Vident Investment Advisory, LLC (“VIA”) is a Delaware limited liability company formed in March 2014. We have been providing investment advisory services since December 2014. VIA is a wholly owned subsidiary of Vident Financial, LLC (“Vident Financial”). Funds VIA primarily provides a range of investment solutions as a sub-adviser to exchange-traded funds registered under the Investment Company Act of 1940, as amended (“IC Act”) (“ETFs”). VIA also acts as a sub-adviser to pooled investment vehicles structured as Undertakings for Collective Investment in Transferable Securities (“UCITS”) and to other privately offered pooled investment vehicles including business entities operating as hedge funds (“private funds”). Hereinafter, ETFs, UCITS and private funds are collectively referred to as the “Funds.” Included as ETF clients are the Vident ETFs, four exchange-traded funds which are series of ETF Series Solutions (“ESS”) and distributed by ALPS Distributors, LLC (“ALPS”). VIA’s affiliate, Vident Advisory, LLC (“VA”), serves as the Vident ETFs’ primary adviser. VIA and VA are not affiliated with either ESS or ALPS. VIA is responsible for trading portfolio securities and other investment instruments on behalf of the Funds, including selecting broker-dealers to execute purchase and sale transactions, as instructed by a Fund’s primary adviser or in connection with any rebalancing or reconstitution of a Fund’s underlying investment index, subject to the supervision of the Fund’s primary adviser, management company, and/or board of directors (or trustees), as applicable. Funds may trade various combinations of any asset class or investment vehicle, including global equities, fixed income, ETFs, mutual funds, money market funds, private funds, commodities, futures, and liquid alternatives, as permitted by an underlying benchmark, index, or the disclosure document of the Fund. VIA does not tailor its advisory services to the individual needs of investors in the Funds. The Funds’ offering documents set forth their respective investment strategies, guidelines, and restrictions. Prospective investors should review these documents carefully before making any investment in the Funds. Unless otherwise noted herein, this brochure will focus its discussion on the services VIA provides to separately managed accounts (“SMAs”). Separately Managed Accounts VIA provides discretionary investment sub-advisory services to SMAs via an agreement with a third-party manager (“TPM”). VIA’s sub-advisory services are tailored to the individual needs of each SMA account owner. VIA’s current discretionary sub-advisory SMA mandates include laddered bond portfolios (“LBP”) and equity strategy SMAs (“ESMA”). Laddered Bond Portfolios VIA manages the LBP according to a customized fixed income strategy that is individually tailored to meet the cash flow needs of each

SMA account owner according to the SMA’s investment guidelines. The SMA may also place investment guidelines and/or restrictions on the account. Equity Portfolios VIA manages the ESMA based on an instructed investment strategy model determined by the TPM and the SMA account owner, inclusive of any established investment guidelines and/or restrictions, capital gains tax schedules, and other requirements established by the account owner. The concept of ESMA include, when chosen by the SMA, the use of select environmental, governance, and/or social screens chosen by the SMA and as implemented by VIA utilizing third-party providers’ investment criteria screens or the TPM’s own investment screens (or otherwise collectively considered as “values-based investment” screens). Account Management Each SMA may trade various combinations of any asset class or investment vehicle, including equities, American Depository Receipts (“ADRs”), fixed income securities, government securities, ETFs (inclusive of the Vident ETFs), mutual funds, and money market funds. As sub-adviser, VIA will work with the TPM to understand established investment guidelines and/or restrictions, capital gains tax schedules, and values-based investment requirements of each SMA. In turn, the TPM works with its client, the SMA account owner. VIA will monitor account performance on an ongoing basis and will make changes to the investment portfolio as required by changes in market conditions, fixed income security maturities, changes in the TPM’s investment strategy model portfolio selected by the SMA account owner, and/or changes in the financial circumstances of the SMA account owner (as relayed to VIA by the TPM). VIA will not work directly with the SMA account owner, rather it will rely on coordination with the TPM on the management of the account. Trading activity is influenced by the frequency of rebalances, contributions, withdrawals, and fixed income security maturities (including call exercise). VIA’s discretionary investment authority allows our firm to determine the specific securities and the amount of securities to purchase, sell or exchange for the SMA. The SMA, through the TPM, may request in writing that VIA make specific investments for the account, and the SMA has the ability to impose investment restrictions. ESMA is unable to receive initial public offering allocations due to unknown eligibility and restrictions around “trading away” (as discussed further below in Item 12 – Brokerage Practices). Please refer to a further discussion below in Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss and Item 16 – Investment Discretion. Wrap Fees VIA does not participate in wrap fee programs. Assets Under Management As of December 31, 2022, VIA managed $6,678,390,435 on a discretionary basis and $0 on a non- discretionary basis.