Description of the Advisory Firm Counterpoint Mutual Funds, LLC dba Counterpoint Funds (the “Investment Manager” or “Counterpoint”) was formed in the state of California as a limited liability company in 2014 primarily for the purpose of providing investment management to registered investment companies. Michael Krause, CFA, Daniel Krause, and John Koudsi are the firm’s principal owners. Description of Advisory Services Services to Registered Investment Companies Counterpoint generally provides portfolio management services to registered investment companies such as mutual funds and ETFs (“Fund(s)”). The firm uses quantitative models to form its investment strategies that are delivered in these public vehicles. Counterpoint adheres to any restrictions by regulation or fund policy for each Fund. Services to Platform Providers Counterpoint utilizes investment strategies similar to our strategies for the Funds we advise to build model portfolios. Counterpoint has entered into agreements with certain registered third-party investment advisers that maintain model platforms, sometimes called Turnkey Asset Management Platforms (“TAMPs”) or Separately Managed Account (“SMA”) platforms, collectively (“Platform Providers”). The Platform Providers offer model portfolios to other investment advisers or broker-dealers (“Advisers”), who select from among the available models to invest their clients’ assets. The platforms offer Counterpoint’s model portfolios as well as models from other managers. Advisers and their clients access Counterpoint’s models through these platforms. Counterpoint

provides its models to the Platform Providers for inclusion on their platform. Counterpoint manages each model portfolio and amends and modifies the model, based on each model’s investment strategy. The Platform Providers or Advisers do all trading to invest accounts according to the model chosen for the account. When we recommend changes or rebalances to the model portfolios, we will notify the Platform Providers promptly in accordance with our trade rotation policy so that they can adjust the portfolios of invested clients to fit the model. Counterpoint has no control over the actions or trading decisions of Platform Providers or Advisers when we recommend changes or rebalances to the models. Client Tailored Services and Client Imposed Restrictions Advisory services are tailored to the Funds’ investment objectives. Generally, Counterpoint has the authority to select which and how many securities and other instruments to buy or sell without consultation with the Funds. Models provided to Platform Providers will not contain investments in any investment vehicles that contain load or contingent deferred sales charges. Counterpoint does not work directly with the Advisers’ retail clients. Before investing retail clients’ assets based on Counterpoint’s model portfolios, each Adviser is responsible for reviewing that our models are suitable for the client. Wrap Fee Programs Counterpoint does not participate in “wrap fee” programs. Assets Under Management As of December 31, 2022, Counterpoint had assets under management on a discretionary basis of $1,351,835,495.