SWBC Investment Advisory Services, LLC (“SWBC” or the “Firm”) is an SEC Registered Investment Advisory firm. We are a wholly owned subsidiary of Southwest Business Corporation, established in April 1976. Southwest Business Corporation also owns SWBC Investment Services, LLC (a FINRA registered Broker/Dealer) and SWBC Investment Company, Inc. (an SEC Registered Investment Advisor). SWBC provides advisory services to the retirement plan market with fiduciary responsibility as defined by Employee Retirement Income Security Act of 1974, as amended (“ERISA”). This is accomplished by defining services for two market segments. The first is referred to as our consulting practice, which concentrates on the custom requirements of an individual retirement plan sponsor. The second is referred to as our institutional practice, which develops and manages an enterprise- level advisory discipline for groups of retirement plan sponsors with similar characteristics using a single recordkeeping vendor solution. Consulting Practice SWBC provides advisory services to organizations sponsoring retirement plans which may include 401(k) plans, 403(b) plans, pension plans, profit sharing plans, IRAs, and non-qualified plans, collectively referred to as plan sponsors (“Plan Sponsor”). SWBC requires each Plan Sponsor to make a selection of services in writing as part of the Advisory Services Agreement (“ASA”), which sets forth the rights and obligations of SWBC and the Plan Sponsor. SWBC provides ERISA Section 3(21) services as an investment advisor and ERISA Section 3(38) services as an investment manager to both retirement plans (“Plan(s)”) and Plan participants (“Participants”). These services are offered at a Plan Sponsor level where SWBC will create investment models and allocations based upon internal research and analysis performed by SWBC. The goal of these investment models and allocations is to assist Participants in the diversification of their retirement investments. SWBC acknowledges its status as a fiduciary under Section 3(21)(A) or Section 3(38) of ERISA, with respect to certain advisory services provided to the Plan Sponsor and to Participants pursuant to the terms and conditions of the ASA and/or other applicable agreements. SWBC will not assume fiduciary status or any liability with respect to investment options, products, or services that are not recommended by SWBC or are otherwise excluded as detailed in the ASA. From time to time and upon request, the Firm provides group and individual educational sessions to plan participants on behalf of Plan Sponsors. Advisory Services (both fiduciary and non-fiduciary) include, but are not limited to: Plan Sponsor Investment Advisory Services
• Serving as Fiduciary as defined by ERISA
• Investment Policy Statement Development and Management
• Review and Analysis of Existing Investment Options
• Investment Option Search, Selection and/or Replacement
• Investment Option Monitoring and Due Diligence
• Quarterly Performance Reporting and Review
• Asset Allocation Analysis
• Model Portfolio Development and Management
• Investment Option Mapping
• Individual Participant education Institutional Practice The Firm provides ERISA Section 3(21) services as an investment advisor and ERISA Section 3(38) services as an investment manager to both Plans and Participants. SWBC serves as an investment advisor or investment manager solely to Plans and Participants, not to retirement plan providers (“Platform Providers”). These services will be offered at a platform level where SWBC will create investment models and allocations based upon internal research and analysis performed by SWBC. The goal of these investment

models and allocations is to assist participants in the diversification of their retirement investments. Plan Sponsor clients should be aware that SWBC’s recommendations are limited to the universe of investment options currently available within each Platform Provider’s platform/product, which is selected solely by Plan Sponsors. The investments available within each Platform Provider’s platform/product are selected solely by the Platform Provider with no input from SWBC regarding those investments made available or the share class selected for use with each investment and reflects the relationship between the Platform Provider and Plan Sponsor. Each Platform Provider maintains several recordkeeping platforms/products, each with its own costs and expenses, which ultimately dictate the specific share classes made available for each investment within each platform/product. SWBC has no authority or responsibility to select which investment products and share classes are available within the universe of investment options. SWBC will not consider available share classes when creating investment models and allocations for Plans. The decision regarding the Platform Provider platform/product to be used, and the associated pricing structure that will apply, is solely that of the Plan Sponsor and SWBC is, therefore, limited in its recommendations as a result of the Plan Sponsor’s platform/product decision. It is possible that selection of an alternative Platform Provider platform/product would result in the use of alternative investment share classes, reduced cost, and/or increased investment returns. SWBC also works with Platform Providers that serve a variety of Plan Sponsors in order to facilitate the services provided to Plan Sponsors through their platform/product. SWBC does not provide advisory services to Platform Providers, therefore, in these arrangements, SWBC makes it clear that SWBC is obligated to act solely in the interest of the participants and beneficiaries of each Plan Sponsor. SWBC requires each Plan Sponsor to sign an ASA, which sets forth the rights and obligations of SWBC and the Plan Sponsor. As applicable, SWBC acknowledges its status as a fiduciary under Section 3(21)(A) or Section 3(38) of ERISA, with respect to advisory services provided to the Plan Sponsor and Plan Participants pursuant to the terms and conditions of the ASA and/or other applicable agreements. SWBC will not assume fiduciary status or any liability with respect to investment options that are not recommended by SWBC or are otherwise excluded as detailed in the ASA. Advisory Services (both fiduciary and non-fiduciary) include: Plan Sponsor Investment Advisory Services
• Serving as Fiduciary as defined by ERISA
• Investment Policy Statement Development and Management
• Investment Option Search, Selection and/or Replacement (subject to investment
• availability and share class selection decisions imposed by the Platform Provider for
• each platform/product)
• Investment Option Monitoring and Due Diligence
• Quarterly Performance Reporting and Review
• Investment Option Mapping As referenced above, SWBC also works with Platform Providers in order to facilitate the advisory services provided to Plan Sponsor clients utilizing their platforms; however, under no circumstances does SWBC serve in a fiduciary capacity to Platform Providers. While SWBC does receive compensation from Platform Providers for various services, these services and compensation are independent of the services provided to Plan Sponsors and Participants. We do not believe do not believe that these services or compensation creates a conflict of interest with the services provided to Plan Sponsors and their Participants. Further details will be provided upon request.