asset classes. Asset Allocation Keystone Discretionary Under the Keystone Program, the Client authorizes Janney Capital to provide discretionary investment management services for the Client’s account. A Janney Financial Advisor will assist the Client in selecting an investment strategy through the Client’s stated investment objectives and risk tolerance and will recommend a target asset allocation. The Janney Capital asset allocation models are constructed with a portfolio construction process focused on expected return, volatility and correlation to the asset allocation model. Generally, accounts will be invested in a portfolio of load waived and no-load mutual funds, exchange-traded funds (“ETFs”) and exchange-traded notes (“ETNs”) in accordance with the recommended asset allocation model. Janney Capital may, in its sole discretion, invest in any other type of security in the Client’s account. The following asset allocation models are available under the Keystone Program.
• Equity Growth
• Diversified Growth
• Balanced 60/40
• Balanced 40/60
• Diversified Income
• Current Income ETF Advantage The ETF Advantage Program is a long-term investment program investing primarily in investment portfolios of exchange-traded products selected by Janney Capital. Under the ETF Advantage Program, JANNEY MONTGOMERY SCOTT LLC PAGE - 10 the Client authorizes Janney Capital to provide discretionary investment management services for the Client’s account. The Janney Financial Advisor will assist the Client in selecting an investment strategy through the Client’s stated investment objectives and risk tolerance and will recommend a target asset allocation. The Client’s account under this Program will generally be invested in a portfolio of exchange- traded

securities, including but not limited to ETFs and ETNs. Janney Capital may, in its sole discretion, invest in any other type of security in the Client’s account. The following asset allocation models are available under the ETF Advantage Program.
• Equity Growth
• Diversified Growth
• Balanced 60/40
• Balanced 40/60
• Diversified Income
• Current Income Goals-Based Portfolio Solutions (GPS) Program Under the Goals-Based Portfolio Solutions (GPS) Program, a Janney Financial Advisor will recommend an investment allocation from Third-Party Managers. Client’s account will be invested in a suitable model portfolio formulated and maintained by a Third-Party Manager consisting of the Third-Party Manager’s proprietary no-load mutual funds or exchange traded funds. Clients grant Janney full investment discretion with respect to buying, selling, holding, converting and exchanging securities and other assets in the account consistent with the selected model portfolio, including any modifications to such model portfolio, and any client restrictions. The Janney Financial Advisor will periodically discuss with Client their financial circumstances and investment objectives. Janney Financial Advisors are not compensated for providing investment advisory services to Client accounts in the GPS Program when the Client’s account balance falls below $10,000. Therefore, a conflict of interest exists between the Client’s interest and the interests of Janney and Janney Financial Advisors when recommending the Client make additional deposits into the GPS Program when the account balance is under $10,000. Janney has procedures in place to ensure that any recommendation to participate in the GPS Program by a Janney Financial Advisor is based upon the Client’s stated investment objectives and in the best interest of the Client. Pioneer Under the Pioneer Program, a Janney Financial Advisor will recommend an investment strategy consistent with the Client’s financial circumstances, investment objectives and risk tolerance. The Janney Financial Advisor will have several options in the Pioneer Program when providing investment management services; (1) select a model portfolio created by a Third-Party Manager or (2) select a Janney model portfolio developed and managed by WM Research. Janney Capital is responsible for and provides general oversight and maintenance, on a non-discretionary basis, of select equity model portfolios provided by Janney’s WM Research and based on analysis by a third-party research provider. Clients grant Janney full investment discretion with respect to buying, selling, holding, converting and exchanging securities and other assets in the account consistent with the selected model portfolio, and any client restrictions accepted by Janney at its sole discretion. JANNEY MONTGOMERY SCOTT LLC PAGE - 11 Portfolios may include mutual funds, exchange traded products and equities. Client assets will generally be invested in one or more model portfolios developed or approved by Janney. Janney will invest and reinvest the assets in the account in a portfolio of securities, cash or cash equivalents (such as money market funds) or other instruments that is compatible with the Client’s stated investment objectives and risk tolerance, as provided by the Client to Janney, generally consistent with the model portfolios. Internal Portfolio Management Partners Advisory In the Partners Advisory Program, a Client retains Janney to provide non-discretionary advisory services. With assistance from a Janney Financial Advisor, Clients can direct the assets to align with their investment objectives and risk tolerance. The Janney Financial Advisor will provide advice and recommendations to the Client with respect to the investment of the securities and cash in the account. At the discretion of Janney’s Wealth Management Department, certain Financial Advisors may be granted limited exceptions to the Partners Advisory Program’s investment guidelines and may be permitted greater latitude in their recommendations to the Client of certain securities and investment strategies. Janney does not have investment discretion under the Partners Advisory Program. Ultimately, it is the Client’s decision whether to implement any or all such recommendations provided by the Janney Financial Advisor. As such, Clients should carefully consider whether the Partners Advisory Program is best aligned to meet their stated investment goals. To make this assessment, a Client should review all relevant factors, including the Client’s investment objectives, risk tolerance, past and anticipated trading practices, current assets, current investments, the value and type of investments to be held in the account, anticipated use of other investment advisory services, and the costs and benefits of the account. If a Client elects to direct their own investment strategies notwithstanding the investment advisory advice and recommendations they receive from a Janney Financial Advisor, a transactional brokerage account may be more suitable. The costs of a Partners Program account may be more or less than the cost of a brokerage account that is assessed transaction-based commissions. A Partners Advisory Program may not be appropriate if the Client anticipates little or no trading activity, high levels of cash or cash equivalents, or a desire to engage in transactions not otherwise permitted in the Partners Advisory Program. If a Client’s Partners Advisory Account experiences no trade activity or maintains a high cash balance, as determined by Janney, for an extended period of time, Janney may in its sole discretion, immediately, upon sending notice to the client, terminate the Partners Advisory Account and convert the account to a transaction-based brokerage account. Compass Under the Compass Program, a Janney Financial Advisor will provide investment advice and management to the Client on a discretionary basis. When an account is managed on a discretionary basis, the Financial Advisor has the ability to direct and execute transactions without consulting with the Client. In other words, a Janney Financial Advisor, and not the Client, has the discretion to decide what securities to buy and sell in Client accounts. A Janney Financial Advisor will assist the Client in selecting an investment strategy through the Client’s stated investment objectives and risk tolerance. In order to qualify to manage accounts under the Compass Program, Janney’s Wealth Management Department will review a Janney Financial Advisor’s experience, education, and investment philosophy and methods for managing client assets. A Janney Financial Advisor in the Compass Program may develop specific investment strategies that include investing in multiple or single asset classes, model portfolios or JANNEY MONTGOMERY SCOTT LLC PAGE - 12 some other distinct investment strategy. Financial Advisors will implement a strategy across multiple Client accounts or take a more customized approach to management of Client accounts. A Janney Financial Advisor is primarily responsible for making and implementing investment management decisions for a Client account within the Compass Program’s investment guidelines. The guidelines specify the types of securities eligible for investment in a Compass Program account. In the event an account in the Compass Program experiences no trade activity or maintains a high cash balance, as determined by Janney, for an extended period of time, Janney may in its sole discretion, immediately, upon sending notice to the client, terminate the Compass Account and convert the account to a transaction-based brokerage account. At the discretion of Janney’s Wealth Management Department, certain Financial Advisors may be granted limited exceptions to the Compass Program’s investment guidelines and may be permitted greater latitude in selecting securities and diversification. Therefore, the availability of investment strategies and securities and the applicability of investment limitations vary depending on a Client’s particular Janney Financial Advisor. Additionally, and also at its discretion, Janney’s Wealth Management Department may re-assign Clients’ accounts to another Financial Advisor if the Client’s Financial Advisor is terminated as an employee of Janney. In that event, Janney may convert the account to the Partners Advisory Program and continue to provide investment advice on a non-discretionary basis. The Compass Program’s guidelines are subject to change without notice. Depending on the investment strategy the Financial Advisor uses, investments may include equity and fixed income securities, certain closed-end funds, mutual funds, UITs and exchange-traded funds. All or a portion of a Client’s account may be held in cash or cash equivalents, including securities issued by money market mutual funds or deposited in interest-bearing bank accounts. Janney also makes available to Clients in the Compass program, Alternative Investments such as private equity, hedge funds, and real estate. Due to the complex nature of Alternative Investments, Janney offers these products on a non- discretionary basis only to pre-qualified sophisticated investors such as accredited investors or qualified purchasers. Where approved, Financial Advisors may use certain option strategies, such as covered call writing and purchasing protective puts. Janney has developed certain investment parameters, which may limit the Client’s investment options under the Compass Program. These investment parameters were instituted in order to limit risk to the Client. A Janney Financial Advisor may make investment decisions that are contrary to research ratings issued by WM Research or that may differ from other Financial Advisors, Janney Capital Management, Janney’s Capital Markets Equity Research team or asset allocations provided by Janney’s Investment Strategy Group (ISG). Investors Select Under the Investors Select Program, a Janney Financial Advisor will provide investment advice and manage the Client account on a discretionary basis. The Investors Select Program is available for those clients that require individualized discretionary services, such as those clients who work for other financial industry firms that prohibit their employees to hold securities accounts at Janney unless the account(s) is managed by a Janney Financial Advisor or a third-party manager on a discretionary basis. A Janney Financial Advisor will execute recommended securities transactions on the Client’s behalf with full discretion. JANNEY MONTGOMERY SCOTT LLC PAGE - 13 Financial Planning Services Janney offers financial planning services through the Wealth Planning group within its Wealth Management Department. The plan delivered includes a list of the client’s current financial assets related to the purpose of the plan, a recommended investment strategy and/or asset allocation strategy and, in certain cases, a list of general investment recommendations. In a brokerage relationship, delivery of the completed written plan constitutes the end of the financial planning advisory relationship. Following delivery of the report, the client may elect to utilize Janney for additional brokerage or advisory services with respect to the implementation of any recommendations received. Any additional services or products including investment advisory or brokerage services rendered to or engaged by the client are incidental to the financial planning advisory service and, if applicable, will be covered under separate advisory, brokerage or similar agreement(s). In addition to Janney’s Wealth Planning group, certain Janney Financial Advisors perform one-time investment reviews for their clients. Such reviews consist of written reports delivered after the client has completed a questionnaire and discussed their assets, liabilities, and financial requirements with the Janney Financial Advisor. This service may or may not constitute an investment advisory service, but if the service is considered to be investment advisory in nature, the investment advisory relationship terminates upon the delivery of the final report. The client may then opt to implement the plan with Janney and subsequent products and services may or may not be advisory in nature, but will be covered under separate advisory, brokerage or similar agreements if applicable. Retirement Plan Investment Advisory Services Janney works with employers and plan administrators (the “Plan Sponsor”) to offer investment advisory and consulting services to ERISA qualified retirement plans (each, a “Plan”) by providing advice with respect to the investment options offered by the employer-sponsored Plan. Janney will not serve as a custodian for Plan assets in connection with Retirement Plan Investment Advisory Services. The Plan Sponsor is responsible for selecting the custodian for Plan assets. The custodian for Plan assets is responsible for providing the Plan with periodic confirmations and statements. Janney offers services that are non-discretionary in nature and are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan. Janney generally does not accept investment discretion over plan assets or any participant’s investments in conjunction with providing the investment advisory services. Janney provides these non-discretionary investment advisory services directly by our Financial Advisors and are not offered through any of Janney’s Wrap Fee Programs. If the Plan is covered by ERISA, Janney will perform these investment advisory services to the Plan as a "fiduciary" defined under ERISA Section 3(21). Plan Sponsors may engage Janney to perform one or more of the following investment advisory fiduciary services and non-fiduciary consulting services. The applicable Advisory Agreement will delineate which services are considered fiduciary and non-fiduciary:
• Assistance in the development and maintenance of investment policy statement
• Review and recommendation of investment selections
• Ongoing investment monitoring
• Periodic investment performance and reporting JANNEY MONTGOMERY SCOTT LLC PAGE - 14
• Provider due diligence and evaluation
• Participant services related to enrollment and investment education
• Plan consulting Janney will work with the Plan Sponsor to tailor the services provided to the needs of each Plan as described in the applicable Advisory Agreement. Janney may also provide related ancillary assistance concerning the Plan’s ongoing administration and operation. A description of the fees charged for Retirement Plan Investment Advisory Services can be found in the “Fees and Compensation” section of this Disclosure Brochure under “Retirement Plan Investment Advisory Services Fees.” Consulting Services Janney offers certain advisory services on a consulting basis. These services include Client needs assessments, investment profiles, on-going portfolio review, periodic performance measurements, adviser monitoring, and other services agreed upon by the Client and Janney. Janney will recommend Third-Party Managers, mutual funds and/or other investments for the Client that we believe are appropriate given Janney’s understanding of the Client’s risk tolerance and investment objective. The Client is under no obligation to act on any of Janney’s recommendations. The Client retains absolute discretion over all such investment decisions and is free to accept or reject any recommendation from the Financial Adviser. Additional Information Regarding Janney’s Investment Advisory Business and Services Clients can impose investment restrictions under the Programs by notifying us in writing of the type of restrictions they wish to impose on their accounts. Under certain Programs, the Client can also restrict certain assets from being purchased into or sold out of the Client’s account by notifying us in writing, and in all Programs, a Client can restrict securities purchases in certain asset classes by notifying us in writing. Restrictions are subject to the approval of Discretionary Managers. Accounts with restricted positions may perform differently, and in some cases perform worse than, those accounts without restrictions. In an effort to limit certain kinds of risk to the firm and Clients, Janney reserves the right to apply purchase restrictions on certain security types and investment strategies including, but not limited to, cryptocurrencies, digital assets and special purpose acquisition companies (“SPACs”). Investment Company Prospectus Delivery By electing to participate in a Discretionary Program where Janney, or a third-party investment manager, exercises discretionary authority in connection with managing your Account, excluding the Compass and Investors Select wrap programs, Clients authorize Janney and/or the third-party investment manager to receive the investment company securities prospectus that has been purchased for the account(s) on their behalf. In the event a third-party investment manager elects not to receive the investment company securities prospectuses on behalf of clients, Clients will receive the prospectuses directly. Clients can receive investment company security prospectuses directly, in lieu of delivery to Janney or the third-party investment manager by submitting the request to their Financial Advisor. Clients that continue to receive investment company security prospectuses directly will also receive proxy material directly. JANNEY MONTGOMERY SCOTT LLC PAGE - 15