ASSETMARK, INC.

EFFECTIVE MARCH 26, 2025 Referral Disclosure Brochure Form ADV Part 2A Appendix 1, Wrap Fee Program Brochure SEC File Number − 801 56323 IA Firm CRD Number - 109018 ITEM 1 – COVER PAGE This wrap fee Disclosure Brochure provides information about the qualifications and business practices of AssetMark, Inc. (“AssetMark”). If you have any questions about the contents of this Brochure, please contact AssetMark using the information shown on the left. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. AssetMark is a registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. Additional information about AssetMark is also available on the SEC’s website at www.adviserinfo.sec.gov. AssetMark, Inc. Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 800-664-5345 R273_RefDsclBro_2025_03  Referral Disclosure Brochure Page ii ITEM 2 – MATERIAL CHANGES This section provides a summary of material changes that were made to this brochure since the last update. It includes changes to AssetMark’s Platform and is intended to help Clients determine if they want to review this brochure in its entirety or contact their Financial Advisor with questions about the changes. AssetMark can make interim updates to this brochure throughout the year. However, you will receive notice of any material changes, which must also be filed with the SEC. Information about AssetMark is available on the SEC’s website at www.adviserinfo.sec.gov or at www.assetmark.com. You can also request a copy by contacting us at: AssetMark, Inc. Attention: Adviser Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 800-664-5345 advisorcompliance@assetmark.com There have been no material changes since the last Form ADV Part 2A Appendix 1 update in September 2024. The following updates were made, in addition to clarifying edits in the disclosure brochure: • Item 4 – Services, Fees and Compensation - Additional disclosures about investments in funds managed by AssetMark or AssetMark affiliates. - Additional information about refund of prepaid Account fees for withdrawals. • Item 5 – Account Requirements and Types of Clients - Investment Minimums – Account Size • Item 6 – Portfolio Manager Selection and Evaluation - Updates to Shareholder Materials, Proxy Voting and Class Actions • Item 9 – Additional Information - Updates to FDIC-Insured Cash Programs - Additional information under Custodial Relationships • Exhibit B – AssetMark Asset Management – Solution Types - Upcoming management change for MarketDimensions and OBS Strategies This must remain with the Client  Page 1 of 37 ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i ITEM 2 – MATERIAL CHANGES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii ITEM 3 – TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ITEM 4 – SERVICE, FEES AND COMPENSATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • WRAP FEE PROGRAM. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • ASSETMARK AND ITS OWNERSHIP STRUCTURE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • ASSETMARK’S INVESTMENT MANAGEMENT SERVICES AGREEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • DESCRIPTION OF PLATFORM SERVICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • OTHER SERVICES AND NON-MANAGED ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 • INVESTMENT VEHICLES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 • ASSETS UNDER MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 • FEES AND COMPENSATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 • SELECTION AND REVIEW OF PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS . . . . . . . . . . . . . . . . . . . . . . . . 13 • INVESTMENT AND TAX RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 • ASSETMARK AS PORTFOLIO STRATEGIST OR INVESTMENT MANAGER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 • VOTING CLIENT SECURITIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 • REVIEW OF ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 ITEM 9 – ADDITIONAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 • DISCIPLINARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 • OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 • CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING . . . . . . . . . . . . . . . . . . . . . 22 • CUSTODIAL RELATIONSHIPS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 EXHIBIT A – SOLUTION TYPES – MODEL PROVIDERS AND INDIVIDUAL MANAGED ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 EXHIBIT B – ASSETMARK ASSET MANAGEMENT SOLUTION TYPES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 EXHIBIT C – PROPRIETARY MUTUAL FUND SOLUTIONS - CONFLICTS OF INTEREST DISCLOSURES. . . . . . . . . . . . . . . . . . . . . . . . . . 33 FEES AND INVESTMENT MINIMUMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Referral Disclosure BrochureThis must remain with the Client Page 2 of 37 ITEM 4 – SERVICES, FEES AND COMPENSATION important provisions governing participation in the Platform. Under the IMSA, the Financial Advisor is responsible for: WRAP FEE PROGRAM • evaluating the Client’s investment needs and objectives; • consulting with the Client concerning the Client’s participation in the Platform; • determining the initial and ongoing suitability of various Platform Solutions for the Client’s investment objectives and financial condition. Under the IMSA, AssetMark is responsible for, among other things: AssetMark, Inc. (“AssetMark”) is the sponsor of the AssetMark Platform (“Platform”) through which it offers its advisory and Platform services to Clients (the “Client”). Representatives of third-party investment adviser firms (these firms are referred to in this brochure as “Financial Advisory Firms” and their representatives are referred to as the “Financial Advisors”), consult with Clients to assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet the Client’s financial needs. • initial and ongoing due diligence related to the Solution, as described ASSETMARK AND ITS OWNERSHIP STRUCTURE in more detail below; • terminating or replacing Solutions available on the Platform, if appropriate; • implementing in Client Accounts decisions made by the Model Providers (described below) for the Solutions on the Platform. AssetMark is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since 1999 providing various investment advisory and consulting services to other advisors and investment Clients. AssetMark and AssetMark Trust Company (“AssetMark Trust”) are wholly owned subsidiaries of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc. is an independent, U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. AAM acts as Portfolio Strategist (described below) providing Model Portfolios (described below) for a number of Solutions. It is also among the Discretionary Managers (described below) offered on the Platform. With respect to those Strategies in which AssetMark acts as a Discretionary Manager, its obligations are accordingly those of a Discretionary Manager and include the selection of securities for the Account (consistent with the Strategy (described below) selected by the Financial Advisor and Client) and trade execution. A list of Portfolio Strategists/Model Providers and Investment/Discretionary Managers are provided in Exhibit A. AssetMark Wealth Solutions includes AssetMark’s Asset Management (“AAM”), Due Diligence, Investment Consulting, and other portfolio, wealth, and practice solutions. AAM is responsible for AssetMark’s proprietary investment strategies. If the Client and the Financial Advisor choose a Solution Type (or “Solutions,” described below) managed by AAM, AssetMark is responsible for the management of that Solution Type for the Client’s Account (described below). AssetMark also serves as the investment adviser for the GuideMark Funds and GuidePath Funds (each a “Fund” and collectively the “Proprietary Funds”) available in certain Solution Types on the Platform: Individual Solutions are available either through third-party Investment Management Firms (described below) or as proprietary Strategies managed by AAM. Strategists are also permitted to use AssetMark proprietary investment options or funds as part of a Strategy. 1) GuideMark Funds (no-load sub-advised mutual funds) 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund) AssetMark is responsible for the selection and management of subadvisors for each of the GuideMark Funds. However, the Client and the Financial Advisor, and not AssetMark, are responsible for selecting the Solution Type that uses Proprietary Funds. While AssetMark does deliver full management (including, for Model Provider Strategies, trade execution) of the Client’s Account using the Platform, AssetMark’s account management obligations are delivered after the Financial Advisor and Client have selected the Strategy and Platform Custodian (described below) for the Account. Thus, regardless of the Strategy selected, it is the Financial Advisory Firm and the Financial Advisor, not AssetMark, that recommends the Strategy to the Client and monitors whether to recommend that the Client remain in the Strategy. DESCRIPTION OF PLATFORM SERVICES AssetMark is not registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor, based on its determination that it will rely on certain exemptions from registration provided by the Commodity Exchange Act (“CEA”) and the rules thereunder. The CFTC has not passed upon the availability of these exemptions to AssetMark. AssetMark currently acts as a registered “commodity pool operator” (“CPO”) with respect to the GuidePath Managed Futures Strategy Fund and its wholly owned controlled foreign corporation, the GuidePath Managed Futures Strategy Cayman Fund. AssetMark is registered as a CPO under the CEA and the rules of the CFTC. Financial Advisory Firms enter into an agreement with AssetMark to implement the Platform for their Clients. As part of its services, AssetMark provides account administration, custody, brokerage and advisory services and is therefore considered a “wrap program.” AssetMark has developed internet-based software which provides the Financial Advisory Firm with the ability to directly monitor its Client Accounts, download information concerning changes in the Platform, and access current information relating to the Platform. ASSETMARK’S INVESTMENT MANAGEMENT SERVICES AGREEMENT into an To participate in the Platform, AssetMark, the Client and the Financial Investment Management Services Advisor will enter Agreement (“IMSA”) that outlines the responsibilities of AssetMark and the Financial Advisor, as well as the Client’s responsibilities, authorizations and acknowledgements as the Client. The IMSA also outlines the fees and compensation payable by the Client and other To establish an Account, a Client typically will complete a questionnaire, or otherwise provide information to the Financial Advisory Firm, to enable the Client and the Financial Advisory Firm to identify the Client’s risk tolerance and rate of return objectives. The Client typically will provide the Financial Advisory Firm with information concerning investment experience, the Client’s anticipated need for liquidity, potential timing of the need for retirement funds, and other investment needs and parameters. This Referral Disclosure BrochureThis must remain with the Client Page 3 of 37 Here are four main types of investment strategies which can be used in a client portfolio: information will assist the Client and the Financial Advisory Firm in selecting which of the Risk/Return Profiles (described below) is most closely aligned with the Client’s investment goals. The Financial Advisory Firm remains responsible for monitoring the Solution Types and Risk/Return Profiles and recommending any changes to the Client throughout the duration of the Client’s Account on the Platform, including any custom accounts at third-party Discretionary Managers. AssetMark’s responsibility is to implement the Solution Type and Risk/Return Profile chosen by the Client and the Financial Advisory Firm. AssetMark does not advise the Client about potential changes to the Client’s Solution Type or Risk/Return Profile. RISK RETURN PROFILES 1. Core: A mix of predominantly equities and fixed income across US or global markets and has multiple risk profiles. Other asset classes, including real assets and alternatives may be included to help manage risk. Core Strategies may focus on a total return or income mandates. Some Core Strategies may offer a tax aware option whereby tax-exempt fixed income investments are held within portfolios and in some cases tax-managed equity investments can also be held. For some Core Strategies, holding periods and turnover levels will be considered; however, AssetMark cannot guarantee that the portfolios will behave in a tax-sensitive manner over any given time period. One of the fundamental elements of the Platform is establishing the Client’s appropriate Risk/Return Profile. These Profiles range from most conservative (lowest estimated risk and lowest potential return) to most aggressive (highest estimated risk and highest potential return). Strategies on the Platform can only have a single risk profile or may have multiple risk profiles. 2. Equity: Strategies that are mainly invested in equities and are typically a single risk profile. Equity Strategies may focus on one of three investment mandates; total return (enhancing return over a diversified benchmark through active management – Enhanced Return Focus), income (ie equity dividends) or defense (limiting losses during market downfalls through reducing equity exposure – Limit Loss Focus – holding lower beta securities or using hedging strategies). The investment objectives for each of the six Risk/Return Profiles are listed below: • Profile 1 – Conservative: The profile is designed for an investor who wants to focus on preservation of capital as a primary goal and wishes to minimize downside risk. 3. Bond: Strategies that are mainly invested in fixed income and are typically a single risk profile (Bond and Bond Alternatives). Some Bond Strategies may include some low volatility alternative or equity exposure. These Strategies can help manage risk through diversification benefits and may focus on either a total return, income or defensive (typically lower duration) investment mandate. • Profile 2 – Moderate Conservative: The profile is designed for an investor who seeks to preserve capital but wishes to assume moderate downside risk in order to earn a return sufficient to preserve purchasing power. • Profile 3 – Moderate: The profile is designed for an investor who seeks to balance risk of loss to capital with capital appreciation. 4. Alternative: Strategies that are mainly invested in non-correlated liquid alternative strategies to provide diversification benefits to help manage risk. Alternative Strategies are typically a single risk profile and can invest in traditional alternative strategies, niche strategies or trend following strategies (managed futures – Equity Alternatives). • Profile 4 – Moderate Growth: The profile is designed for an investor who seeks enhanced capital appreciation and is willing to accept greater risk of downside loss and volatility of returns. SOLUTION TYPES Investment Strategies are available through three general “Solution Types” (or “Solutions”) on the Platform. • Profile 5 – Growth: The profile is designed for an investor who seeks significant capital appreciation and is willing to accept a correspondingly greater risk of loss and volatility of returns. • Profile 6 – Maximum Growth: The profile is designed for an investor who seeks the highest level of capital appreciation and is willing to accept the correspondingly greater risk of loss and volatility of returns. Generally, the percentage allocation to equity securities targeted for each Risk/Return Profile increases for each Profile from Profile 1, Conservative, which would represent the lowest target allocation of equity securities, through Profile 6, Maximum Growth, which would represent the highest target allocation of equity securities. • Model Portfolios – Client Accounts are allocated among securities and other investment vehicles on a non-discretionary basis pursuant to Model Portfolios provided by “Portfolio Strategists” (also referred to as “Model Providers”). Model Portfolios include mutual fund and ETF investment strategies and Separately Managed Accounts (“SMA”). SMA Model Portfolios are allocated among securities and other investment vehicles in accordance with the model and are typically selected for a specific asset class. AssetMark will serve as the Overlay Manager (described below) with regard to SMA accounts. INVESTMENT STRATEGIES • Individually Managed Accounts (“IMA”) – the Client Account is managed and individual Client Account trades are implemented on a discretionary basis by a “Discretionary Manager” (also referred to as an “Investment Manager”). For some IMAs, AssetMark serves as the Discretionary Manager; for others, a third-party manager serves as Discretionary Manager and AssetMark has no role in trading for the IMA. Another element of establishing the Client’s investment objective is to identify the appropriate mix of Investment Strategies to manage risk efficiently and meet the Client’s return objectives. Each Portfolio Strategist, Investment Manager and/or Solution Type is classified by AssetMark based on their Investment Strategy. The Client, with the assistance of their Financial Advisor, can select Solution Types for their Portfolio that represent a blend of different Investment Strategies. • Individual Mutual Fund (“IMF”) – Client accounts are allocated to a single mutual fund and is intended to complement other Solution Types available on the AssetMark Platform, as part of the Client’s overall Portfolio. The IMF’s used in this advisory service can be Proprietary or third-party funds. Each IMF is not available at all Platform Custodians. Clients should be aware that the Platform Fees Referral Disclosure BrochureThis must remain with the Client Page 4 of 37 As Overlay Manager, AssetMark intends to invest the Account consistent with the models provided by the Portfolio Strategist, unless circumstances indicate that modified allocations or investments are appropriate. The Client, with assistance of their Financial Advisor, can specify the initial Portfolio Strategist for the Account and will be given notice of any change to that Portfolio Strategist. AssetMark can remove or replace the Portfolio Strategists on the Account in its discretion. Individually Managed Accounts (“IMA”) An IMA can be established as: • Equity/Balanced; • Fixed Income; and • Custom High Net Worth charged by AssetMark for this service can be higher or lower than those charged by others in the industry or directly from the third- party mutual fund provider, and that it can be possible to obtain the same or similar services from other investment advisers at lower or higher rates. AssetMark may waive the Platform Fee in its discretion. A Prospectus for any individual mutual fund made available under this Solution Type can be obtained upon request from AssetMark or the Client’s Financial Advisor. Clients should review fund prospectuses and consult with their Financial Advisor if they have questions regarding these IMF Solution Types. The mutual funds shares selected for use can be institutional or retail shares, and can include administrative service fees, sub-transfer agency fees and/or 12b-1 fees, that are fees borne by Clients. See Servicing Fees Received by Custodians, including AssetMark Trust and Share Class Use for a discussion of 12b-1 fees, administrative service fees and sub-transfer agency fees and the Fees & Investment Minimums table at the back of this Disclosure Brochure for the Platform Fees charged IMFs. The client’s Investment Strategy can be customized to each clients account and implemented with a number of features and alternatives, such as: • a range of Risk/Return Profiles; • selection of one or more Investment Strategies and Mandates; • a group of available Portfolio Strategists or Investment Managers; and The Investment Manager will provide discretionary investment management services to the Account and the Client grants the Investment Manager the authority to buy and sell securities and investments for the Account, vote proxies for securities held by the Account, to select the broker-dealers or others with which transactions for the Accounts will be effected, and such other actions that are customary or appropriate for an Investment Manager to perform. The Investment Manager is responsible for selecting the securities for Client investment, including the share class if the investment is in mutual funds. Custody fees, if charged, are asset based. Usually, transaction fees are not charged to IMA accounts. Step Out or Trade Away Trades for IMAs • various IMAs, so that the Client, as advised by the Financial Advisor, can create a Strategy by which each of the Client’s Accounts under the Platform will be managed or maintained. Some Solution Types are available through third-party Investment Management Firms unaffiliated with AssetMark. Other Solution Types are Proprietary Strategies available through AAM, or Individual Mutual Funds as described above. AssetMark makes available fact sheets and other information to assist the Financial Advisor and Client in making an informed decision. More detailed information about the proprietary solutions are provided in Exhibit B – AssetMark Portfolios Solutions Solution Types. Overlay Manager The Investment Manager has the authority to “step-out” a trade and use a brokerage firm other than that usually used with the Client’s selected Custodian, and such trading will result in additional fee(s) from the Platform Custodian, unless such fees are waived (refer to Item 9 under “Brokerage Practices”). If a Discretionary Manager of an IMA determines to “step out” or “trade away” a trade, the Custodians are permitted to assess a fee of $20.00 per trade. This transaction fee would be in addition to any commission or trading costs. If an Account is invested in fixed income investments, e.g., a Parametric bond ladder IMA, the Client should expect this $20.00 fee on each security transaction. Commission charges, dealer spreads, markups/downs, and foreign currency conversion rates associated with these transactions may not be visible in program documents. For SMA Investment Solutions, the Client, with the assistance of their Financial Advisor, shall select a model provided by a Portfolio Strategist and AssetMark will serve as the “Overlay Manager” (or Investment Manager or Discretionary Manager) for Client Accounts. The Overlay Manager shall provide limited discretionary investment management services to the Account as discussed further below. The Client grants the Overlay Manager the authority to buy and sell securities and investments for the Account, to vote proxies and to effect corporate actions. AssetMark has contracted with Portfolio Strategists to provide recommendations for exposures to a specific asset classes or securities. For Clients selecting an IMA, their Account will be managed by an Investment Manager consistent with the Strategy selected by the Client. The Investment Manager shall provide discretionary investment management services to the Account, and the Client grants the Investment Manager the discretionary authorities discussed above. AssetMark can replace the Investment Manager at its discretion. Certain Custom IMAs are available in the Core Markets Investment Approach and the six Risk/Return Profiles, as described above under Risk/Return Profiles. In certain IMA Solutions, Clients will receive from the Investment Manager, and will be required to acknowledge receipt of, additional disclosures regarding specific investments, such as alternative investments, the use of the IMA managers’ mutual funds, or the use of options and/or certain fixed-income solutions. Use of IMA Manager Proprietary Mutual Funds The SMA Model Portfolios have been constructed by Portfolio Strategists engaged by AssetMark using individual securities recommendations. The Overlay Manager will have limited discretionary authority to execute transactions in each Account necessary to (i) track any reallocations, rebalance or other adjustments to the SMA asset allocations constructed by the Portfolio Strategists, (ii) implement changes recommended by the Portfolio Strategists; (iii) effect sale transactions of specified securities as directed by the Client and purchases of replacement securities; (iv) implement trades to support advisor-directed tax- loss harvesting requests for Clients and (v) implement any individual securities restrictions imposed on the Account by the Client. IMA Managers can use their own proprietary funds or funds of an affiliate in the IMA Client Accounts they manage. In these situations, the IMA Manager typically receives fees from AssetMark in their Referral Disclosure BrochureThis must remain with the Client Page 5 of 37 FINANCIAL ADVISOR – CUSTOM ACCOUNTS Multiple Strategy Accounts management of the Client’s Account, and they typically receive investment adviser or other fees from their proprietary funds. This is a conflict because it can create an incentive for the IMA Manager to select their own proprietary or affiliated funds. These fees can exceed what the IMA Manager would receive for using third-party mutual funds. Clients should discuss this conflict with their Financial Advisor. Clients will also receive the IMA Manager’s Form ADV Disclosure Brochure which will also disclose all conflicts of interests. The IMA Manager also provides additional disclosures regarding their rebate process in order to avoid collecting two fees on the same assets. In some instances, the IMA Manager will receive fees from AssetMark and rebate the portion of fees received from the funds they or the affiliate manages. In other cases, the IMA Manager will receive their fees from the funds they or the affiliate manages and rebate the portion of the fees received from AssetMark. To the extent that an IMA Manager invests Account assets in a fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. Certain Model Solutions discussed above are also available as sleeve-level options within a Multiple Strategy Account. In a Multiple Strategy Account, an Account can be customized with no set allocation limits. The Client, with the assistance of their Financial Advisor, can select from various Portfolio Strategists and Investment Managers, including AAM, and AssetMark-advised mutual funds (“Proprietary Funds”). In selecting and determining the allocations in each sleeve, a Multiple Strategy Account will be established. The number of sleeves selected can vary from a minimum of two to a maximum of eight selections, to comprise the Multiple Strategy Account and will be evaluated on quarterly basis for rebalancing across the sleeves. The standard minimum account by sleeve will vary. The fees charged for the Multiple Strategy Account will be based on the single-strategy fee schedule for each Strategist selection and weighted based on the allocation to each sleeve. Use of Options Custom GPS Select GPS Select, as described in Exhibit B – AssetMark Asset Management – Solution Types, can be customized within a specific range from the baseline to various Investment Strategies. The Client, with the advice of their Financial Advisor, not AssetMark, can select from various Investment Approaches from Portfolio Strategists and Investment Managers, including AAM, and Proprietary Funds. In doing so, and by selecting within the range of pre-determined allocations, a Custom GPS Select account will be established. Each Portfolio Strategist, Investment Manager or mutual fund selection is referred to as a “sleeve” allocation. If a mutual fund Solution Type is selected, the share class used will be consistent with the underlying single strategy Solution. The Financial Advisor is responsible for advising the Client on an ongoing basis whether or not to maintain or change the Investment Strategy, the Portfolio Strategist and the Investment Manager for the duration of the account. AssetMark does not advise the Client about the Investment Strategy, the Portfolio Strategist or the Investment Manager appropriate for that Client’s Account. Options strategies will be used for certain IMA Solutions. Clients should consider their financial resources, investment objectives and tolerance for risk and should be aware that options trading can be highly speculative and could result in financial losses even though margin borrowing will not be used for the types of options traded by these Client Accounts. Clients will be obligated to deliver the underlying security within the prescribed time for a call option that is exercised. Each of AssetMark and the Investment Manager is authorized to act as the Client’s agent to complete the Client’s obligations with respect to any options in the Client Account. The Client agrees to assume the financial risks of options transactions. All options transactions are subject to the rules, regulations, customs and practices of The Options Clearing Corporation (OCC) and the securities exchange, association or clearing organization through which the transactions are executed. Expiring options that are valuable (meaning, in the money) are exercised automatically pursuant to the exercise by exception procedure of the OCC. Additional information about the risks, characteristics and features of options is available at: https://www.theocc.com/company- information/documents-and-archives/options-disclosure-document. Custom High Net Worth AssetMark will make available the specific range of pre-determined allocations, which range will be updated from time to time. The number of sleeves selected can vary from a minimum of three to a maximum of eight sleeve selections, to comprise the entire Custom GPS Select account. The standard minimum account by sleeve varies and AssetMark’s revenue will increase or decrease based on the sleeve allocation agreed upon between the Client and Financial Advisor. Savos Custom GMS, PMP, Advisor – Custom, or Personal Portfolios (Refer to Exhibit B – AssetMark Asset Management – Solution Types for more detailed information regarding the selection of AAM strategies to be used within these custom accounts.) • Custom GMS and Privately Managed Portfolios (“PMP”): The Client, with the assistance of the Financial Advisor, can request that AAM deviate from standard allocations for the selected GMS or PMP Strategy. Such an Account is considered a Custom GMS or PMP Strategy. For Custom High Net Worth (“HNW”) accounts, the Client, with the assistance of the Client’s Financial Advisor, selects an Investment Manager to manage the individual Client Account and to provide discretionary investment management services to the Account. The Client grants the Investment Manager the authority to buy and sell securities and investments for the Account, to re-balance and re-allocate assets within the Account, to vote proxies for securities held by the Account and such other discretionary authorities as described in the IMSA, and as determined between the Client, their Financial Advisor and the Investment Manager. As such, the Client’s personalized investment objective can go beyond the standard investment objectives listed for each of the six Risk/Return Profiles as described earlier in this section, and as developed by the Investment Manager for the Client. The Investment Manager, in its discretion, will maintain investment decision records with regards to the Client’s HNW Account. If a Client’s investment objective and/or Risk/Return Profile changes, the Financial Advisor is responsible for notifying AssetMark of the change. • Advisor – Custom Accounts: The Client can choose to participate in a program in which their Financial Advisor, in consultation with AAM, can request further customization for their Client’s Account (“Advisor – Custom Accounts” or “ACA”). The Financial Advisory Firm will be solely responsible for determining the additional customization and Referral Disclosure BrochureThis must remain with the Client Page 6 of 37 can be negotiable. Accounts enrolled in TMS can trade at different times than other accounts on the AssetMark Platform invested in the same strategy and can hold higher cash allocations due to minimum trade size, rounding and other factors. TMS accounts will not be automatically rebalanced if the cash allocation exceeds a 2% threshold. The cash allocations will be invested in the cash “sweep” vehicle at the client’s selected Custodian, which for AssetMark Trust is usually its Insured Cash Deposit (“ICD”) Program. OTHER SERVICES AND NON-MANAGED ACCOUNTS Administrative and General Securities Accounts the suitability for the Client. AAM, in its discretion, will determine the implementation of the ACA. The Financial Advisory Firm will be solely responsible for determining the additional customization. The Financial Advisory Firm can request that AAM recommend to the Financial Advisory Firm asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the ACA developed by the Financial Advisory Firm may not be consistent with the Investment Strategies or Risk/Return Profiles described in this Disclosure Brochure for the GMS or PMP Accounts described in Exhibit B – AssetMark Asset Management – Solution Types. The GMS or PMP Platform Fee schedules will be charged to the Client Account, unless otherwise negotiated between the Financial Advisory Firm and AssetMark. • Savos Personal Portfolios – Custom: A Savos Personal Portfolios (“SPP”) - Custom Account can be customized within a specific range across equity, fixed-income and tactical allocations. The Client, with the assistance of their Financial Advisor, can select from various SPP investment sleeves. In doing so, and by selecting within the range of pre-determined allocations, a Savos Personal Portfolios - Custom Account will be established. Each equity, fixed- income and tactical allocation is referred to as a “sleeve” allocation. INVESTMENT CONSULTING Although options vary depending upon the Custodian selected by the Client, the Client can usually establish an Account at their selected Custodian to hold “non-managed” assets (an “Administrative/Non- Managed Account”), and such Account can include a Cash Account or a General Securities Account. An Administrative/Non-Managed Account is provided as an administrative convenience for the Client. Assets in an Administrative/Non-Managed Account are not managed or advised by AssetMark, and AssetMark is not responsible for their investment or management. The Client will be solely responsible for directing the investments in the Administrative/Non-Managed Account. Administrative/Non-Managed assets are subject to the terms of the Client’s agreement with their selected Custodian. In addition to reporting by the Client’s Custodian, the assets of an Administrative/ Non-Managed Account will be included in periodic AssetMark reports that the Financial Advisor can provide to the Client. If Clients select AssetMark Trust as their Platform Custodian, they will be offered a FDIC-Insured Cash Program and Certificates of Deposit for their Administrative account. This option and other cash management services from AssetMark Trust and the conflicts of interest involved in AssetMark‘s affiliate AssetMark Trust offering these services are discussed in Item 9 of this Brochure. Cash Accounts A Financial Advisory Firm or Financial Advisor can request that AssetMark consult on the creation of practice-based models that include Platform Solutions to meet specific goals and/or objectives sought by the Financial Advisory Firm or Financial Advisor. These models can include proprietary and/or third-party Solutions. The Financial Advisory Firm and Financial Advisor will continue to be responsible for determining the final combination of Solutions used in their practice-based models and the suitability of these Solutions for their Client(s). AssetMark does not provide individualized investment advice to Clients or to the Financial Advisor for individual client accounts. There is typically no fee for this service, but the Financial Advisor is expected to make an asset commitment to the Platform, which creates a conflict of interest for the Financial Advisor. The inclusion of a proprietary Solution creates a conflict of interest for AssetMark if selected by the Financial Advisory Firm and Financial Advisor because AssetMark receives fees for the management of proprietary Solutions. TAX MANAGEMENT SERVICES Certain custodians offer cash management services, which are described in more detail in their custodial agreements and/or disclosures. For more information about Cash Management Services at AssetMark Trust, including the conflicts related to these services, refer to Item 9, Additional Information. Additionally, AssetMark Trust clients will receive a separate disclosure entitled AssetMark Trust Company Disclosures Regarding Services that describes its Cash Management Services. SERVICES NO LONGER OFFERED AssetMark also continues to manage other advisory services which are no longer offered to new Clients. Clients with these services can contact AssetMark for more information. INVESTMENT VEHICLES The Solution Types can be comprised of: (i) closed-end mutual funds; (ii) open-end mutual funds; (iii) ETFs, (iv) individual securities (stocks, bonds, preferred stocks, treasury bills and notes, bank notes) and (v) alternatives. The Client Accounts managed by Investment or Discretionary Managers can also include options and alternative investments, as advised by the Financial Advisor and the Investment Manager. Tax Management Services (TMS) is designed to improve the after-tax return for the client’s account. The application of TMS can cause the account to stray from the Strategy and Risk/Return Profile selected for the Account. Clients can submit account restrictions, such as GICS sub-industry restrictions for individual stocks, not mutual funds or ETFs. The application of TMS will cause the account to deviate from its selected investment strategy and may also affect the risk profile and overall performance of the account. Municipal securities held in TMS accounts can be replaced with non-municipal or non- state specific securities as portfolio holdings, resulting in interest income that may be subject to federal, state, and/or local income taxes. If you select TMS with a high tax sensitivity, you should expect the account to deviate from the selected strategy to a higher degree than if a lower tax sensitivity is selected. If additional customizations or restrictions are added to your TMS account, they may impact the account’s tax and investment results and the effectiveness of TMS. AssetMark does not provide tax planning, accounting, or legal advice or services. The Tax Management Services fee is ten basis points (0.10%) with a $100 minimum annual fee per account. TMS fees The Portfolio Strategists select and monitor the performance of the mutual funds, ETFs, and securities within their asset allocations and will periodically adjust and rebalance the asset allocations in Referral Disclosure BrochureThis must remain with the Client Page 7 of 37 Use of Portfolio Strategist and IMA Manager Proprietary Mutual Funds and AssetMark and AssetMark Affiliate Proprietary Funds accordance with their investment strategies. Each Investment Solution will maintain a 2% target cash allocation for the payment of fees, to cover withdrawals and other fees applicable to the Account. However, Portfolio Strategists and IMA Managers can determine to allocate a higher percentage to cash. From time to time, AssetMark will add to or remove certain investment vehicles from the Platform: a) Mutual Fund and ETF model portfolios available through the Platform; b) Investment Managers available for the IMA Accounts; c) Portfolio Strategists available on the Platform; and d) other Investment Management Firms providing asset allocations and asset selections for Solution Types. Portfolio Strategists and IMA Managers are permitted to use their own funds or funds that they or an affiliate advises in the Model Portfolios or IMA accounts they manage. In these situations, the Portfolio Strategist and the IMA Manager typically receive fees from AssetMark for the Model Portfolio or the management of the Client’s IMA Account, and they typically receive investment adviser or other fees from the funds that they or an affiliate advise. These fees can exceed what the Portfolio Strategist or IMA Manager would receive for using third-party mutual funds. This is a conflict for the Portfolio Strategist or IMA Manager because it can create a financial incentive for the Portfolio Strategist or IMA Manager to select their own proprietary or affiliated funds. Clients should discuss this conflict with their Financial Advisor. Clients will also receive the IMA Manager’s Form ADV Disclosure Brochure in which the IMA Manager is required to disclose all conflicts of interests. To the extent that an IMA Manager invests Account assets in, or a Portfolio Strategist makes an allocation to, a fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. The Financial Advisor reviews the Portfolio Strategists’, Investment Managers’ and Investment Management Firms’ and the Strategies’ performance on behalf of the Client and makes or recommends investment decisions (pursuant to the authorizations given the Financial Advisor in the IMSA) based on such analysis. AssetMark does not recommend specific Portfolio Strategists, Investment Managers or Investment Management Firms to Clients. MUTUAL FUND MODEL PORTFOLIOS AAM uses Proprietary Funds in various investment solutions. Information about the Proprietary Funds, including fees and expenses, are described in more detail in the Proprietary Funds’ prospectus. To the extent that AssetMark makes an allocation or invests Account assets in a fund managed by an AssetMark affiliate, AssetMark will rebate the portion of fees received by the AssetMark affiliate from the fund. ETF MODEL PORTFOLIOS An ETF is an investment fund traded on stock exchanges and holds assets such as stocks, commodities, or bonds, and can be traded over the course of the trading day. Each investor owns shares, which represent a portion of the holdings of the fund, and ETFs, like mutual funds, have management fees paid to the manager of the ETF. There are no separate share classes for ETFs. ETF Solutions invest in third- party ETFs, which are not advised by AssetMark. For Clients selecting a Mutual Fund Account, their Account will be invested in institutional mutual funds, retail NTF funds and/or mutual funds that generally do charge a sales load but where the sales charge has been waived. Third-party mutual funds and AssetMark ‘s Proprietary Funds are used. (Refer to Servicing Fees Received by Custodians, including AssetMark Trust and Share Class Use below) The Account will be invested consistent with allocations provided by a Portfolio Strategist for the Risk/Return Profile selected by the Client based on the advice of the Financial Advisor. Certain Portfolio Strategists compose their mutual fund allocations utilizing only those mutual funds managed by the Portfolio Strategist, Investment Manager or an affiliate of the Portfolio Strategist or Investment Manager. One or more of the Portfolio Strategists will construct their allocations exclusively using Proprietary Funds managed by AssetMark, including the GuideMark and GuidePath Funds. To the extent that a Portfolio Strategist makes an allocation to a mutual fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. AssetMark does not advise the Client about the Portfolio Strategist or the Risk/Return Profile appropriate for that Client’s Account. Multiple Investment Strategies are available as a model portfolio. Information regarding the Solutions and the Portfolio Strategists available for each of the Investment Strategies is available from the Client’s Financial Advisor. If a Mutual Fund account is chosen, it can also include non-mutual fund investments. For example, non-mutual fund investments could include cash alternatives and/or ETFs held by the Account. A Client, with the assistance of their Financial Advisor, can also select from ETF Solution Types, and their Account will be invested in ETFs consistent with allocations provided by a Portfolio Strategist for the Risk/Return Profile selected by the Client. A Portfolio Strategist can compose their ETF asset allocations utilizing only those ETFs managed by the Portfolio Strategist or an affiliate, an unaffiliated investment manager, or a combination of both. To the extent that a Portfolio Strategist makes an allocation to a mutual fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. ETFs are traded daily at market determined prices on a national exchange in a similar manner to other individual equity securities. ETF Solution Types also invest in exchange-traded notes (“ETNs”), which are senior, unsecured debt securities issued by an underwriting bank. AssetMark is responsible for trading the ETF Solution Types based on the recommendations of Portfolio Strategists. The ETF trading practices are discussed further in Item 9 under “Brokerage Practices” in the Trade Execution and Brokerage Allocation section. Multiple Investment Strategies are available as an ETF Model Portfolio. Information regarding the Solution and Portfolio Strategists available for each of the Investment Strategies is available from the Client’s Financial Advisor. Portfolio Strategists select from mutual funds that are AssetMark Proprietary Funds, third-party funds, NTF funds, load-waived, or retail mutual fund share classes that are available on each Custodian’s platform. There are no per-trade transaction fees charged to the Client in the mutual fund Solution Types on the AssetMark Platform. See Servicing Fees Received by Custodians, including AssetMark Trust Company and Share Class Use under Fees and Compensation for more information on indirect fees the Client pays through their investment in mutual funds. Referral Disclosure BrochureThis must remain with the Client Page 8 of 37 FINANCIAL ADVISOR FEE A Client Account is also permitted to include some non-ETF investments or an allocation to proprietary mutual funds managed by the Portfolio Strategist. In addition, the Client retains all indicia of beneficial ownership, including, without limitation, all voting power and other rights as a security holder in each of the funds held for the Client. ASSETS UNDER MANAGEMENT The Financial Advisor Fee is paid to the Financial Advisory Firm with which the Client’s Financial Advisor is associated and compensates for the consultation and other support services provided by the Financial Advisory Firm through the Financial Advisor. These services include obtaining information regarding the Client’s financial situation and investment objectives, conducting an analysis to make a determination of the suitability of the Solutions to be provided by AssetMark for the Client, providing the Client with AssetMark disclosure documents, assisting the Client with Account paperwork and being reasonably available for ongoing consultations with the Client regarding the Client’s investment objectives. As of December 31, 2024, the Referral Model Platform had $77.4 billion in assets under management. These assets include investments in proprietary mutual funds, proprietary strategies and third-party Investment Managers under the Referral model. These assets are managed on a discretionary basis. Clients should also be aware that the Financial Advisors recommending these advisory services receive compensation as a result of Clients’ contracting with AssetMark for these services. On December 2, 2024, AssetMark announced the close of its acquisition of Morningstar Wealth’s Turnkey Asset Management Platform (TAMP) assets. The assets under management also includes the acquired Morningstar accounts. Morningstar will continue to provide account services to the acquired accounts through mid-year 2025. FEES AND COMPENSATION The fees applicable to each Account on the Platform can include: 1. Financial Advisor Fee 2. Platform Fee, which includes any Strategist or Manager Supplemental Fee, as applicable, and most custody fees. AssetMark receives Client referrals through representatives of broker- dealer firms and investment adviser firms. The Financial Advisors consult with Clients to assess their financial situation and identify their investment objectives in order to implement investment solutions and Strategies designed to meet the Client’s financial needs. A Financial Advisor referring a Client to AssetMark for advisory services interviews the Client and makes a determination that a Solution Type is suitable for the Client before making the referral to AssetMark. Working with the Financial Advisor, a Client selects a Solution Type for the Client’s Account, and the components of the Client’s Strategy, including the Client’s desired and appropriate Risk/Return Profile. Financial Advisors are required to contact Clients at least annually regarding the suitability of the Client’s chosen Solution Type(s). AssetMark manages each Client Account according to the Client’s selected Solution Type under the terms of the AssetMark IMSA. The Fees applicable to the Account will be set forth in the Client Billing Authorization the Client receives each time an Account is established. The Financial Advisor Fee and the Platform Fee when combined are referred to as the Advisory Fee. Other fees for special services are also charged. The Client should consider all applicable fees. The Financial Advisor and Client select an annual rate for the Financial Advisor Fee, which is paid to the Financial Advisory Firm, by choosing a flat rate, or a custom tiered rate of up to 1.50% (150 basis points), as negotiated and agreed between the Client and the Financial Advisor. PLATFORM FEE The Platform Fee includes: (i) payment for advisory services (including the Strategist’s or Manager’s Supplemental Fee, if applicable) and administrative services; and Clients should be aware that the fees charged by AssetMark can be higher or lower than those charged by others in the industry and that it can be possible to obtain the same or similar services from other investment advisers and other platform providers at lower or higher rates. A Client can obtain some or all of the types of services available through AssetMark on an “unbundled” basis either through other firms or through single or multiple strategy account selections on the Platform and, depending on the circumstances, the aggregate of any separately paid fees, or bundled fees can be lower or higher than the fees described below and in the Fees & Investment Minimums table at the end of this Disclosure Brochure. (ii) payment for custodial and brokerage services (although additional fees are payable for certain third-party mutual funds, Actively Managed Fixed Income Strategies, Funding Accounts (an account used to receive cash and assets transferred in kind before sale or transfer to an advised Account), acquired Global Financial Private Capital (“GFPC”) Strategies, and Accounts custodied at Charles Schwab & Co. (“Schwab”). to AssetMark It is important that the Client understands all the fees applicable to the Account and understands that all fees are subject to negotiation. The Platform Fee schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimums table located at the end of this Disclosure Brochure. The Fees & Investment Minimums will be updated from time to time, to include the addition of new products and services, to remove any terminated strategies, or to make updates. Information regarding the Fees & Investment Minimums will also be posted at www.assetmark. com/info/disclosure, and you should consult this site for the most up-to-date information about the Fees & Investment Minimums. Generally, you will also receive notification in advance if there is a fee increase. That notification may direct you to your Financial Advisor or to the web address listed above for specific information on the change. The Platform Fee provides compensation for maintaining the Platform and for providing advisory, administrative, custodial and brokerage services to the Account. The advisory services include, but are not limited to: selecting, reviewing and replacing, as AssetMark deems appropriate, the Portfolio Strategists providing allocations, Investment Management Firms providing securities recommendations, Discretionary and Overlay Managers providing discretionary management services and other Consultants and service providers; review and validation of Portfolio Strategists’ recommendations; and in certain cases provision of advisory services to the Account itself, whether through recommendations from third- Referral Disclosure BrochureThis must remain with the Client Page 9 of 37 SUPERVISORY FEE party Portfolio Strategist or management by third-party Discretionary Manager or management of the Account by AssetMark; and providing instruction for trade execution for mutual fund and ETF Solution Types. As discussed above, AssetMark does not advise Clients about the selection or retention of Strategies; the Financial Advisor is responsible for those advisory services to Clients. The Platform Fee will be higher for certain Financial Advisory Firms due to the amounts payable to Financial Advisory Firms with supervisory responsibility over the Financial Advisors. This supervisory fee, of up to 0.20% annually, is deducted from Client Account assets, and paid to certain Financial Advisory Firms, for supervision of the Account. The receipt of a supervisory fee creates an incentive for Financial Advisory Firms to use the AssetMark program versus other platform programs. You can ask your Financial Advisor if a supervisory fee applies to your Account. Information on participating Financial Advisory Firms is available from AssetMark upon request. The administrative services include but are not limited to: arranging for custodial services to be provided by various Platform Custodians pursuant to separate agreement between Client and Custodian; preparation of quarterly performance reviews (to complement account statements provided by Custodians); and maintenance and access to electronic or web-based inquiry system that provides detailed information on each Client Account on a daily basis. MINIMUM ACCOUNT PLATFORM FEE The annual rate of the ongoing Platform Fee is based on the amount and type of assets under AssetMark management or administration. Each fee schedule is tiered so that, subject to certain exceptions, the first dollar under management receives the highest fee and only those assets over the breakpoints receive the reduced fees. Under certain circumstances, assets held in one AssetMark Investment Solution Account are considered when determining assets under management for breakpoint purposes relating to another Investment Solution Account held for the benefit of the same or a related person. Certain ETF and mutual fund investment solutions are charged an annual Minimum Platform Fee of $350, or a quarterly prorated amount based on the number of days in that quarter. If the quarter end value of an Account multiplied by the fee rate is less than the calculated quarterly minimum fee, then the Account will be charged the prorated quarterly minimum fee based on the number of days in the quarter. The Minimum Platform Fee is typically charged to accounts that no longer maintain the Investment Minimums in certain strategies. The Minimum Platform Fee, if charged, could represent a higher percentage fee than the stated Platform Fee for the strategy. Clients should consult with their Financial Advisor to understand the impact of fees when Investment Minimums are not met. Some of AssetMark’s Platform Fees are negotiable, and exceptions to the Fees & Investment Minimum table are made with the approval of an authorized officer of AssetMark. As a standard practice, AssetMark grants exceptions to its fee schedule for accounts of employees and employees of broker-dealer, investment advisory or other firms with whom AssetMark maintains an active selling agreement, any of which can be offered discounted fees. CUSTODIAL AND BROKERAGE SERVICES The Platform Fee Schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimums table at the end of this Disclosure Brochure. The Fees & Investment Minimums table will be updated from time to time, to include the addition of new products and services, to remove any terminated strategies, or to make updates. Information regarding the Fees & Investment Minimums will also be posted at www.assetmark.com/info/disclosure, and you should consult this site for the most up-to-date information about the Fees & Investment Minimums. STRATEGIST’S OR MANAGER’S SUPPLEMENTAL FEE For an Account invested in a third-party Investment Solution, a supplemental Strategist or Investment Manager Fee can be payable to the Strategist or Discretionary Manager. The Investment Manager Fee provides compensation for services provided by the Discretionary Manager that are customary for a Discretionary Manager to provide, including but not limited to, selecting, buying, selling and replacing securities for the Account and selecting the broker-dealers with which transactions for the Account will be effected. The Platform Fee charged to Client Accounts includes compensation for custodial and brokerage services. Pursuant to agreements that AssetMark has negotiated with AssetMark Trust (AssetMark’s affiliate Custodian) and the third-party Custodians on AssetMark’s Platform, AssetMark pays the Custodian for the custodial and brokerage services provided to Client Accounts. (The Custodians also have other income sources.) The Client does not pay transaction fees on trades made in most of the Solution Types available on the Platform. Separate transaction fees will be charged in Fixed Income IMA Solutions and in some equity IMA Solutions. Additionally, AssetMark generally receives more revenue when Clients choose AssetMark Trust as their Custodian. These differences in payments and revenue create conflicts of interest for AssetMark. AssetMark addresses these conflicts by having the same Platform Fee apply regardless of the Custodian chosen and by allowing the Client to choose their own Custodian, which can be AssetMark’s affiliated Custodian, AssetMark Trust. Although the Platform Fee is the same among Custodians, different fees for incidental expenses can apply. For certain Solution Types, the Account will be charged a Supplemental Investment Manager Fee on the basis of the applicable Discretionary Manager. These fees are payable by the Client on Account assets at the annual rates set out on the Fees & Investment Minimums fee table located at the end of this Disclosure Brochure. The selected Custodian’s full fee schedule will be presented to the Client together with the separate custodial agreement to be executed between the Client and their selected Custodian. Please refer to the Custody Agreement (described below) for specific fees attributable to the Client Account. More information about Custodians is also discussed below in Item 9, Additional Information – Custodial Relationships. The Strategist’s and Manager’s Supplemental Fee can be negotiated at the sole discretion of the Discretionary Managers. Each Discretionary Manager’s investment process and philosophy are described in their Form ADV Part 2A Disclosures Brochure, which is provided to the Client when they open an Account. To request another copy, the Client can contact their Financial Advisor or AssetMark’s Compliance department at the address on the front cover of this Brochure. Referral Disclosure BrochureThis must remain with the Client Page 10 of 37 FEES FOR TERMINATED STRATEGIST OR NO STRATEGIST ACCOUNTS Account values are typically grouped for fee billing purposes. Advisory Fees will be calculated based on the total value of existing Accounts across a Client household. This grouping is usually referred to as “Householding” and often results in a reduction of the overall Portfolio Fees. The Client will not be assessed or refunded a pro-rata portion of the Platform Fee when an Investment Solution change is made in their Account and is executed intra-quarter between quarterly billing events. The Platform Fee for the new investment Solution will be effective in the next applicable billing cycle following the execution of the Investment Change instruction, which may be the monthly or quarterly cycle depending on Client-directed activity in the account. SERVICING FEES RECEIVED BY CUSTODIANS, INCLUDING ASSETMARK TRUST COMPANY AND SHARE CLASS USE AssetMark has Accounts that no longer receive advisory services pursuant to the IMSA because the Strategy in which the Account was invested has been terminated from the AssetMark Platform and the Client has not selected another Strategy for the assets. These Accounts are referred to as “No Strategist” or “Terminated Strategist” Accounts. Neither AssetMark, nor any Discretionary Manager will manage or shall be responsible for giving any advice with regard to these assets, but the Account typically remains invested in the investments last selected for the Strategy at a Platform Fee that is a reduction from that payable when the Strategy was active on the AssetMark Platform. Any Financial Advisor Fee payable pursuant to the IMSA shall be payable on No Strategist or Terminated Strategist Accounts unless AssetMark receives instructions not to charge the Financial Advisor Fee. It is up to the Financial Advisor to a Client to recommend a new Strategy to a Client for a No Strategist or Terminated Strategist Account. A separate Custodial Account Fee applies to No Strategist or Terminated Strategist accounts. Please see the Custody Agreement for specific fees attributable to the Client Account. Platform Fee schedules for No Strategist or Terminated Strategist Accounts are available by contacting AssetMark or the Client’s Financial Advisor. FINANCIAL PLANNING AND CONSULTING FEES Portfolio Strategists select from the mutual funds available on each Custodian’s platform to be used in the Mutual Fund Accounts. The Custodian determines and then makes available the universe of mutual funds to be used in the AssetMark investment solutions. If a mutual fund is not available, the Portfolio Strategist works with AssetMark and the Custodian to make the fund available, where possible. Mutual fund families offer a variety of funds with varying fee structures and different share classes. The funds available at the Custodians for use with the AssetMark Platform will vary among different mutual fund share classes and will generally fall into these two share class categories. Financial Advisory Firms that provide financial planning and consulting services are permitted to charge their Financial Planning and Consulting Fees through the Client’s Account on the Platform. Client authorization is required to establish or modify the Financial Planning and Consulting Fee, and to elect from which Account the fee will be charged, or establish for payment via Automated Clearing House, or ACH. The Fee can be a one-time fee or a recurring fee. If a Client elects to charge this Fee to an Individual Retirement Account (“IRA”) or other qualified account, the Client is responsible for any adverse tax consequences that can arise from fee payments from an IRA. • Retail share class – Retail share class funds charge a 12b-1 fee of generally 0.25%, which is paid to the Custodian. Retail shares also include administrative fees, shareholder servicing and sub-transfer agent fees, which are also paid to the Custodian. There are a range of retail share classes available on the custodial platforms that also charge 12b-1 fees or administrative fees. These share classes are generally known as no-load or service shares (C shares), or load- waived A shares, Investor Shares, or NTF mutual funds, available through NTF programs at various Custodians. Fee Billing Process • Institutional share class – Institutional share class funds have lower expenses because there are no 12b-1 fee charges. However, institutional share classes can include administrative fees, shareholder servicing, and/or sub-transfer agent fees paid to the Custodian. NTF funds generally pay Custodians, including AssetMark Trust, AssetMark’s affiliated custodian, a range of servicing fees from the 12b-1 fees and administrative service fees, which typically include shareholder servicing and sub-transfer agent fees, collected by the mutual funds. See below Administrative Service Fees Received by Affiliate. Advisory Fees (or “Account Fees”) are payable quarterly, in advance. The quarterly Advisory Fee is calculated by multiplying the market value of all Account assets, inclusive of accrued interest and dividends, as of the end of the previous calendar quarter by the “quarterly rate.” The quarterly rate is number of calendar days in the quarter, divided by 365 (or 366, as applicable) days in the year, multiplied by the applicable annual Advisory Fee rate provided for in the Fees & Investment Minimum table. For the initial deposit to the Account and for any subsequent amounts deposited to the Account, the Advisory Fee shall be payable upon AssetMark‘s commencement of management, based upon the amount of the deposit multiplied by the quarterly rate (as described above) of the applicable annual rate and charged pro-rata through the end of the calendar quarter. Each of the Fees are calculated on a “tiered” basis so that the first dollar under management receives the highest fee and only those assets over the breakpoints receive the reduced fees. AssetMark will use retail share mutual funds and institutional share mutual funds. There are no separate transaction fees charged for mutual fund investments on the Platform. AssetMark does not always use the lowest cost share class. In striving for consistency across all custodial options on the Platform, AssetMark will seek to select the lowest cost share class available across all Custodians. Due to specific custodial or mutual fund company constraints, situations will arise where a specific share class is not consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class may be the retail share class. Information about the specific fees charged by mutual funds is described in each fund’s prospectus. Unless other arrangements are made in writing, the Custodian will debit these fees from the Account. Additional fees, such as custodian termination fees, are due where applicable, pursuant to the Client’s separate agreement with the Custodian (“Custody Agreement”). In the event the Client takes a withdrawal from their Account, AssetMark will not refund any prepaid fees related to the amount that has then been withdrawn. However, upon termination of the Account, a portion of the prepaid Advisory Fees will be refunded, calculated by multiplying the daily prepaid Advisory Fee during the final quarter by the number of days remaining in that quarter. Referral Disclosure BrochureThis must remain with the Client Page 11 of 37 INDIRECT INVESTMENT EXPENSES AND MUTUAL FUND FEES PAID BY CLIENT Platform Fee. All mutual funds included in mutual fund strategies on the Platform will be available for purchase at each fund’s net asset value and with no sales charge, so that no sales commissions are incurred in connection with investment in the initial Portfolio and Portfolio rebalancing. While most mutual funds available through the Platform will charge no transaction fees, mutual funds or Custodians charge redemption fees under certain circumstances. The Platform Fee for related Accounts of any Client on the Platform is negotiable, as are Platform Fees paid on Accounts that are associated with a particular Financial Advisory Firm, subject to approval. These negotiated fees typically lower the portion of the Platform Fee that AssetMark receives. Some expenses are inherent within the investments held in Client Accounts. Mutual funds pay management fees to their investment advisers, and certain funds and money market accounts have other types of fees or charges, including 12b-1, administrative, shareholder servicing, bank servicing or certain other fees, which are typically reflected in the net asset value of these mutual funds held in Client Accounts. Such expenses are borne by all investors holding such securities in their Accounts and are separate from AssetMark’s fees or charges. As discussed above, retail share classes of mutual funds typically pay 12b-1 fees to Custodians in return for shareholder services performed by those Custodians. SPECIAL SERVICE FEES PAID BY CLIENT Certain mutual funds and ETFs selected for Client Accounts include Proprietary Funds from which AssetMark or an AssetMark affiliate receives compensation as the investment adviser, as described above. AssetMark receives management and other fees for its management of the GuideMark and GuidePath Funds. Non-standard service fees incurred as a result of special requests from Clients, such as wiring funds or overnight mailing services, will be an expense of the Client’s Account and will typically be deducted by the Custodians at the time of occurrence. An authorized officer of AssetMark or the Custodian must approve exceptions. SECURITY AND SALES-BASED FEES PAID BY CLIENT Some mutual funds charge short-term redemption fees. Currently, AssetMark seeks to avoid investing Client assets in funds that charge such fees to the extent practicable, but avoidance of these fees cannot be guaranteed. MUTUAL FUND SHARE CLASS USE IN AAM STRATEGIES An Account can also incur fees referred to as “Regulatory Transaction Fees,” paid to brokerage firms to offset the fees the firms owe to self- regulatory organizations and U.S. securities exchanges to cover fees charged by the SEC for costs related to the government’s supervision and regulation of the U.S. securities markets and professionals. In addition, applicable Accounts will also be charged expenses related to custody of foreign securities and foreign taxes. The Client should review the agreement or schedule of fees of their selected Custodian. FINANCIAL ADVISORY FIRM AND FINANCIAL ADVISOR PROGRAMS In the AAM Strategies, mutual fund share class is selected on a fund- by-fund basis and seeks to eliminate 12b-1 fees where possible. AssetMark will seek to use institutional classes where these share classes are available. In striving for consistency across all custodial options on the Platform, the AAM Strategies will seek to select the lowest cost share class available across all Custodians. Due to specific custodial or mutual fund company constraints, situations will arise where a specific share class is not consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class may be the retail share class. Financial Advisory Firms receive fees for their services and compensation from AssetMark for referrals of Clients, as described above under Financial Advisor Fee. Therefore, they have a financial incentive to recommend the AssetMark wrap fee program over other programs or services, which creates a conflict of interest on the part of the Financial Advisory Firms. OTHER COMPENSATION DISCLOSURE Bank money market accounts and other bank services typically charge separate fees. For more information regarding bank services, refer to Cash Management Services offered by Affiliate in Item 9 below. In addition to the compensation payable under the IMSA, AssetMark enters into other fee arrangements with certain Financial Advisory Firms and/or Financial Advisors as described below. Such arrangements will not increase the fees payable under the IMSA by the Client. However, Client’s should review and understand that these arrangements can be deemed to cause a conflict of interest because they provide Financial Advisory Firms and Financial Advisors with incentives to place and retain Client assets on the AssetMark platform. Each of the mutual funds, ETFs, alternative investments and other funds or pooled investment vehicles available on the Platform bears its own operating expenses, including compensation to the fund or sub- adviser. As an investor in the mutual funds or ETFs, the Client indirectly bears the operating expenses of the mutual funds or ETFs, as these expenses will affect the net asset value (or share price in the case of an ETF) of each mutual fund or ETF. These expenses are in addition to the Financial Advisory Fee paid to the Client’s individual Financial Advisory Firm and the Platform Fee payable to AssetMark. The ratios of fund expenses to assets vary from fund to fund according to the actual amounts of expenses incurred and fluctuations in the fund’s daily net assets. Information on the specific expenses for each of the mutual funds is set forth in the fund’s prospectus and periodic reports. The cost of advisory and investment management services provided through the Platform can be more or less than the cost of purchasing similar services separately. For example, direct investment in a mutual fund or ETF would be less expensive than investment in the same fund through the Platform, because the Client would not bear any Advisor Benefits Program for Financial Advisors Under AssetMark’s Advisor Benefits Program, Financial Advisors have the option to utilize AssetMark’s advisor-directed tools, templates and best practices, or to engage with AssetMark to receive business and investment consulting, and/or, education and guidance for implementing a growth plan for their businesses. Certain Financial Advisors can receive an allowance or “growth support” for reimbursement of qualified expenses incurred by the Financial Advisor based on their participation in AssetMark sponsored events, marketing initiatives, or use of technology resources and tools. Financial Advisors can also receive benefits by reaching certain levels, or tiers, on the AssetMark Platform. This program creates a financial incentive for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. Referral Disclosure BrochureThis must remain with the Client Page 12 of 37 long-term obligations by those Financial Advisory Firms that can be costly or difficult for those firms to terminate and certain of those arrangements may give AssetMark the right to convert the debt obligation into equity in the Financial Advisory Firm, giving AssetMark certain additional rights. Therefore, these loans can create an on- going conflict of interest for Financial Advisory Firms between their own financial interests tied to those financing arrangements and the interests of their Clients. Payment for testimonials/endorsements Financial Advisors may provide video, audio or documented statements endorsing AssetMark, and AssetMark may compensate the Financial Advisors for these. Community Inspiration Award In order to promote community involvement, AssetMark created the Community Inspiration Award to honor selected Financial Advisors across the United States who have inspired others by supporting charitable organizations in their communities. AssetMark will make a cash donation, subject to the published rules governing the program, to the Financial Advisor’s nominated charity in accordance with the following: i) the charitable organization is not a Client or prospective Client of the Financial Advisor, ii) the Financial Advisor cannot hold an officer position on the charitable organization’s board or direct funds at the charitable organization, and iii) the charitable organization must not have the ability to contribute funds or services to a candidate for public office or to a Political Action Committee. There is no direct compensation paid to an honored Financial Advisor. However, the Financial Advisor has an incentive to place, or retain Client assets on the Platform as a result of AssetMark’s contribution to their supported charitable organization. Marketing Support for Financial Advisory Firms Certain Financial Advisory Firms enter into marketing arrangements with AssetMark whereby the Firms receive compensation and/or allowances in amounts based either upon a percentage of the value of new or existing Account assets of Clients referred to AssetMark by Financial Advisors, the addition of new Financial Advisors making use of the Platform, or a flat dollar amount. These arrangements provide the communication of AssetMark‘s service capabilities to Financial Advisors and their Clients in various venues, including participating in meetings, conferences and workshops. AssetMark also provides certain Financial Advisory Firms or their representatives with organizational consulting, education, training and marketing support. These arrangements create a financial incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. Negotiated Fees AssetMark is permitted, in its discretion, to negotiate the Platform Fee for Clients of certain Financial Advisors. Certain Financial Advisors with higher aggregate levels of assets on the Platform are eligible for negotiated fees, which are passed through to the Client. The Financial Advisor does not earn additional compensation as a result of these negotiated fees. These arrangements create an incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. Direct and Indirect Support for Financial Advisors AssetMark sponsors annual conferences for participating Financial Advisory Firms and/or Financial Advisors designed to facilitate and promote the success of the Financial Advisory Firm and/or Financial Advisor and/or AssetMark advisory services. AssetMark offers Portfolio Strategists, Investment Managers and Investment Management Firms, who in some cases also are Sub-Advisors for the GuideMark and GuidePath Funds, the opportunity to contribute to the costs of AssetMark’s annual conferences and be identified as a sponsor. AssetMark covers travel-related expenses for certain Financial Advisors to attend AssetMark’s annual conferences, quarterly meetings or to conduct due diligence visits. In addition to, and outside of the Advisor Benefits Program, AssetMark contributes to the costs incurred by Financial Advisors in connection with conferences or other Client events conducted by the Financial Advisor or the Financial Advisory Firm. AssetMark also solicits research from Financial Advisors regarding new products or services that AssetMark is considering for Clients. In exchange for this feedback and guidance, AssetMark can offer an incentive to the Financial Advisor for their attendance at, or participation in, for example, an online survey or an in-person focus-group. These programs create financial incentives for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. Pilot and Early Release Programs AssetMark can invite certain Financial Advisor Firms to participate in pilot or early release programs designed to solicit feedback on new product or service offerings. In exchange for participation in these programs, AssetMark may provide certain incentives to the Financial Advisor Firms such as fee waivers, or other incentives. Discounted Fees for Financial Advisors Financial Advisors can receive discounted pricing or complimentary subscriptions from third-party service providers or from AssetMark or its affiliates for services such as business consulting, practice management, technology, financial planning tools and marketing- related tools and services because of their participation in the Platform. In certain cases, AssetMark receives a portion of the subscription fees paid by Financial Advisors to such third-party service providers. Discounted pricing and complimentary subscriptions can be subsidized by AssetMark. These arrangements create a financial incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. Strategist Fees In circumstances where a Financial Advisory Firm uses a Portfolio Strategist to assist in the management of a Client’s account, AssetMark will pay a strategist fee on a selected basis to the Financial Advisory Firm for use and monitoring of the model portfolio recommended by the Portfolio Strategist. This strategist fee creates a conflict of interest because the Financial Advisory Firm has an incentive to use the model portfolios produced by a Portfolio Strategist in order to keep receiving the fee, compared to other arrangements that might be less expensive or more appropriate for the Client. Transitions Program for Financial Advisory Firms AssetMark and its affiliates may enter into business arrangements designed to assist Financial Advisory Firms with succession planning, and will continue to do so. These financing arrangements result in additional revenue to AssetMark and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has agreed to share a portion of their Firm’s revenue with AssetMark and will have an incentive to continue using AssetMark’s products Loans by AssetMark to Financial Advisory Firms AssetMark and its affiliates have made loans on a selected basis to some Financial Advisory Firms, and will continue to do so in certain circumstances. These financing arrangements result in additional revenue to AssetMark (primarily interest earned on those loans) and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has borrowed money from AssetMark and that still has a loan balance outstanding will have an incentive to continue using AssetMark’s products and services for its Clients even when AssetMark’s services can be more expensive or less appropriate for the Client. Certain financing arrangements are structured to create Referral Disclosure BrochureThis must remain with the Client Page 13 of 37 Investment Minimums - Account Size and services for its Clients even when AssetMark’s services can be more expensive or less appropriate for the Client. Therefore, these business arrangements can create a conflict of interest for Financial Advisory Firms between their own financial interests and the interests of their Clients. ASSETMARK CASH PAYMENTS TO THIRD PARTIES Investment Minimums are periodically reviewed and subject to change. AssetMark can, in its discretion, waive the Investment Minimum requirement from time to time. Accounts falling below the Investment Minimum can duly impair the ability to be fully invested in your selected model. It is also important to note that certain investment solutions are subject to a Minimum Account Fee, which might be charged when an account falls below the Investment Minimum. For example, this can occur when you make significant withdrawals from your account. Accounts below the Investment Minimum can be terminated by AssetMark after notice is provided to the Financial Advisor and/or the end investor. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION SELECTION AND REVIEW OF PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS AssetMark makes cash payments to third parties (“Referring Firms”) for referrals (“Referral Fees”) of Financial Advisory Firms (“Referred Financial Advisory Firms”) that enter into a Referral Model selling arrangement (“Referral Arrangements”). In certain cases, Referral Fees shall be discounted in the event that a Referring Firm receives compensation from a qualified custodian (as defined in Item 9 below under Custodial Relationships) in connection with the referral of a Referred Financial Advisory Firm. Each Referring Firm enters into a written agreement with AssetMark and discloses in writing to each prospective Referred Financial Advisory Firm the existence of the Referral Arrangement. Referral Arrangements will not increase the fees payable by Clients of Referred Financial Advisory Firms under the IMSA. PORTFOLIO STRATEGISTS ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Clients on the Platform include but are not limited to individuals, high- net-worth individuals, retirement plans, corporations, partnerships, trusts, insurance companies, charitable organizations and banks. The Portfolio Strategists and Investment Managers used in Model and IMA Solution Types are selected for the Platform by AssetMark in order to make available a curated range of investment options and philosophies to Clients and their Financial Advisors. The selection and due diligence process is described below. Each of the Portfolio Strategists provides to AssetMark a range of investment allocations that will correspond to some or all of the six Risk/Return Profiles, ranging from most conservative to most aggressive, as discussed above under “RISK/RETURN PROFILES”. If the Client’s Account is an Individual Retirement Account (“IRA”) or subject to ERISA, the Client and/or their Financial Advisor must inform AssetMark in writing, and the Client agrees to be bound by the terms of the “ERISA and IRA Supplement to AssetMark Investment Management Services Agreement.” Unless expressly agreed to in writing, AssetMark does not serve as a trustee or plan administrator for any ERISA plan and does not advise such plans on issues such as funding, diversification or distribution of plan assets. For the Guided Income Solutions, the typical Client will be an individual who is either close to retirement or currently in retirement and would like to use a portion of their savings to generate a monthly income stream. The Portfolio Strategists use technical and/or fundamental analysis techniques in formulating their investment decisions to meet their targeted objective. Although each of the Risk/Return Profiles includes asset allocations developed by several Portfolio Strategists, each of the Portfolio Strategists nevertheless has its own investment style resulting in the use of different asset classes, and mutual fund, ETF, or investment management firm options within their asset allocations. Investment Strategies can be a single asset class or multiple asset classes which may include, but are not limited to the following: • U.S. Equities: Large-Cap Growth, Large-Cap Value, Mid-Cap Growth, Mid-Cap Value, Small-Cap Growth, Small-Cap Value • International Equities: Developed Markets, Emerging Markets • Fixed Income: U.S. Core, High-Yield, Global, International, Emerging Markets • Other: REITs, Commodities, Absolute Return Strategies, Hedging Strategies and other non-standard sectors including Alternatives A Client must deposit the Account minimum into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a managed Account until the Account balance reaches the required minimum. A Client’s Account will be held by the Custodian in cash or in the assets transferred in-kind until such time as the value of the deposits to the Account reaches the required minimum for investment. If accounts are at AssetMark Trust, the cash balance will be invested in the AssetMark Trust’s ICD Program. • Cash. Clients should be aware that a reasonable amount of time will be needed to purchase, redeem, settle and/or transfer assets, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. The objective is to provide Clients with a variety of Investment Strategies and approaches for accomplishing the Client’s investment objectives. The Client and their Financial Advisor should review each Portfolio Strategist’s investment style prior to selecting the Portfolio Strategist and Investment Strategy for each Client Account on the Platform. A Client must work with a Financial Advisor who will assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet their financial needs. If a Client does not have a Financial Advisor, e.g. Financial Advisor is terminated or retires, the Client must assign a new Financial Advisor. Otherwise, the account will be deemed to be an Orphaned Account and AssetMark will take steps to terminate the IMSA. Portfolio Strategists will provide AssetMark with instructions to rebalance (to most recent Model Portfolio allocations) or to reallocate (to new Model Portfolio allocations), either periodically or as they deem appropriate over time, depending on their specific Investment Approach and investment process. These adjustments to the asset allocations will result in transactions in Client accounts. The Financial Advisory Firm or the Client instructs and directs that the Client’s Referral Disclosure BrochureThis must remain with the Client Page 14 of 37 account be invested in accordance with all rebalancing and adjustment instructions provided by the Portfolio Strategists unless and until the Client or Financial Advisory Firm expressly terminates the rebalancing and adjustments and/or executes written instructions to change the Strategy in which the account is invested. Client will receive notification of all account transactions in periodic account statements provided by the account Custodian. AssetMark negotiates agreements with each Portfolio Strategist separately and the terms of these agreements vary from firm to firm, which creates a potential incentive for AssetMark to favor one Portfolio Strategist over another based on how advantageous that firm’s agreement is for AssetMark. For more information regarding specific Portfolio Strategist’s’ investment processes and philosophy, or to request a copy of a Portfolio Strategist’s Form ADV Part 2A Disclosures Brochure, contact the Financial Advisor or AssetMark’s Compliance department at the address on the front cover of this Brochure. INVESTMENT MANAGEMENT FIRMS independent AssetMark uses investment management firms (referred to as “Investment Managers” or “Discretionary Managers”) in the certain IMAs. independent AssetMark has contracted with Portfolio Strategists, to provide recommended allocations based upon the corresponding risk profile determined by the Client and the Advisor, by which AssetMark intends to invest the Account, unless circumstances indicate modified allocations or investments are appropriate. These allocation recommendations are implemented by AssetMark in Client Accounts when they are received from the Portfolio Strategists and will result in transactions in the impacted Accounts. Portfolio Strategists will guide AssetMark with instructions to rebalance portfolios (return back to policy mix) and/or reallocate (change the target mix), either periodically or as they deem appropriate over time, depending on their specific Investment Approach and investment process. The Investment Management Firms acting as Investment Managers or Discretionary Managers in their discretionary management capacity, and acting as the Investment Management Firms in their advisory capacity, depending on the Solution Type in question, are all referred to below as Investment Management Firms in the discussion of their selection and oversight. The selection and due diligence process is described below. AssetMark negotiates agreements with each independent Investment Management Firm separately and the terms of these agreements vary from firm to firm, which creates a potential incentive for AssetMark to choose one independent Investment Management Firm over another based on how advantageous that firm’s agreement is for AssetMark. SELECTION AND DUE DILIGENCE PROCESS FOR PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS Although some of the Portfolio Strategists creating portfolios comprised of mutual funds consider all of the mutual funds available under the Platform, certain Portfolio Strategists compose their mutual fund allocations utilizing those mutual funds managed by the Portfolio Strategist or an affiliate of the Portfolio Strategist. This creates a conflict of interest for these Portfolio Strategists, as discussed above. In addition, one or more of the Portfolio Strategists will construct their allocations using AssetMark’s Proprietary Funds. A Prospectus for the Proprietary Funds can be obtained upon request from AssetMark or the Financial Advisor. Clients should review prospectuses and consult with their Financial Advisor if they have questions regarding these Funds. Each portfolio strategist and investment manager completes a detailed questionnaire (“DDQ”) about their investment process, performance and reporting and risk management, in addition to covering business organization, compliance and ethics, operational framework, and client support. The DDQ is reviewed by AssetMark Due Diligence with compliance and ethics sections also being reviewed by AssetMark’s compliance group. An external third party is used for operational due diligence review. AssetMark’s due diligence process is deep and thorough and focuses on five key P’s; People, Philosophy, Process, Portfolio Construction and Performance. Consistency in the first four explains performance so we spend most of our time understanding the qualitative and quantitative aspects of a manager and strategy and use performance as the confirmation of our understanding. The team seeks the following in the five key P’s: 1. People – stable and tenured teams that have experience managing through different market environments. 2. Philosophy – a philosophy that is clearly defined and articulated well. Understanding the foundations to the philosophy and how it has adapted over time is critical. 3. Process – a consistent application of the investment process. Demonstrating how investment decisions were made in multiple market environments and tying the decisions back to the philosophy. AssetMark makes available to the Financial Advisory Firm and the Financial Advisor factsheets of each investment solution managed by the Portfolio Strategists and Investment Managers. This includes a brief review of each firm, including key investment management personnel, strategy process, allocation shifts and performance metrics. The Client and Financial Advisory Firm can select more than one Portfolio Strategist and/or Investment Strategy for the Client’s Accounts, and, as noted above, the Client and Financial Advisory Firm are free to change Portfolio Strategists, Investment Strategy or the mutual fund or ETF components of their Portfolios from time to time, though any change by a Client in the components of a specific asset allocation used for a Client’s Account will result in a custom portfolio for that Account which would no longer be automatically rebalanced along with the Portfolio Strategist’s rebalancing of its asset allocation. The Client is free to consult with the Financial Advisory Firm at any time concerning the portfolio, and AssetMark is available to consult with Clients and Financial Advisory Firms concerning the administration of the Platform. It is not anticipated that Clients or Financial Advisory Firms will have the opportunity to consult directly with the Portfolio Strategists concerning their asset allocation Strategies, although the Financial Advisory Firms will be provided with information concerning such Strategies and any updates or revisions to such information. For more information regarding specific Portfolio Strategists’ investment processes and philosophy, or to request a copy of a Portfolio Strategist’s Form ADV Part 2A Disclosure Brochure, contact the Financial Advisor or AssetMark’s Compliance department at the address on the front cover of this Brochure. 4. Portfolio Construction – rigor in the risk oversight in building the portfolio. A clear discipline and process that shows how risk management is considered in the investment process. 5. Performance – the proof statement and purposefully last. The team’s evaluation of the other P’s builds up their expectations of how the strategy should perform. The actual results are used to confirm expectations and to demonstrate how the manager adds value over time. AssetMark will from time to time add or remove a Portfolio Strategist in its discretion. As the Portfolio Strategists identify other mutual funds, ETFs or investment management firms suitable for the Platform, AssetMark will periodically add or remove mutual funds, ETFs or investment management firms to those available for use in the Portfolio Strategists’ asset allocations. Referral Disclosure BrochureThis must remain with the Client Page 15 of 37 not calculated or reviewed by AssetMark due to the custom nature of these strategies. For Client level performance, the InvestCloud APL system is used to calculate a time weighted rate of return. Performance results are displayed to each Client daily, via eWealthManager.com, if selected by the Financial Advisor and more formally quarterly via Clients’ Quarterly Performance Review, if selected by the Financial Advisor. ASSETMARK AS PORTFOLIO STRATEGIST OR INVESTMENT MANAGER AssetMark also serves as the Portfolio Strategist and Investment Manager for certain Model and IMA Solution Types. Refer to Exhibit B – AssetMark Asset Management – Solution Types for more detailed information. For new searches, all findings are reported to the Due Diligence Investment Committee prior to being reviewed by the Investment Oversight Committee (“IOC”). Once selected for the Platform, the Due Diligence team conducts quarterly reviews via conference calls or in person to discuss, among other things, performance, changes to their investment process and philosophy and any material organizational changes at the firm. For ongoing monitoring all findings are reported to the Due Diligence Investment Committee on a quarterly basis, or sooner based on the significance of the findings. In the event of significant news occurring within a quarter, the Due Diligence team is in immediate contact with the Strategist or Investment Manager to fully understand the impact of the news. If a change in status is warranted, an interim investment committee meeting will be held, and relevant action taken. Any strategists on non-satisfactory status are listed in a report that is available on eWealthManager and are reviewed with the IOC on a quarterly basis. INVESTMENT DISCRETION AssetMark accepts discretionary authority to manage the assets in the Client’s Account. Pursuant to the IMSA, the Client grants AssetMark the authority to manage the assets in their Accounts on a fully discretionary basis. The grant of discretionary authority to AssetMark includes, but is not limited to the authority to: • take any and all actions on the Client’s behalf that AssetMark determines to be customary or appropriate for a discretionary investment adviser to perform, including the authority to buy, sell, select, remove, replace and vote proxies for securities, including mutual fund shares and including those advised by AssetMark or an affiliate, and other investments, for the Account, and to determine the portion of assets in the Account to be allocated to each investment or asset class and to change such allocations; • select the broker-dealers or others with which transactions for the Account will be effected; AssetMark charges to Portfolio Strategists and IMA Managers that have been selected to participate on the Platform a one-time set up fee and an annual maintenance fee (which is typically tiered such that the fee will increase to the extent that Client Account assets invested in Model Portfolios and/or IMA Accounts managed by Portfolio Strategists and IMA Managers exceed certain thresholds) for performing certain functions, which may include administrative, operational, compliance, investment and marketing functions, in connection with adding and maintaining the Portfolio Strategist or IMA Manager on the Platform. This creates a conflict of interest for AssetMark because it provides a financial incentive for AssetMark to favor Portfolio Strategists and IMA Managers who agree to pay the fee in order to participate on the Platform. AssetMark offers a Strategist Data Program through which Portfolio Strategists pay an annual fee to access reports that provide additional detail with respect to assets invested in the Model Portfolios maintained by Portfolio Strategists. AssetMark also offers a Strategist Engagement Program that provides Portfolio Strategists the ability to engage with AssetMark in connection with the support and maintenance of their Model Portfolios on the Platform, including event sponsorships and Strategist Data Program participation, for a bundled annual fee. The Programs described above create a conflict of interest for AssetMark because they provide a financial incentive for AssetMark to favor Portfolio Strategists who pay the fees to participate in the Programs. • retain and replace, or not, any person providing investment advice, securities recommendations, Model Portfolios or other services to AssetMark, including without limitation, Portfolio Strategists giving advice with regard to mutual funds, ETFs, and Investment Management Firms giving advice with regard to IMAs, as deemed appropriate by AssetMark. INVESTMENT AND TAX RISKS However, as discussed above, AssetMark does not select or recommend Investment Solutions to particular Clients or monitor the continuing appropriateness of Investment Solutions for particular Clients. These recommendations and monitoring are the responsibility of the Client’s Financial Advisor. REASONABLE RESTRICTIONS, PLEDGING AND WITHDRAWING SECURITIES AssetMark allows reasonable investment limitations and restrictions when notified of such by the Client. Clients should understand that all investments involve risk (the amount of which vary significantly), that investment performance can never be predicted or guaranteed and that the value of their Accounts will fluctuate due to market conditions and other factors. Clients who open Accounts by transferring securities instead of opening an Account with cash, should also understand that all or a portion of their securities will be sold either at the initiation of or during the course of management of their Accounts. The Client is responsible for all of the tax liabilities arising from such transactions and is encouraged to seek the advice of a qualified tax professional. AssetMark does not provide tax advice. AssetMark Clients have the option to place restrictions against investments in specific securities or types of securities for their Account that are reasonable in light of the advisory services being provided under the different Solution Types offered on the Platform, understanding that any restrictions placed on an Account can adversely affect performance. Requests for such restrictions are reviewed by AssetMark to ensure that they are reasonable and will not unduly impair AssetMark’s ability to pursue the Solution Type and Strategy selected by the Client. Clients can also pledge the securities in their Account or withdraw securities from their Account (transfer in-kind to another Account or Custodian), but must do so by giving instructions in writing to AssetMark and AssetMark Trust. It is important to note Performance for the asset allocation models by the Portfolio Strategists, are calculated monthly using a time weighted methodology in InvestCloud (f/k/a Tegra118 and Fiserv) APL trading and portfolio management system. Performance results are shown on a net of fees basis. Composite performance is calculated using actual Client Accounts. Generally, investment Solutions move from a model-tracking portfolio to composite performance reporting when at least one Account is under the Referral Model and meets the minimum investment amount for the specific strategy at AssetMark in the previous quarter. Performance for IMA Investment Solutions is Referral Disclosure BrochureThis must remain with the Client Page 16 of 37 that restrictions cannot be effected in certain investments or due to operational capabilities such as in a mutual funds, or at the sleeve level within a Multiple Strategy Account. Side-by-side management refers to managing accounts that pay performance fees (fees based on a share of capital gains on or capital appreciation of Account assets) while at the same time managing accounts that do not pay performance fees. AssetMark does not charge performance-based fees. corporate actions in their discretion. Client represents that, under applicable instruments or governing law, Client is authorized to make such direction. Such direction may be amended by the Client at any time by delivering written notice to the Advisor and, if applicable, to the Discretionary Manager. The Advisor shall promptly deliver any such notice through AssetMark to the Discretionary Manager. Client understands and agrees that the terms and conditions of the Client’s election to receive Shareholder Materials and vote proxies, or to delegate to the Discretionary Manager the voting of proxies and receipt of Shareholder Materials, is subject to the terms and conditions imposed by the Custodian and each Discretionary Manager. Investing in securities involves risk of loss that Clients should be prepared to bear. VOTING CLIENT SECURITIES SHAREHOLDER MATERIALS, PROXY VOTING AND CLASS ACTIONS Shareholder materials and proxy voting for Platform Accounts If an Account, for which AssetMark votes proxies, holds shares of a fund for which AssetMark acts as adviser, AssetMark will vote 100% of the shares over which it has voting authority according to instructions it receives from its Clients, which are the Fund’s beneficial shareholders. AssetMark will vote shares with respect to which it does not receive executed proxies, in the same proportion as those shares for which it does receive executed proxies. This is known as “mirror voting” or “echo voting.” Client’s right to vote proxies, and therefore its designation to another to vote proxies, cannot apply to securities that have been loaned pursuant to a securities lending arrangement. Proxy Voting for Administrative Accounts For all Accounts, Client has the right to receive prospectuses, proxy materials and other issuer-related shareholder materials concerning the securities held in their Account (the “Shareholder Materials”) and to vote all proxies and voluntary corporate actions, such as mergers, acquisitions and tender offers or similar occurrences, solicited with respect to securities held in each their Account; provided, however, that the delivery of Shareholder Materials and proxy voting rights shall be subject to the terms of the Client’s agreement with their Custodian and the selected Custodian’s policies and procedures. The Client retains the right to vote proxies if the Account is an Administrative/Non-Managed Account. Class Actions and Similar Actions The Solution Types offered on the AssetMark Platform are Model Portfolios, Individually Managed Accounts (“IMAs”) and Individual Mutual Funds (“IMFs”). The processes for delivery of shareholder materials and voting of proxies for these are as follows. In the instance of an Account invested in a Model Portfolio Strategy or an Individual Mutual Fund, unless other arrangements are made with respect to the securities held in the Client Account, if the Client has selected AssetMark Trust as their Custodian, the Client directs AssetMark to receive all Shareholder Materials and to vote the proxies and voluntary corporate actions in its discretion. Client represents that, under applicable instruments or governing law, Client is authorized to make such direction. Neither Advisor, any Discretionary Manager, AssetMark nor any Portfolio Strategist shall advise or act for the Client with respect to any legal matters, including bankruptcies or class actions, with respect to securities held in the Account. However, if you choose AssetMark Trust as your custodian, pursuant to your Custody Agreement, unless you opt out, you authorize AssetMark Trust to act on your behalf and as your agent and contract with a third party for Class Action Services. AssetMark Trust has contracted with Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to provide Class Action Services to AssetMark Trust custodial clients. These services offered through AssetMark Trust, including the conflicts of interest they create for AssetMark, are detailed below in item 9. Voting Process and Material Conflicts As of March 2025, in the instance of an Account invested in a Model Portfolio Strategy or an Individual Mutual Fund, the practice of third- party Custodians (that is, one other than AssetMark Trust), has been to forward Shareholder Materials to Client, and Clients have been responsible to vote proxies and voluntary corporate actions. For current Clients who have selected a third-party custodian (that is, one other than AssetMark Trust), the current practice of clients receiving Shareholder Materials, including proxies, will continue. However, if a Client becomes a client of a third-party custodian after the end of May 2025, unless other arrangements are made with respect to the securities held in the Account, the Client will direct AssetMark to receive all Shareholder Materials and to vote the proxies and voluntary corporate actions in its discretion. Client represents that, under applicable instruments or governing law, Client is authorized to make such direction. Client always has the right to receive shareholder materials and vote proxies applicable to the securities in the Account. If at any time you would like to receive these materials, contact your Financial Advisor. You may also contact AssetMark at [add email address] or [add mailing address. In the instance of an Individually Managed Account, unless other arrangements are made, the Client directs the Discretionary Manager to receive all Shareholder Materials with respect to the securities held in the Client Account and to vote the proxies and voluntary AssetMark has adopted proxy voting policies and procedures designed to fulfill its duties of care and loyalty to its Clients. AssetMark has adopted a set of voting guidelines provided by an unaffiliated third- party firm with which it has contracted to vote proxies on its behalf. These policies, procedures and the voting guidelines provide that votes will be cast in a manner consistent with the best interests of the Client. The specific guidelines address a broad range of issues including board composition, executive and director compensation, capital structure, corporate reorganizations, shareholder rights, and social and environmental issues. AssetMark’s proxy voting policies and procedures provide for the identification of potential conflicts of interest that can occur due to business, personal or family relationships, determination of whether the potential conflict is material, and they establish procedures to address material conflicts of interest. To address voting items identified as those in which AssetMark has a material conflict of interest, AssetMark generally will rely on the third-party firm to vote according to the guidelines. Alternatively, AssetMark can also refer a proposal to the Client and obtain the Client’s instruction on how to vote or disclose the conflict Referral Disclosure BrochureThis must remain with the Client Page 17 of 37 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Together with their Financial Advisor, Clients invested in High Net Worth and IMA Strategies will have direct access to Investment Managers to discuss their Account. On the other hand, Clients who have selected Model Portfolios will not have access to the Model Provider or Portfolio Strategist. to the Client and obtain the Client’s consent on its vote. AssetMark is not obligated to vote every proxy; there will be instances when refraining from voting is in the best interests of the Client. Because the interests of Clients can differ, AssetMark can vote the securities of different Clients differently. AssetMark will generally delegate the voting of all proxies by the GuideMark Funds to the sub-advisors engaged to advise the GuideMark Funds. ITEM 9 – ADDITIONAL INFORMATION DISCIPLINARY INFORMATION Clients can obtain a copy of AssetMark’s complete proxy voting policies and procedures upon request. Clients can also obtain information from AssetMark about how AssetMark voted any proxies on behalf of their account(s). To obtain proxy voting information, requests should be mailed to: AssetMark, Inc. Attention: Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 advisorcompliance@assetmark.com ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS If a Client selects an IMA Strategy, the Client’s information will be shared with the IMA Manager who has discretionary authority on the Account. Client information will not be shared with Portfolio Strategists who provide asset allocation Strategies and have no discretion over the Account. REVIEW OF ACCOUNTS On September 26, 2023, the SEC issued an Order Instituting Administrative Cease-and-Desist Proceedings against AssetMark. The SEC alleged that, from at least September 2016 through January 2021, AssetMark failed to fully disclose that AssetMark and affiliate AssetMark Trust together set the amount of the payment that AssetMark Trust would retain as compensation from the payment received by the banks that participated in the FDIC-Insured Cash Deposit Program (“ICD Program”) (the “ICD Program Fee”), which, in turn, determined the amount that would be distributed as interest by the banks to clients. The SEC alleged that AssetMark had failed to fully disclose the associated conflicts of interest related to its role in setting the ICD Program Fee. The SEC also alleged that AssetMark, from at least January 2016 through August 2019, did not fully disclose the associated conflicts of interest related to AssetMark’s receipt of custodial support payments from certain no-transaction fee (“NTF”) mutual funds. These failures constituted breaches of AssetMark’s fiduciary duty to advisory clients. The SEC alleged that AssetMark violated Section 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 promulgated thereunder. AssetMark consented to the Order without admitting or denying the SEC’s findings. On August 25, 2016, the SEC announced a settlement with AssetMark in an order containing findings, which AssetMark neither admitted nor denied, that AssetMark violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)-1(a)(5) by allowing its staff, from July 2012 through October 2013, to circulate to prospective Clients who were considering an F-Squared managed account service offered by AssetMark, performance advertisements created by F-Squared relating to a different separately managed account service not offered by AssetMark and which misleadingly described that different service’s performance between 2001 and 2008, and that AssetMark violated Section 204(a) of the Advisers Act and Rule 204-2(a)(16) by failing to maintain records substantiating the performance in the advertisements created by F-Squared. There are no disciplinary items to report for the management team of AssetMark. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Under the IMSA, the Client Account review function is performed by the Client’s Financial Advisor. AssetMark does not assign Client Accounts directly to specific individuals for investment supervision, and there is no single individual or class of individuals within the organization that can be identified as being solely responsible for implementing a full set of review criteria on any one Client Account. Instead, AssetMark offers a Platform of Solution Types to its Clients, each of which is a Model Portfolio to which the Client’s Account is linked. A variety of teams within the organization then have responsibility for reviewing the application of the appropriate investment guidelines to each Account. At the model level, two groups are responsible for ensuring that the investment models to which Client Accounts are linked are consistent with the guidelines and investment Strategy selected by the Client. AssetMark Due Diligence reviews those model recommendations provided by the Portfolio Strategists. AAM reviews on an ongoing basis the performance of the proprietary strategies. The Trade Operations Group monitors account adherence to models provided by Strategists and adherence to models created and maintained by AAM. AssetMark makes available periodic account statements to its investment advisory Clients in the form of a Quarterly Performance Review. A supplemental report is also available for use with Clients in the Guided Income Solutions. These written reports generally contain a list of assets, investment results, and statistical data related to the Client’s Account. AssetMark urges Clients to carefully review these reports and compare them to statements that they receive from their Custodian. AssetMark is a direct subsidiary of AssetMark Financial Holdings, Inc., an independent U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. The following companies are under common control with AssetMark. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Conflicts do exist though, and those are noted below. The industry activities of these affiliated companies are described in further detail below: • Atria Investments, Inc. (d/b/a Adhesion Wealth) • AssetMark Brokerage, LLC The Clients and their Financial Advisors can contact AssetMark to arrange for consultations regarding the management of their Accounts. Clients should refer to their Financial Advisors to discuss and assess their current financial situation, investment needs and future requirements in order to implement and monitor investment portfolios designed to meet the Client’s financial needs. • AssetMark Services, Inc. • AssetMark Trust Company Referral Disclosure BrochureThis must remain with the Client Page 18 of 37 ADMINISTRATIVE SERVICE FEES RECEIVED BY AFFILIATE Adhesion Wealth Adhesion Wealth is a registered investment adviser with the U.S. Securities and Exchange Commission, currently providing sub-advisory services to other registered investment advisers, either directly or through a third party sponsored program. AssetMark Brokerage, LLC AssetMark Brokerage, LLC (“AssetMark Brokerage”) is a broker-dealer registered with the SEC and is a member of FINRA. AssetMark selects mutual funds used in their Solution Types and, generally, the mutual funds selected are institutional share class funds. However, if institutional share class funds are not available, a fund that includes a Rule 12b-1 fee can be selected. Although most mutual funds held by AssetMark Trust client accounts do not pay a 12b-1 fee, administrative service fee or similar income is paid with regard to most funds held by client accounts. This income and variation in payments create conflicts because AssetMark Trust is paid this income, as described below. AssetMark Services, Inc. AssetMark Services, Inc. provides recordkeeping and administrative services to retirement plans. AssetMark Trust Company AssetMark Trust is an Arizona chartered trust company that serves as the Custodian for certain Accounts on the AssetMark Platform. AssetMark also has indirect affiliations with companies under GTCR. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Although not affiliated when AssetMark Trust contracted with the Program Administrator for services, AssetMark Trust and the Program Administrator, as described below in the FDIC-Insured Cash Program, are now under common ownership. AssetMark Trust uses sub-custodians in fulfilling its responsibilities, including National Financial Services Corp., (whose affiliated broker- dealer, Fidelity Brokerage Services, LLC, also provides brokerage and clearing services for Client Accounts), see below, Custodial Relationships. Fidelity operates as a sub-custodian for AssetMark Trust, and as sub-custodian Fidelity receives certain payments from investment companies for certain administrative and recordkeeping services. AssetMark Trust receives payments from Fidelity for the recordkeeping and other administrative duties performed by AssetMark Trust as Custodian. Because Fidelity operates as a sub-custodian for AssetMark Trust, Fidelity remits approximately 92.25% of such fees collected from these investment companies to AssetMark Trust in exchange for the custodial support services AssetMark Trust provides. If an AssetMark-advised fund, e.g., a GuidePath or GuideMark Fund, is used, Fidelity pays AssetMark Trust 100% of the payments. Below are the types of fees AssetMark Trust receives: Some employees of AssetMark are also shared with affiliated entities. This presents potential conflicts around the sharing of client’s personal information, trading practices, and supervision. To mitigate these conflicts, the Company has policies in place to supervise and monitor the activities of these shared employees. AFFILIATE SERVICES AND CONFLICTS OF INTEREST • 12b-1s, which are a cost to the shareholders of the mutual fund. If the prospectus of a mutual fund allows for 12b-1 fees to be paid for either “distribution” or “service,” it will be included in the fund’s expenses and deducted from the income the mutual fund earns; • Administrative Service Fees (“ASFs”), which are not an expense to the shareholders of the fund. These are an expense to the mutual fund and are paid to Fidelity per an agreement between the mutual fund company and Fidelity; • Recordkeeping fees earned on ERISA plan account holdings; and • Transaction-based fees, which may or may not be expenses of the fund. AssetMark also holds fund shares directly, without using Fidelity as sub- custodian. In such a case, the fund or fund company can pay AssetMark Trust ASFs directly. AssetMark Trust receives ASFs from Fidelity, banks and insurance companies, or from their respective service providers. Banking Institution - AssetMark Trust With the input from their Financial Advisors, the Client chooses a Custodian from among those offered through the Platform. AssetMark Trust, an affiliate of AssetMark, is among the available Platform Custodians. If the Client chooses AssetMark Trust as their Platform Custodian, AssetMark Trust is paid for custodial and brokerage services provided to Client Accounts through the Platform Fee charged their Account and, where applicable, through additional fees. Pursuant to a contract between AssetMark and AssetMark Trust, AssetMark pays AssetMark Trust for services AssetMark Trust provides its custodial Clients. Additionally, AssetMark Trust receives payments from mutual funds, mutual fund service providers and other financial institutions for certain services AssetMark Trust provides related to investments held in Client Accounts. AssetMark Trust handles transfer agency functions, shareholder servicing, sub-accounting and tax reporting functions that these financial institutions would otherwise have to perform. Such payments are made to AssetMark Trust by these financial institutions based on the amount of assets invested in Client Accounts. Any such payments to the Custodian will not reduce the Platform Fee. Some mutual funds, or their service providers, provide compensation in connection with the purchase of shares of the funds, unless prohibited by law or regulation. Any such income received by AssetMark Trust is in consideration for services it provides. This amount, in the aggregate, is substantial, in consideration of the services provided by AssetMark Trust to these respective service providers and varies by mutual fund. These payments are used to offset the additional annual custody fee otherwise payable by IRA Clients and Clients with Accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). AssetMark Trust currently waives any portion of this IRA & ERISA Account Fee not offset by this income. CASH MANAGEMENT SERVICES OFFERED BY AFFILIATE Investment Companies - GuideMark Funds and GuidePath Funds The GuidePath Funds are directly managed by AAM and invested in unaffiliated mutual funds and ETFs. AAM manages the GuidePath Funds based on research provided by current Portfolio Strategists in each of the Investment Approaches. AssetMark Due Diligence has ongoing oversight over the performance of the Sub-Advisers in the GuideMark and GuidePath Funds and the Portfolio Strategists on the Platform. If Clients select AssetMark Trust as their Platform Custodian, they will be offered the following cash management services: FDIC-Insured Cash and CDARS Programs; Securities-Backed Lines of Credit; and FDIC-insured checking accounts. AssetMark Trust does not directly provide these services; they are provided to AssetMark Trust Clients through third-party providers, and AssetMark Trust is compensated by Referral Disclosure BrochureThis must remain with the Client Page 19 of 37 the third parties. With the exception of the Cash Allocation (discussed below), these services are optional; Clients can opt out of the services or choose not to use them. A disclosure document further discussing these cash management services, AssetMark Trust Company Disclosures Regarding Services, will be provided to Clients who select AssetMark Trust as their Platform Custodian. Please read this disclosure to better understand the features, costs and conflicts of interest related to these services. The following is only a summary of those disclosures. Cash Program, if the cash is deposited in the ICD Program and not the High Yield Cash Program, then those assets can be aggregated with assets in other Client Accounts with AssetMark for “householding” purposes, which aggregation should result in larger aggregate balances that can reduce the rate(s) of the Platform Fee(s) applicable to other Client Account(s). If the Client has selected a tiered Financial Advisor (or “FA”) Fee, this householding or aggregation of balances can also reduce the rate of the Client’s FA Fee. Deposits in the High Yield Cash Program, however, will not be aggregated with other AssetMark Client Account assets for fee householding purposes. You should determine if you would prefer the higher interest rate(s) offered by HYC or the lower fees available through “householding.” FDIC-Insured Cash Program Cash Allocation in Accounts invested in Platform Strategies: A portion (the “Cash Allocation”) of Client Accounts invested in a Platform Strategy is placed in cash or a cash alternative investment. If you choose AssetMark Trust as your custodian, this Cash Allocation will be placed in AssetMark Trust’s Insured Cash Deposit (“ICD”) program and deposited in one or more banks insured by the Federal Deposit Insurance Corporation (“FDIC”), unless a money market mutual fund is required or requested. AssetMark has established the target Cash Allocation at 2% in part to defray the costs of providing the Platform and to help assure cash is available to pay Financial Advisor Fees and the Platform Fee. The interest your Account earns on the 2% Cash Allocation to FDIC-Insured Cash is less than what typically would be earned on a money market fund. As discussed in more detail below, because of the revenue that AssetMark and its affiliate AssetMark Trust earn from the Cash Allocation, this is a conflict of interest. Fees on Advised Accounts and Conflicts of Interest: The Platform Fee is assessed on 100% of the value of Account assets invested in Platform Strategies upon initial investment and, thereafter, at the end of each calendar quarter, even though the Cash Allocation, cash pending investment or distribution portions of the Account do not receive any investment advisory or brokerage services. (They do receive administrative and custodial services.) The Financial Advisor Fee is also assessed on 100% of the value of assets in Accounts invested in Platform Strategies. In some low interest-rate environments, the Financial Advisor Fee plus Platform Fee can exceed the amount of interest paid on the Cash Allocation. It is anticipated that, when looked at jointly, AssetMark Trust and AssetMark will receive more compensation on the Cash Allocation and cash pending investment or distribution portions of Accounts invested in the ICD Program than on Account assets invested in the Accounts’ investment Strategy. The target Cash Allocation is 2%, and the Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. Accounts enrolled in AssetMark’s Tax Management Service (“TMS)” are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives. In addition to the Cash Allocation, a Client Account can also hold cash pending investment or distribution and these cash amounts will be invested in the ICD Program. Additionally, Funding Accounts will be invested in the ICD Program. (A Funding Account is used to receive cash and assets transferred in kind before sale or transfer to an advised Account.) You may opt out of the ICD Program for your Cash Allocation. If you opt out of the ICD program, your Cash Allocation will be invested in one or more money market mutual funds. Cash that is not yet in a sweep vehicle (due to trading activity, residuals or new cash in a funding account) will simply be held in cash until swept to the ICD program or a money market mutual fund, when cash is moved from the funding to managed account, or typically by the following business day. Administrative Accounts: If a Client selects an Administrative Cash Account, all of the Administrative Cash Account will be placed in the ICD Program, unless the amount of the deposit qualifies for, and the Client elects, the High Yield Cash Program, which is also part of the FDIC Insured Cash Program but one in which the interest rates credited are expected to be higher than those credited ICD Program deposits. The interest rate paid on the High Yield Cash program can be negotiable. General Securities Accounts (“GSAs”) may also hold FDIC- Insured Cash Program funds. You may also opt out of the FDIC-Insured Cash Program, in which case your account will be invested in one or more money market funds. There is no Platform Fee and no Custodial Account Fee for Administrative Cash accounts. Any Financial Advisor Fee payable pursuant to a Client Advisory Agreement will be payable on an Administrative Cash Account unless AssetMark receives instructions not to charge the Financial Advisor Fee. Although there is no Platform Fee for Administrative Cash Accounts with deposits in the FDIC-Insured Client participation in the FDIC-Insured Cash Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust receives compensation from the Program Banks for the record keeping and administrative services it provides in connection with maintaining the FDIC-Insured Cash Program (the “Program Fee”). The interest rates paid Client Accounts under the FDIC-Insured Cash Program are determined by AssetMark Trust, in consultation with AssetMark, and are based on the interest rates paid by the Program Banks, less the Program Fees paid to AssetMark Trust by the Program Banks. In determining the interest rates paid Client Accounts, AssetMark Trust and AssetMark also consider other factors, including the rates paid by competitors. The Program Fees paid to AssetMark Trust can be up to 4% on an annualized basis viewed on a rolling twelve-month basis, and across all Deposit Accounts. The amount of the Program Fee paid to AssetMark Trust and Administrative Fee paid to the third-party Program Administrator reduce the interest rate paid on Client Program Deposits. AssetMark Trust has discretion over the amount of its Program Fee, and AssetMark Trust reserves the right to modify the Program Fees it receives from Program Banks. This discretion in setting the Program Fee creates a conflict of interest on the part of AssetMark Trust and AssetMark; the greater the Program Fee AssetMark Trust receives – which is determined by AssetMark Trust in consultation with AssetMark – the lower the interest rate paid to Clients. In certain interest rate environments, the Program Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Program Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. The gross interest rates paid by each Program Bank, which affects the interest rates paid in the FDIC-Insured Cash Program, do and are expected to vary from Program Bank to Program Bank; this creates a conflict for AssetMark Trust when selecting Program Banks in that it incentivizes AssetMark Trust to select the banks that pay higher interest rates. No part of the Program Fee is paid to Financial Advisors. Neither AssetMark nor AssetMark Trust share any revenue from the Program with individual AssetMark employees, Financial Advisory Firms who use our Platform, or Financial Referral Disclosure BrochureThis must remain with the Client Page 20 of 37 Advisors who provide advice to clients with Accounts on our Platform. This is a mitigation against the conflict of interest relating to the fees and revenue AssetMark Trust (and AssetMark, Inc. as an affiliate) earn from the Program. be up to 4% on an annualized basis viewed on a rolling twelve-month basis across all CDs. AssetMark Trust has discretion over the amount of its Placement Fee, and AssetMark Trust reserves the right to modify the Placement Fees it receives from Destination Institutions. This discretion in setting the Platform Fee creates a conflict of interest on the part of AssetMark Trust and AssetMark; the greater the Placement Fee AssetMark Trust receives – which is determined by AssetMark Trust in consultation with AssetMark – the lower the interest rate paid to Clients on CDs. In certain interest rate environments, the Placement Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Placement Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. No part of the Placement Fee is paid to Financial Advisors. The Program Fees paid to AssetMark Trust can be greater or less than compensation paid to other Platform Custodians with regard to cash sweep vehicles. The interest rate Program Deposits earn with respect to the AssetMark Trust FDIC-Insured Cash Program are expected to be lower than interest rates available to depositors making deposits directly with a Program Bank or with other depository institutions. Program Banks have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Program Bank. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest and other rates available the market, including money market mutual fund rates. The Placement Fees paid to AssetMark Trust can be greater or less than compensation paid to other custodians for similar services. The interest rate CDs earn with respect to the CDARS Program offered through AssetMark Trust can be lower than interest rates available to depositors making deposits directly with, or purchasing CDs directly from, a Destination Institution or other banks or depository institutions. Destination Institutions have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Destination Institution. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest on CDs and other rates available the market, including money market mutual fund rates. If an Account’s cash is invested in a money market mutual fund (because, for example, the Account opted out of the FDIC-Insured Cash Program or is a Section 403(b)(7) custodial account), AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Program Fees it receives from Program Banks in the FDIC-Insured Cash Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers and that has been its recent experience. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Program Fee from Program Banks than the service fee from money market mutual funds. In addition to CDs, AssetMark Trust custodial clients may invest cash in the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts) and/or money market mutual funds. If an Account’s cash is invested in a money market mutual fund, AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Placement Fees it receives from Destination Institutions in the CDARS Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Placement Fee from Destination Institutions than the service fee from money market mutual funds. Securities-Backed Lines of Credit (“SBLOC”) If Clients select AssetMark Trust to act as their Platform Custodian, they can use the holdings in their non-retirement Account(s) as collateral for a loan. Such loans are usually referred to as Securities- Backed Lines of Credit (“SBLOC”). CDARS Program for Certificates of Deposits In addition to the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts), AssetMark Trust makes available to its custodial client a Certificate of Deposit Account Registry Service® (“CDARS”) Program that allows a depositor to deposit amounts in Certificates of Deposit (“CDs”) at one or more depository institution insured by the Federal Deposit Insurance Corporation (“FDIC”). Deposits in the CDARS Program are deposited through a network of individual “Destination Institutions” unaffiliated with AssetMark Trust. Subject to the satisfaction of certain conditions, these deposits are eligible for FDIC insurance up to the maximum amount permitted by the FDIC, currently $250,000 for all deposits held at each Destination Institution in the same legal capacity. AssetMark Trust is not a depository institution and does not issue or offer CDs. There is no Platform Fee is assessed on the CDs held in your GSA. If instructed by your Financial Advisor, a Financial Advisor Fee can be charged. Conflicts of Interest: receives compensation from Suitability: Using an Account as collateral for a loan is not suitable for all Clients. Securities-backed loans involve a number of risks, including the risk of a market downturn, tax implications if pledged securities are liquidated, and the potential increase in interest rates, and other risks. If the value of pledged securities drops below certain levels, the borrower can be required to pay down the loan and/or pledge additional securities. Clients must consider these risks and whether a securities- backed loan is appropriate before applying. Clients should consider these issues and discuss their financial position and objectives and whether using their investments as collateral for a loan is appropriate with their Financial Advisor. Client participation in the CDARS Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust the Destination Institutions for the placement of deposits in CDs through the CDARS Program (the “Placement Fee”). (The third-party administrator of the CDARS Program also receives a fee (“CDARS Administrative Fee”) from the Destination Institutions.) AssetMark Trust, in consultation with AssetMark, determines the amount of its Placement Fee, and the Placement Fee reduces the interest rates paid by the Destination Institutions on the CDs under the CDARS Program, as does the CDARS Administrative Fee paid to the third-party CDARS Program Administrator. In determining the Placement Fee, AssetMark Trust and AssetMark consider a number of other factors, including the rates paid on CDs in competitor programs. The Placement Fees paid AssetMark Trust can There are two general ways for a Client to apply for a loan using the assets in their non-retirement AssetMark Trust custodial Account(s) as collateral: 1. Apply for a loan through a lender available through AssetMark Trust’s Cash Advantage™ Lending service; or 2. Apply for a loan from the lending institution of the Client’s choice. Referral Disclosure BrochureThis must remain with the Client Page 21 of 37 offer Broadridge Class Action Services to its clients. AssetMark Trust addresses this conflict by this disclosure, by making clear to clients that they can opt out of the services and by having a procedure for them to do so. An additional conflict exists as follows. Clients can choose as the Strategy for their Account one managed by AssetMark Trust affiliate, AssetMark. AssetMark would then have the conflict of choosing for its advisory clients securities likely to be involved in class actions, because such could increase the likelihood that AssetMark Trust clients would choose to use Class Action Services. AssetMark Trust and AssetMark address this conflict by disclosing it. AFFILIATE FEE INCOME AND ASSOCIATE CONFLICTS DISCLOSURE AssetMark Trust Company’s Cash Advantage™ Lending Service: AssetMark Trust has established relationships with two separate lenders to which Clients can apply for a line of credit under AssetMark Trust’s Cash Advantage™ Lending service. Currently, the two lenders are Supernova Lending, Inc. (“Supernova”) and The Bancorp Bank, an FDIC-insured bank (“Bancorp”). AssetMark’s arrangements with these lenders are designed to streamline the loan application process and provide the lenders access to information about the Accounts that Clients use as collateral for the loans. AssetMark Trust is not affiliated with either Supernova or Bancorp, and each is responsible for its own services. Clients may also use their own lender. AssetMark Trust does not have the authority to encourage Clients to take a loan and does not have the authority to decide whether one of the lenders in its Cash Advantage™ Lending service will offer Clients loans. The interest rate paid for a line of credit can be negotiable. Compensation and conflicts of Interest: AssetMark Trust benefits if a Client takes a loan because the lenders in the Cash Advantage™ Lending service pay AssetMark Trust compensation based on outstanding loan balances. AssetMark Trust has discretion to reduce its compensation in order to reduce the interest rate charged a loan. AssetMark Trust has a conflict of interest with respect to the interest rates charged on loans; the higher the compensation AssetMark Trust receives, the more expensive the loans are for Clients. GPS Fund Strategies and GPS Select Client Accounts invested in these Strategies will receive allocations, determined by AssetMark, among AssetMark‘s Proprietary Funds. AssetMark receives fees from the Proprietary Funds in which these Accounts invest. The fees differ between Funds and the total fees collected will vary depending upon the profile selected by the Client and the fund allocation within each profile. If a Client elects the GPS Fund Strategies, the Client authorizes and instructs that the Account be invested pursuant to the selected profile, acknowledges that fund advisory and other fees collected by AssetMark will vary, and approves of the fee payments to AssetMark. The Client will be given prior notice if these allocations or mutual funds change resulting in fee payments and, unless the Client or the Financial Advisor gives notice to AssetMark, the Client consents to these changes. If a Client selects GPS Select, the Client authorizes and instructs that the Account be invested pursuant to the selected profile and acknowledges that AssetMark is permitted to modify Fund allocations within a range such that fund management fees earned by AssetMark can vary within a range of 0.30% of the assets in the Strategy. Client approves fund allocations within this range and acknowledges Client will not receive prior notice of the fund allocation changes unless such allocations would exceed the 0.30% range. Deposit Accounts Opened through AssetMark Trust Company’s Cash Advantage™ Service If Clients select AssetMark Trust as their Platform Custodian, they can choose to open a deposit (checking) account at Bancorp, the FDIC-insured bank that offers online banking services and debit cards through AssetMark Trust’s Cash Advantage™ service. Bancorp deposit accounts and AssetMark non-retirement custodial accounts can be linked, so that amounts can be automatically transferred between accounts based upon the minimum and maximum targets set for balances in the Client’s Bancorp checking account. AssetMark Trust benefits financially if Clients open accounts at Bancorp because Bancorp pays AssetMark Trust compensation based on the average monthly balances in Clients’ deposit accounts. CLASS ACTION SERVICES OFFERED BY AFFILIATE For more information regarding the fees collected by AssetMark when using these Strategies, refer to the allocation tables provided in Exhibit C at the end of the Disclosure Brochure. To the extent that an IMA Manager invests Account assets in, or a Portfolio Strategist makes an allocation to, a fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will typically earn investment advisory or other fees from the fund. To the extent that AssetMark makes an allocation or invests Account assets in a fund managed by an AssetMark affiliate, AssetMark will rebate a portion of the fees paid. INCENTIVE COMPENSATION Certain AssetMark associates, typically sales associates, are eligible to receive compensation pursuant to a Sales Incentive Plan (“SIP”). Payments under a SIP are based on meeting certain production goals in support of AssetMark’s long-term growth strategy and profitability but are not based on specific product offerings. Financial Advisors, not AssetMark associates, are responsible for a Client’s suitability and/or investment recommendations. AssetMark can also provide additional incentives for affiliate (Adhesion Wealth Services) program referrals or to promote services, e.g. tax management services. Certain AssetMark associates are also eligible to receive compensation based on meeting production goals specific to AssetMark’s proprietary strategies. These incentives create a conflict of interest because AssetMark associates can earn more compensation in support of AssetMark’s business profitability and growth. AssetMark Trust has contracted with Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to provide Class Action Services to AssetMark Trust custodial clients. Broadridge will be compensated for its Class Action Services to AssetMark Trust clients by retaining 20% of class action proceeds payable to AssetMark Trust clients (who have not opted out of the Class Action Services). AssetMark Trust also uses Broadridge as a service provider for other services. Broadridge is compensated by AssetMark Trust or another party, such as the security issuer, depending on the service. For example, AssetMark Trust pays Broadridge to deliver prospectuses related to the holdings in client accounts to AssetMark Trust clients, but the security issuer pays Broadridge for delivery of proxy materials. Broadridge provides incentives to AssetMark Trust to use Broadridge by providing rebates to AssetMark Trust if multiple services are used. AssetMark Trust receives payments from Broadridge based on the compensation Broadridge receives for delivery of proxy materials to AssetMark Trust clients, and the rate used to calculate these payments will increase if Broadridge Class Action Services are used. The rebate paid by Broadridge to AssetMark Trust (which is based on the compensation Broadridge receives for proxy material delivery from the security issuer) can exceed the amount of fees paid by AssetMark Trust to Broadridge during the year (for prospectus deliveries). This receipt by AssetMark Trust creates a conflict of interest in that it is to AssetMark Trust’s advantage to Referral Disclosure BrochureThis must remain with the Client Page 22 of 37 BROKERAGE PRACTICES CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING TRADE EXECUTION AND BROKERAGE ALLOCATION Trading is directed by and is the responsibility of AssetMark or the Discretionary Manager, if applicable. Subject to the Client’s chosen Solution Type and Strategies, AssetMark or the Discretionary Manager gives instructions for the purchase and sale of securities for Client Accounts. AssetMark or the Discretionary Manager selects the broker-dealers or others with which transactions for Client Accounts are effected. There is often an additional charge by the Platform Custodian, if AssetMark or the Discretionary Manager, as applicable, determines to trade away from the selected brokerage firm. AssetMark has adopted a Code of Ethics (the “Code”) that is intended to comply with the provisions of Rule 204A-1 under the Advisers Act, which requires each registered investment adviser to adopt a code of ethics setting forth standards of conduct and requiring compliance with federal securities laws. Additionally, the Code is designed to comply with Section 204A of the Advisers Act, which requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by any person associated with such investment adviser. The Code requires that all “Supervised Persons” (including officers and certain affiliated persons and employees of AssetMark) in carrying out the operations of AssetMark, adhere to certain standards of business conduct. Specifically, the Code requires that these persons: (i) comply with all applicable laws, rules and regulations; (ii) avoid any conflict of interest with regard to AssetMark and its Clients; (iii) avoid serving their personal interests ahead of the interests of AssetMark and its Clients; (iv) avoid taking inappropriate advantage of their position with AssetMark or benefiting personally from any investment decision made; (v) avoid misusing corporate assets; (vi) conduct all of their personal securities transactions in compliance with the Code; and (vii) maintain, as appropriate, the confidentiality of information regarding AssetMark’s operations. AssetMark or the Discretionary Manager, if applicable, will generally direct most, if not all transactions to the Platform Custodian. Trades are bundled by Custodian in trading blocks and submitted for execution on a pre-determined randomized rotation, or through simultaneous submission to all Custodians. In addition, if the selected Custodian is AssetMark Trust, generally most, if not all transactions will be directed to Fidelity Brokerage Services, LLC, and/or National Financial Services, LLC (collectively and individually “Fidelity”) or other broker-dealers selected by AssetMark, and contracted with by AssetMark Trust, in view of their execution capabilities, and because the selected broker- dealer(s) is paid by AssetMark or AssetMark Trust and generally does not charge Client Accounts transaction based fees or commissions for its execution service. In certain circumstances, better execution could be available from broker-dealers other than the broker-dealer(s) generally used by the Client’s Custodian. AssetMark, or other Discretionary Manager is permitted to trade outside the selected broker-dealer(s). For Accounts custodied at AssetMark Trust, AssetMark, or the Discretionary Manager as applicable, can combine purchase and sale transactions for a security into a single brokerage order. By combining the purchase and sale transactions into a single brokerage order, Clients that are buying a security will receive the same average price as Clients that are selling the same security and Clients selling will receive the same average price as Clients that are buying the same security, based on the single net order placed by AssetMark. This aggregation process could be considered to result in a cross transaction among affected Client Accounts. The Code contains a number of prohibitions and restrictions on personal securities transactions and trading practices that are designed to protect the interests of AssetMark and its Clients. First, the Code prohibits trading practices that have the potential to harm AssetMark and/or its Clients, including excessive trading or market timing activities in any Account that AssetMark manages, trading on the basis of material non-public information, and trading in any “Reportable Security” when they have knowledge the security is being purchased or sold, or is being considered for purchase or sale by the Accounts managed by AssetMark or any AssetMark-advised mutual funds. Second, the Code mandates the pre-clearance of certain personal securities transactions, including transactions in securities sold in initial public offerings or private placements. The Code also requires the pre-clearance of Reportable Security transactions for certain Access Persons (“Access Persons” is a segment of the Supervised Persons group that have access to AssetMark pre-trade information). Finally, the Code requires Access Persons to submit, and the Chief Compliance Officer (the “CCO”) to review initial and annual holdings, and quarterly transaction reports. AssetMark utilizes StarCompliance to provide enhanced tracking of certain employee transactions and gives AssetMark the ability to analyze those employee trades against certain parameters and transactions in its managed Accounts or any Proprietary Funds. Access Persons also utilize this system to annually certify their receipt of, and compliance with, the Code and pre-clear their Reportable Security transactions, if they are required to do so by the Code. Clients should be aware that the arrangement that AssetMark Trust has with Fidelity described above creates a financial incentive for AssetMark to utilize that broker-dealer regardless of execution quality, in order to avoid incurring the charges that accompany trading with other broker-dealers. This incentive creates an actual or potential conflict of interest to the extent that AssetMark utilizes Fidelity to execute trades for Client Accounts when higher quality execution might be available through other broker-dealers. However, in fulfilling its fiduciary obligations, AssetMark evaluates the execution quality received by Clients at their selected Custodians on a periodic basis. Any execution trends over a period of time are researched and discussed at AssetMark’s quarterly Execution Review Committee meeting. In addition, some investment solutions that have historically only been available at AssetMark Trust, are now available at other Custodians. All Supervised Persons under the Code are responsible for reporting any violations of the Code to the CCO. The Code directs the CCO to submit reports to the Board of Trustees of any AssetMark-advised mutual funds regarding compliance with the Code, and to impose sanctions on violators, as warranted. AssetMark will provide a copy of the Code to any Client or prospective Client upon request. ETFs are traded daily at market determined prices on a national exchange in a similar manner to individual equity securities. Although ETFs are traded intra-day in the same manner as equity securities, the actual timing of trade order execution varies, depending upon trade volume, systems limitations and issues beyond AssetMark’s control, and the actual fulfillment of trade orders by the broker in the market can take place at different prices and different times throughout the day. AssetMark submits ETF trades for a given day to each broker in a Referral Disclosure BrochureThis must remain with the Client Page 23 of 37 execution reports from vendors such as Abel Noser and Fidelity, which it uses to review best execution of trades on the Platform. AssetMark does not pay directly for these reports. The Client’s asset-based Platform Fee, which includes custody, does not vary depending on whether AssetMark receives these execution reports or not. CUSTODIAL RELATIONSHIPS random order, or simultaneously where possible, to provide the most feasibly equivalent execution for all participating Clients. On days with heavy trade volumes, AssetMark can utilize “not held” and/or “limit order” instructions in an attempt to reduce market impact on the price received for the security. When a Portfolio Strategist implements a reallocation adjustment or rebalance to its ETF strategy, and/or in the case of exceptionally high volume requests, AssetMark can utilize an alternate agency broker or an “authorized participant” liquidity provider selected by AssetMark to execute orders for Clients at multiple custodians, and then “step out” those trades to those custodians on a net fee basis. AssetMark also seeks and can rely upon a Portfolio Strategist’s recommendation for stepping out to an alternative broker when executing the Portfolio Strategists reallocation. There are no separate fees charged for ETF trades that are stepped out to an alternate broker, unless in the case of a broker trading on an agency basis, in which case their flat fee will be included in the execution price. On a quarterly basis, AssetMark’s Execution Review Committee will review the step out trade activity in the Accounts. AssetMark receives Model Portfolios or trade recommendations from Strategists on a non-discretionary basis. There can be instances in which the policy of a specific Strategist or Discretionary Manager is to effect trades in the Accounts of their discretionary Clients before delivering Model Portfolios to non- discretionary Clients. ACCOUNT LIQUIDITY RESERVE AssetMark does not provide custodial services to its Clients. AssetMark is determined to have custody of client funds in accordance with the SEC’s Custody Rule given the affiliation between AssetMark and AssetMark Trust, the qualified custodian of the Advisor’s clients’ assets. Given this determination, AssetMark will engage an independent public accountant to conduct an annual, independent surprise audit of client funds and securities. Client assets are held with banks, financial institutions or registered broker-dealers (“Platform Custodians” or “Custodians”) that are qualified Custodians under Advisers Act Rule 206(4)–2. Clients will receive custodial account statements directly from their selected Platform Custodian at least quarterly. Clients are urged to carefully review those statements and compare the custodial statements to the quarterly performance reviews that are available to them. The Client agrees to review all Account Statements, trade confirmations and other notices and confirmations of information and promptly notify AssetMark of any errors within 10 days. AssetMark shall not be liable for any losses due to errors that remain unreported for more than 10 days after receipt of mailed Account Statements, trade confirmations and other notices and confirmations of information or the electronic posting of such documents. Not all Solution Types are offered at all Custodians. to the following The AssetMark Platform provides access Platform Custodians: • AssetMark Trust, an Arizona trust company and affiliate of AssetMark, 3200 North Central Avenue, Seventh Floor, Phoenix, Arizona 85012. Its mailing address is P.O. Box 80007, Phoenix, Arizona 85060. • Charles Schwab & Co., Inc. (“Schwab”). 7801 Mesquite Bend Drive, Ste. 112, Irving, TX 75063 • Fidelity Brokerage Services, LLC (“Fidelity”). 200 Seaport To properly maintain cash flows for Client needs, a portion of all Client Accounts invested in a Strategy is maintained in a short-term investment vehicle. This liquidity reserve (or “Cash Allocation”) is generally referred to as the Custodian’s cash “sweep” vehicle. The Cash Allocation target is 2%, and an Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. (Note: Accounts enrolled in AssetMark’s Tax Management Service (“TMS)” are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives.) Boulevard, Boston, MA 02210. • Pershing Advisor Solutions (“PAS”). One Pershing Plaza, Jersey City, NJ 07399. The sweep vehicle for the Cash Allocation will differ by the Custodian and Strategy selected by the Client. At AssetMark Trust, it is usually AssetMark Trust’s Insured Cash Deposit (“ICD”) Program but depending upon the Strategy selected for the account, could be a money market mutual fund or other short-term pooled investment vehicle. Additionally, an AssetMark Trust Client can opt out of the ICD Program for the Account’s Cash Allocation, in which case the Account will be invested in one or more money market funds (see FDIC-Insured Cash Program, above). DELIVERY OF FUND REDEMPTION PROCEEDS On an exception basis, AssetMark can allow for the selection of a Platform Custodian not listed above. The assets of each Client Account are custodied at a Platform Custodian, and each Client must contract separately with their selected Platform Custodian for custodial services. Payment for the custodial and brokerage services provided by the Platform Custodian to the Account are included in the AssetMark Platform Fee. Refer to “Custodial Account Fees and Servicing Costs” below, for more information on what is included in the Platform Fee. The Client authorizes the Custodian to debit Platform Fees from the Account. Mutual funds are included in some Client Accounts. Under certain economic or market conditions or other circumstances, mutual funds pay redemption proceeds by an in-kind distribution of securities in lieu of cash. Mutual funds, broker-dealers or transfer agents can experience delays in processing orders, or suspend redemptions or securities trading under emergency circumstances declared by the SEC, the New York Stock Exchange or other stock exchanges or regulatory agencies. RECEIPT OF EXECUTION REPORTS AssetMark does not utilize soft dollars by directing trades to broker- dealers and accumulating soft dollar credits. AssetMark receives All Client Accounts are separately maintained on the records of the Client’s selected Custodian. With regard to AssetMark Trust, Client funds and securities are typically held in omnibus accounts at various banks, broker-dealers and mutual fund companies. The holdings of these omnibus accounts reflect book-entry securities, which AssetMark Trust allocates to the individual Client Accounts on its own records. AssetMark Trust uses sub-custodians in fulfilling its responsibilities, including National Financial Services Corp., (whose affiliated broker-dealer, Fidelity Brokerage Services, LLC, also provides brokerage and clearing services for Client Accounts), and JP Morgan Chase (f/k/a Bank One). Referral Disclosure BrochureThis must remain with the Client Page 24 of 37 perform, including, for example, reviewing new Account paperwork and communicating with Financial Advisors to resolve incomplete custodial paperwork. These Services are taken into consideration when AssetMark and each Custodian negotiate the compensation that AssetMark will pay the Custodian for providing custodial and brokerage services to Client Accounts. The amount of the compensation that AssetMark pays differs between Custodians. Additionally, AssetMark generally receives more revenue when Clients choose AssetMark Trust as their Custodian. These differences in payments and revenue create conflicts of interest for AssetMark. AssetMark addresses these conflicts by having the same Platform Fee apply regardless of the Custodian chosen and by allowing the Client to choose their own Custodian, which can be AssetMark’s affiliated Custodian, AssetMark Trust. Although the Platform Fee is the same among Custodians, different fees for incidental expenses can apply. Pursuant to the services agreement between AssetMark and AssetMark Trust, AssetMark reallocates expenses for non-advisory services that AssetMark provides to AssetMark Trust. These services are primarily administrative in nature, all of which are provided by AssetMark for the benefit of all affiliates, including AssetMark Trust. PROSPECTUSES & OTHER INFORMATION The Client, with the assistance of their Financial Advisor, shall select a Custodian for their Account. The Custodian selected by the Client shall send periodic account statements detailing the Client’s individual Account(s), including portfolio holdings and market prices, all transactions (such as trades, cash contributions and withdrawals, in-kind transfers of securities, interest and dividend or capital gains payments) for each individual Client Account, and fee deductions. The Custodian will also provide full year-end tax reporting for taxable accounts and fiscal year-end reporting for Accounts held for tax- qualified entities; and access to electronic or web-based inquiry system that provides detailed information on each Client’s Account, on a daily basis. Additionally, Clients can inquire about their current holdings and the value of their Accounts on a daily basis by electronic or web-based access. The Custodian can also send a Transaction Acknowledgement to the Client for all cash contributions, withdrawals and in-kind transfers as they occur. Although the standard form of IMSA provides that the receipt of individual transaction confirmations is waived by the Client, a Client can elect, by written request to AssetMark or AssetMark Trust, to receive a confirmation of each security transaction and such confirmations will thereafter be provided. A Client can incur termination fees from another custodian when transferring their account to ATC. ATC can elect to reimburse these termination fees to the Client. This arrangement can be deemed to cause a conflict of interest because they provide Financial Advisory Firms and Financial Advisors and their Clients with incentives to place Client assets with ATC, and ATC and AssetMark can earn more revenue. The Custodians will mail a letter of acknowledgement confirming the establishment of an Account and receipt of assets, to the Account’s address of record. Clients are strongly encouraged to review all statements, acknowledgements and correspondence sent by the Custodian. CUSTODIAL ACCOUNT FEES AND SERVICING COSTS The Client designates AssetMark, or the applicable Discretionary Manager, as their agent and attorney-in-fact to obtain certain documents related to securities purchased on a discretionary basis for their Account. If the Client selects AssetMark Trust as their Custodian, Clients waive receipt of prospectuses, shareholder reports, proxies and other shareholder documents. This waiver can be rescinded at any time by written notice to AssetMark. Clients that select a Custodian other than AssetMark Trust, i.e., PAS, or Fidelity, elect to receive prospectuses, shareholder reports, proxies and other shareholder materials for Accounts invested in a Mutual Fund Strategy or Guided Portfolios, i.e., GPS Fund Strategies or GPS Select. The Client is entitled to receive materials related to Proprietary Funds advised by AssetMark. FINANCIAL INFORMATION In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition in this Item. AssetMark has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has never been the subject of a bankruptcy proceeding. The Platform Fee is a “wrap” fee and includes payment for custodial and brokerage services. AssetMark pays each Platform Custodian to provide custodial and brokerage services to Client Accounts. Clients do not pay transaction fees on any trades made in the Solution Types available on the Platform, unless described in the separate Custody Agreement with their selected Custodian. There are some Solution Types that do incur additional fees at the Custodian, such as fixed- income solutions or those that hold alternative or option products. Additionally, AssetMark Trust charges an annual Administrative Custody Fee of $25.00 and reserves the right to waive this fee at its discretion. ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS Not applicable to AssetMark as the Platform sponsor. Each Client will enter a custodial agreement with their selected Custodian and be provided a fee schedule or schedule of charges. Refer to the Custody Agreement or schedule of charges for specific fees applicable to the Client Account that are not included in AssetMark’s Platform Fee. For example, the Custodians can also charge termination fees and various other miscellaneous fees for wires, returned checks and other non-standard activity on an Account such as fees for alternative investments. Custody fees can also apply to Accounts in Solution Types that are either closed or no longer offered to new Clients. As well, for some legacy strategies on the AssetMark Platform no longer available to new investors, AssetMark continues to use retail share classes. All custody fee details are clearly presented in each Custodian’s fee schedule and separate custody agreement. AssetMark has negotiated with each Platform Custodian the compensation that AssetMark will pay the Custodian for providing custodial and brokerage services to Client Accounts. AssetMark provides third-party Platform Custodians with significant support services with respect to the custodial services that the Custodians must Referral Disclosure BrochureThis must remain with the Client Page 25 of 37 EXHIBIT A – SOLUTION TYPES – MODEL PROVIDERS AND INDIVIDUAL MANAGED ACCOUNTS ASSETMARK PLATFORM MODEL PORTFOLIOS INDIVIDUALLY MANAGED ACCOUNTS PROPRIETARY 3RD PARTY PROPRIETARY 3RD PARTY GPS Fund Strategies Acadian 4 AssetMark Custom HNW City National Rochdale (HNW) GPS Select1 AlphaSimplex CIBC (HNW) Guided Income Solutions2 Clark PUMA (HNW) Algorithmic Investment Models (former Beaumont) Market Blend - Global William Blair (HNW) Market Blend - US AllianceBernstein 4, 5 Parametric - Custom MarketDimensions BlackRock4, 5 Fixed-Income OBS DFA/EFS Portfolios Brown Advisory 4, 5 Parametric Savos Fixed Income - Laddered Bonds WealthBuilder Capital Group (American Funds) 4 Capital Group AssetMark Asset Builder Dorsey Wright Clark AssetMark Personal Values DoubleLine3 Nuveen AssetMark Income Builder Federated-Hermes 4 I Savos Preservation Fiera Capital 4 Savos GMS/PMP1 First Trust Savos USRC Franklin Templeton Savos Personal Portfolios1 Hartford (Wellington) 4 GuidePath Managed Futures3 JP Morgan 4 Julex6 S N O T U L O S T N E M T S E V N I Kensington Logan 4 Morningstar4 New Frontier Nuveen5 Neuberger Berman3, 4 PIMCO Principal (Principal Edge) State Street Stone Ridge 3 VanEck WestEnd William Blair 4 FINANCIAL ADVISOR CUSTOM ACCOUNTS¹ Multi-Strategy Account (MSA) Custom GPS Select Custom Savos GMS and PMP Savos Personal Portfolios Custom OTHER SERVICES AND NON-MANAGED ACCOUNTS Administrative Accounts General Securities Account ICD and High Yield Cash INVESTMENT VEHICLES closed-end mutual funds; open-end mutual funds; ETFs, alternatives, stocks, fixed income, bonds, options, preferred stocks; treasury bonds, bills and notes, bank notes. ¹ Financial advisor can customize this Model Portfolio to more closely reflect the Client’s specific needs or preferences 2 Goal or target-based Solution 3 Individual Mutual Fund or Model Provider offers at least one Individual Mutual Fund solution 4 Offers at least one equity model; used in SMA Program 5 Offers at least one ESG model 6 Closed to new business Referral Disclosure BrochureThis must remain with the Client  Page 26 of 37 EXHIBIT B – ASSETMARK ASSET MANAGEMENT – SOLUTION TYPES AssetMark Asset Management (“AAM”) serves as the Portfolio Strategist and Investment Manager for the proprietary Models and IMA Solution Types described below. AAM can exercise its discretion by making investment decisions that are tailored to one specific proprietary solution and not applicable to all proprietary solutions on the Platform. risk environment. This allocation mix is met with the use of GuidePath Funds and, as needed, GuideMark Funds. GPS Fund Strategies are available with or without an exposure to alternative investment mutual funds. With the assistance of the Financial Advisor, the Client’s selected GPS Fund Strategy will take into account the Client’s investment objective, if the Client is in an accumulation or distribution phase, if the Client seeks to have exposure to alternative investments or not, or seeks to use GPS Fund Strategies as a focused strategy in order to complement other Solution Types selected for the Client Portfolio. MODEL PORTFOLIOS Investment Objective: Accumulation vs. Distribution. Guided Portfolios • GPS Fund Strategies • GPS Select Accumulation Objective. An accumulation objective typically refers to investors who are still working and seeking to build their wealth base. A blended mix of Investment Strategies with an emphasis on growth of capital is used. Mutual Fund Solution Types • Market Blend (GuideMark Funds) • OBS/DFA • AssetMark Asset Builder Distribution Objective. A distribution objective typically refers to investors who are in or near retirement and seeking to take withdrawals from their asset base over time. A blended mix of Investment Strategies with an emphasis toward providing income with a secondary objective of growth of capital is used. • AssetMark Personal Values • AssetMark Income Builder Exchange-Traded Fund (“ETF”) Solution Types • MarketBlend Focused GPS Fund Strategies. Focused GPS Fund Strategies provide a means for Clients to access pre-set strategies based primarily on the Client’s risk profile and their desire for focused exposure to one or more Investment Strategies used to complement other Solution Types selected for the Client Portfolio. Mutual Fund/ETF Blend Solution Types • WealthBuilder • MarketDimensions Core Markets Focused. Strategies seek to provide exposure to growth of capital markets and are generally allocated to Core solutions blending a mix of equities and bonds. Savos Solution Types • IMA Accounts, (Equity Balanced, Fixed-Income, and Custom High-Net Worth) Tactical Focused. Strategy seeks to provide flexible exposure to the equity market dependent on risk environment and for defensive equity exposure. • Savos Preservation Strategy • Savos GMS Accounts • Savos PMP Accounts Tactical-Low Volatility Focused. Strategies seek to provide flexible exposure to the equity market alongside flexible bond exposures in a blended mix. • Savos US Risk Controlled Strategy, and • Savos Personal Portfolios Guided Income Solutions Low Volatility Focused. Strategy seeks to provide a low correlation to equities with low volatility experience similar to bonds for risk management purposes. I. GUIDED PORTFOLIOS GPS Fund Strategies Multi-Asset Income Focused. Seeks to provide a blend of income and growth, and depending on the profile. A core position in the GuidePath Multi-Asset Income Fund is held with complementary exposure to GuidePath Growth Allocation, Tactical Allocation and Absolute Return. GPS Select For GPS Fund Strategies, AssetMark will provide investment allocations across Investment Strategies based on investment objectives, market outlook, risk profile and other preferences. As of the date of this Brochure, the GPS Fund Strategies primarily utilize NTF mutual funds advised by AssetMark, the GuidePath Funds. AssetMark advised mutual funds, including the GuidePath Funds, are collectively known as “Proprietary Funds”. For GPS Select, AssetMark will provide investment allocations across Investment Approaches based on investment objectives, market outlook, risk profile and other preferences. Additionally, AssetMark will select the mix of Portfolio Strategists and Investment Managers, including AAM Solutions and Proprietary Funds. AAM starts with a baseline allocation across Investment Strategies; however, these allocations will tilt over time based on their view of the risk environment. AssetMark is compensated by the Proprietary Funds for its advisory services provided to the Proprietary Funds. The Platform Fee for the GPS Fund Strategies is lower than that charged for strategies with third party funds. The Platform Fee for the GPS Fund Strategies does not include a charge for advisory services but pays for custodial, trading, administrative and other services. GPS Select will invest in Strategies which include investments in both mutual funds and ETFs. Mutual fund share class is selected on a fund by fund basis and seeks to utilize institutional share classes. Some mutual funds have both institutional share classes, which do not charge fund shareholders 12b-1 fees but which typically do charge fund shareholders for shareholder servicing or sub-transfer AAM starts with a baseline allocation across Investment Strategies; however, these allocations will tilt over time based on their view of the Referral Disclosure BrochureThis must remain with the Client Page 27 of 37 AssetMark manages GPS Select using limited discretionary authority. While AssetMark will exercise limited discretion on the Portfolio asset allocation within portfolio investment sleeves, AssetMark relies upon the third-party Strategists to conduct individual security selection. As discussed above AssetMark will seek to utilize the lowest cost mutual fund share class for Accounts in the GPS Select Solutions, however, because of limitations on the securities available at the Platform Custodians, there will be circumstances where AssetMark is not able to obtain the lowest cost mutual fund share class available, and will have exercised “discretion” in selecting an alternative share class. Refer to Exhibit C at the back of this Disclosure Brochure for more information. MUTUAL FUND SOLUTION TYPES Market Blend Mutual Fund Strategies agent fees, and retail share classes, which charge fund shareholders 12b-1 fees as well as shareholder servicing fees or sub-transfer agent fees. AssetMark will seek to use institutional classes where these share classes are available. AssetMark has determined that for most Clients, transaction fee mutual funds and share classes would be more expensive than non-transaction fee mutual funds and share classes. The Platform Fee for these solutions is used to pay for the administration and servicing of the Accounts that AssetMark performs. In striving for consistency across all custodial options on the Platform in GPS Select, AssetMark will seek to select the lowest cost share class available across Custodians and that aligns the stated program Account minimum and allocation weighting of funds held with the fund’s prospectus requirements. Due to specific custodial or mutual fund company constraints, the institutional share class is not always consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class can be the retail share class. See Servicing Fees Received by Custodians, including AssetMark Trust Company and Share Class Use in Item 4, Service, Fees and Compensation. Market Blend Strategies use Proprietary Funds, and in Market Blend Strategies, AssetMark provides the following strategic asset allocation Strategies. With the assistance of the Financial Advisor, Clients can select from the following Market Blend Mutual Fund Strategies: • Global GuideMark Market Blend With the assistance of the Financial Advisor, Clients can select from the following GPS Select products: • US GuideMark Market Blend • Select Wealth Preservation. Strategy seeks to preserve capital while keeping up with inflation and is allocated with a blended mix to selected Strategist portfolios across Investment Strategies. This Strategy is designed for wealth preservation and protection from inflation. • Select Accumulation. Strategies seek growth of capital and are allocated with a blended mix to selected Strategist portfolios Investment Strategies. • Select Distribution. Strategies seek a blend of income and growth of capital and are allocated with a blended mix to selected Strategist portfolios across Investment Strategies. Strategist selection will be focused toward Strategists managing to a multi-asset income mandate or where income is a large component of the Strategy. This Strategy is also designed to provide an enhanced level of income and to control portfolio volatility. These Strategies will provide a strategic asset allocation across seven to ten core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the portfolio. The Global model will take global exposures while the US model will take domestic exposures. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. The investment vehicles used to implement the Strategy are the proprietary GuideMark Funds that provide exposure to each of the asset classes. AAM manages the Market Blend Strategies and the underlying Proprietary Funds, but the Client, with the advice of the Financial Advisor, chooses whether to invest, or remain invested, in the Market Blend Strategies. AAM does not advise the Client whether to invest, or to remain invested, in the Market Blend Strategies. Focused GPS Select are based primarily on the Client’s risk profile and desire for focused exposure to one or more Investment Strategies used to complement other Solution Types selected for the Client Portfolio. • Select Low Volatility. Strategy seeks to provide a low correlation to equities with low volatility experience and is allocated with a blended mix to selected Strategist portfolios mainly emphasizing bonds. This focused investment Strategy targets low volatility with a low level of return. It is important to note that Client Accounts invested in Market Blend Mutual Fund Strategies will receive allocations, determined by AAM, among the GuideMark Funds. AssetMark will receive advisory fees from the mutual funds in which these Accounts invest. The mutual fund advisory fees differ between funds and the total fund advisory fees collected by AssetMark will vary depending upon the profile selected by the Client and the fund allocation within each profile. If a Client, as advised by the Financial Advisor, selects a Market Blend Mutual Fund Solution, the Client authorizes and instructs that the Account be invested pursuant to the selected profile, acknowledges that the fund advisory fees collected by AssetMark will vary, and approve of the fund advisory fee payments to AssetMark, within the ranges provided In Exhibit C. The Client will be given notice if these ranges or funds change and it results in a higher average weighted fee earned. Unless the Client or Financial Advisor gives notice to AAM, Client consents to these changes. See Exhibit C for more information. • Select Tactical. Strategies seek to provide flexible exposure to the equity market alongside flexible bond exposures and are allocated with a blended mix to selected Strategist portfolios across mainly defensive equity and bond Investment Strategies. This focused investment Strategy seeks to limit participation in extreme market downturns while generally participating in normal markets. Higher risk profiles will hold higher exposure to Tactical Strategies while lower risk profiles will hold higher exposures to Diversifying Strategies. • Select Multi-Asset Income. Strategies seek to provide a blend of income and growth, and are allocated with a blended mix to selected Strategist portfolios across Investment Strategies. This focused investment Strategy seeks to provide an enhanced level of income across changing markets. AssetMark Asset Builder AAM provides strategic asset allocation services utilizing mutual funds. Client asset allocations are dependent on the stated risk parameters and investment objectives of the Client. Assets are managed on a discretionary basis. Clients can transfer existing investments to fund the Account; however, all transferred assets will be liquidated and Referral Disclosure BrochureThis must remain with the Client Page 28 of 37 MUTUAL FUND AND ETF BLEND SOLUTION TYPES MarketDimensions Strategies invested to the appropriate asset allocation without regard to any taxable gains or losses that can result. Periodic Account reviews will include Account rebalancing. Rebalancing can be performed without consideration for any realized taxable gains or losses that result. Clients can place reasonable restrictions on Accounts. For the MarketDimensions Strategies, AAM will seek to create strategic global portfolios through a combination of multiple asset classes including equities and fixed income. In seeking to maximize total return, these Strategies allocate to a diversified portfolio of domestic and international equity securities, domestic and international fixed income securities, and cash equivalent money market securities indirectly using Dimensional Fund Advisors mutual funds and ETFs (“DFA Funds”). With the assistance of the Financial Advisor, Clients can select from the following MarketDimensions Strategies. AssetMark Income Builder Income Builder is an asset allocation strategy designed to provide a higher level of current yield in comparison to traditionally asset allocated portfolios with a similar risk profile. Income Builder will allocate the portfolio across a variety of fixed income and equity investments: traditional fixed income, high yield fixed income, income and growth and traditional equities. While Income Builder is designed to provide a higher current yield, a higher yield is not guaranteed. • Standard. The Global Standard Strategy will represent asset classes selected from the broad universe of DFA Funds. • Tax-Sensitive. The Tax-Sensitive Strategy will represent asset classes seeking to use tax-advantaged DFA Funds where possible. The Strategy will be reallocated typically one to two times per year. AAM will monitor the Strategies’ exposures to the asset classes on an ongoing basis for excessive drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. Beginning or after June 2025, AssetMark will no longer manage these strategies. Dimensional Fund Advisors will be assuming direct oversight and management of these strategies. OBS Strategies AssetMark Socially and Faith Based Screened Portfolios (Values Based Portfolios) At a Client’s request, AAM will offer portfolios managed for various social or faith based considerations (“Personal Values Portfolios”). Such portfolios can be offered under the Asset Builder and the AssetMark Custom High Net Worth strategies. Personal Values Portfolio allocations are typically constructed from mutual funds, but can also include Separately Managed Accounts, individual securities, closed-end funds and exchange traded funds. Mutual funds utilized in Personal Values Portfolios are selected from a more limited menu of mutual funds than “traditional” allocations. As a result, and though not expected, risk characteristics and performance returns of Personal Value Portfolios could vary significantly from our traditional Portfolios. Personal Values Portfolios can also be limited to certain investment types and securities and therefore, may not be fully diversified. You may wish to discuss these limitations with your Financial Advisor. Minimum Account sizes for applicable service levels apply and are subject to negotiation. ETF SOLUTION TYPES Market Blend ETF Strategies With the assistance of the Financial Advisor, Clients can select from the following Market Blend ETF Strategies: AAM will seek to create strategic global portfolios through a combination of multiple asset classes including equities and fixed income. In seeking to maximize total return, these Strategies allocate to a diversified portfolio of domestic and international equity Securities, domestic and international fixed income Securities, and cash equivalent money market securities indirectly using DFA Funds. These strategies will bias towards the factors favored by Dimensional Fund Advisors. With the assistance of the Financial Advisor, Clients can select from the following OBS Strategies. • AssetMark DFA/EFS. The Flagship Strategy will represent asset classes selected from the broad universe of DFA Funds. • AssetMark DFA/EFS. Enhanced International. The Enhanced International Strategy will represent asset classes selected from the broad universe of DFA Funds and will tilt exposures more towards international markets. • Global Market Blend Strategies. These Strategies will provide a global strategic asset allocation across core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the Portfolio. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. On at least an annual basis the asset class exposures are reviewed for reallocation of the Strategy. The investment vehicles used to implement the Strategy are ETFs that are representative of the cap-weighted indices for each of the asset classes and lower cost. The Strategies will be reviewed at least annually for reallocation. AAM will monitor the strategies’ exposures to the asset classes on a quarterly basis for excessive drift against volatility-based targets and will rebalance the Strategies if targets are breached. Beginning or after June 2025, AssetMark will no longer manage these strategies. Dimensional Fund Advisors will be assuming direct oversight and management of these strategies. WealthBuilder Strategies Investment Strategies based on For WealthBuilder Strategies, AAM will provide strategic investment allocations across investment objectives, market outlook, risk profile and other preferences to provide • US Market Blend Strategies. These Strategies will provide a domestic strategic asset allocation across core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the Portfolio. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. On at least an annual basis the asset class exposures are reviewed for reallocation of the Strategy. The investment vehicles used to implement the Strategy are ETFs that are representative of the cap-weighted indices for each of the asset classes and lower cost. Referral Disclosure BrochureThis must remain with the Client Page 29 of 37 Savos GMS, PMP, US Risk Controlled and Savos Personal Portfolios AAM manages UMAs and is also referred to as Discretionary Manager providing discretionary investment management services. AAM selects securities directly for Client Accounts. IMA Accounts are permitted to hold investments selected by AAM, and these investments can include, but are not limited to, some or all of the following types of securities: ETFs; equities, closed-end mutual funds; open-end mutual funds; preferred stocks; Treasury bonds, bills and notes; and bank notes. The asset allocation decisions, and security selection decisions will be made solely by AAM at its discretion. a portfolio seeking to grow their capital. AAM combines a Core Market globally focused Core portfolio of ETFs with complementary third-party mutual funds that represent other Investment Strategies. The Strategy will also be comprised of a 2% allocation to cash. For more information regarding the cash allocation, refer to the ICD Program section under Other Financial Industry Activities and Affiliations and Affiliate Conflicts of Interest. The goal of the portfolio is to manage risk efficiently through diversification of Strategy. The Core Market portfolio will provide a strategic asset allocation across seven to ten core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the portfolio. The portfolio is globally diversified with asset class exposures reviewed on a quarterly basis for drift against volatility-based targets. Where the drift exceeds pre-set criteria, the Account will be rebalanced. The mutual funds complement the Core Market portfolio and are selected based upon their representation of the approach. Each Fund undergoes deep due diligence before being used within the Strategy, and institutional shares are used. On an annual basis, the portfolio’s exposures are reviewed for reallocation of the Strategy. SAVOS SOLUTION TYPES For IMA Accounts, AAM employs comprehensive analysis, including specific mathematical, technical and/or fundamental tools and risk- control criteria in the management of Client Accounts. The focus of AAM as Discretionary Manager is to add value to each Client’s Account through: (i) the strategic and tactical determination and implementation of asset allocation levels; (ii) the selection of securities with investment characteristics which AAM believes are appealing; and (iii) the formation of portfolios with risk management options to match the portfolio to the Client’s chosen level of risk tolerance. • Savos Preservation Strategy • Savos GMS Accounts • Savos PMP Accounts • Savos US Risk Controlled Strategy For GMS and PMP accounts, a risk management strategy is implemented through the use of fixed income strategies. Portfolio allocations for these risk management strategies will vary based on individual Client objectives within target allocations established and monitored by AAM. • Custom Accounts - Savos Personal Portfolios - Savos Fixed Income Strategies • AssetMark Custom High Net Worth Savos Preservation Strategy For the Savos Preservation Strategy, AAM provides discretionary investment management services to the Account, and the Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and such other discretionary authorities described in the IMSA. GMS & PMP Accounts Clients who select the GMS or PMP Account as their Solution Type must deposit at least $25,000 into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $25,000. A Client’s Account will be held by the Platform Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $25,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. In the Savos Preservation Strategy, the Client and their Financial Advisor need not make further selections to specify the Strategy for the Account. The Savos Preservation Strategy is considered to be Risk/ Return Profile 1 as a bond Investment Strategy. In a GMS or PMP Account, the Client authorizes AAM to provide discretionary investment management services to the Account. The Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and the other discretionary authorities described in the IMSA. AAM is permitted to invest the Account in individual securities, pooled investment vehicles, such as mutual funds or ETFs or in other securities or investments. The primary investment objective of the Savos Preservation Strategy is to generate a positive real (after-inflation) return over each 12 month period. A secondary objective is to limit the strategy’s sensitivity to changes in interest rates. Intra-year volatility and performance will vary and are independent of the Strategy’s primary investment objective. There is no guarantee that the Strategy’s primary and secondary investment objective will be met in all market conditions. The Account will be invested primarily in mutual funds and ETFs. Additionally, AAM is permitted to use one or more Proprietary Funds within the Strategy. The Strategy for each Proprietary Fund is described in more detail in the prospectus for the fund. All Proprietary Funds are registered investment companies for which AssetMark serves as investment adviser. is permitted to invest This Strategy in, among other things, “opportunistic” or “specialized” asset categories, which can include real estate, commodities, precious metals, energy and other less traditional asset classes, with no geographic restrictions. AAM will adjust the holdings in a GMS or PMP Account on an ongoing basis. In some instances, AAM will sell or readjust GMS or PMP Account holdings to take advantage of certain opportunities to reduce taxes for the Client. Additionally, AAM is permitted to use one or more Proprietary Funds within the Strategy. The Strategy for each Proprietary Fund is described in more detail in the Proprietary Funds’ prospectus. All Proprietary Funds utilized are registered investment companies for which AssetMark serves as investment adviser. Additionally, Clients should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets during the annual adjustment period, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. Such transactions can take three or more business days. Referral Disclosure BrochureThis must remain with the Client  Page 30 of 37 The US Risk Controlled Strategy is a defensive U.S. equity solution (Tactical Limit Loss) and is offered in a single risk profile, Profile six (6), Maximum Growth. The GMS or PMP Account is a Core Investment Strategy allocating across equities and fixed income. The type of fixed income used will vary depending on the risk profile selected. There are two main investment mandates that a client can choose between: Custom and Advisor - Custom Accounts • High Dividend – The account will primarily be allocated to U.S. stocks and tilted towards dividend paying securities which can include significant allocations to real estate and high dividend paying stocks. • Global – The account will be allocated to U.S. and international securities (including emerging markets). The Client, with the assistance of the Financial Advisor, can request that AAM deviate from standard allocations for the selected GMS or PMP Strategy. Such an Account is considered a Custom GMS or PMP Strategy. The Custom GMS and PMP Strategy can be customized (1) based on a tax-managed transition plan, (2) due to a request to reduce net capital gains on an ongoing basis, or (3) due to a request for other customization. With the assistance of the Client’s Financial Advisor, the Client selects a Risk/Return Profile for the GMS or PMP Account. Only Profiles numbered two (2) through six (6) that is Moderate, Moderate Growth, Growth and Maximum Growth are available. US Risk Controlled Strategy If the Client requests a tax-managed transition, AAM will take commercially reasonable efforts to limit the immediate realization of net gains related to securities transferred in-kind. Clients can also ask that certain securities not be purchased for their Custom account. Clients can request the implementation of socially responsible screens, of Global Industry Classification Standard (“GICS”) codes or social themes, or the exclusion of specific securities by CUSIP. Requests for restrictions are reviewed by AssetMark to ensure that they are reasonable and will not unduly impair AssetMark’s ability to pursue the Strategy selected by the Client. Clients can also request a Custom Account consistent with a proposal or product sheet provided by AAM for the Account. Contact your AssetMark consultant for more information. Clients who select the US Risk Controlled Strategy as their Solution Type must deposit at least $25,000 into their account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $25,000. Discretionary authority includes the authority, without first consulting with the Client to buy, sell, remove and replace securities and to determine the allocations to each investment, select broker-dealers, vote proxies, and take any and all other actions on the Client’s behalf that AAM determines is customary or appropriate for a discretionary investment adviser to perform. A Client’s Account will be held by Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $25,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. In the US Risk Controlled Strategy, the Client authorizes AAM to provide discretionary investment management services to the Account. The Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and other discretionary authorities. AAM retains the right to allocate across asset classes, which will include such recommended securities, in its own discretion. AAM invests the Account in individual securities and ETFs. Additionally, the Client, can choose to participate in a program in which their Financial Advisor, in consultation with AAM, can request further customization for their Client’s Account (“Advisor – Custom Accounts” or “ACA”). The Financial Advisory Firm will be solely responsible for determining the additional customization and the suitability for the Client. AAM, in its discretion, will determine the implementation of the ACA. The Financial Advisory Firm will be solely responsible for determining the additional customization. The Financial Advisory Firm can request that AAM recommend to the Financial Advisory Firm asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the custom models developed by the Financial Advisory Firm may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for the GMS or PMP Accounts described below. The GMS or PMP Platform Fee schedules will be charged to the Client Account, unless otherwise negotiated between the Financial Advisory Firm and AAM. Savos Personal Portfolios The US Risk Controlled Strategy adjusts equity exposure, seeking to limit losses in extreme market declines while participating in equity market returns most of the time. AAM will adjust the holdings in the US Risk Controlled Strategy based on a proprietary indicator. AAM will sell or readjust holdings where appropriate based on the indicator. During periods of heightened market volatility, AAM will have the ability to adjust the holdings to a non-equity alternative. During periods of low market volatility, AAM will have the ability to adjust the holdings to use a leveraged investment to obtain additional market exposure. Clients who select the Savos Personal Portfolios must deposit at least $150,000 into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $150,000. A Client’s Account will be held by Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $150,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. Additionally, Clients should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets during the adjustment period, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. Such transactions can take three or more business days. In Savos Personal Portfolios, the Client authorizes AAM to provide discretionary investment management services to the Account. The Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and other discretionary authorities. AAM retains the right to allocate across asset classes, which will include such recommended securities, in its own discretion. AAM invests the Account in individual securities, mutual funds and ETFs. Referral Disclosure BrochureThis must remain with the Client Page 31 of 37 AssetMark Custom High Net Worth Savos Personal Portfolios is a Core Investment Strategy invested in a mix of traditional asset classes, mainly equities and fixed income, and a tactical Strategy. Savos Personal Portfolios seeks to provide total return through the combination of multiple asset classes predominantly in equity and fixed income. The tactical sleeve adjusts equity exposure, seeking to limit losses in extreme market declines while participating in equity market returns most of the time. The fixed income holdings will include a combination of ETFs and/or mutual funds selected to maximize the yield of the fixed income sleeve while managing to pre- defined risk limits. The Tax-Sensitive Strategies will offer an optional, personalized tax-managed transition in the Account and will also offer tax-loss harvesting to Clients. There are two main investment mandates a client can choose between: • Growth and Growth Tax-Sensitive - The Strategy focuses on growth whereby equity exposure is taken across U.S. and international equity market securities (including emerging markets), targeting stocks selected to maximize exposure to equity style factors such as value, momentum, and quality. The AssetMark Custom High Net Worth service is available through AAM. The minimum Account size for this Account is $500,000. AAM uses a number of the Strategies and advisory services in providing discretionary investment management services to the Custom High Net Worth Account. AAM can invest the Account in direct securities, pooled investment vehicles, such as open-end mutual funds, closed- end investment companies, including ETFs, or in other securities or investments. AAM retains the right to allocate across asset classes, in its own discretion. Portions of the Account will also be managed by third-party model providers that AAM selects, retains and replaces in its discretion. For the fixed income portion of the Custom High Net Worth Account, AAM will use pooled vehicles or have a third-party Discretionary Manager manage with discretion that portion of the Client’s Account. AAM will remove, add or replace the third-party Discretionary Manager in its discretion. The Client grants AAM the authority to buy and sell securities for the Account and to vote proxies for securities held by the Account. When a third-party Discretionary Manager is used, the Client grants that third-party Discretionary Manager the authority to buy and sell securities and investments and to vote proxies for securities held in that portion of the Account it manages. • Dividend and Dividend Tax-Sensitive - The Strategy focuses on growth and income whereby equity exposure targets stocks that exhibit positive exposure to equity style factors including dividend yield. The Savos Personal Portfolios follow the Core Markets Investment Approach. Profiles numbered three (3) through six (6), are available for the Savos Personal Portfolios, and can be customized based on a tax-managed transition plan. Savos Personal Portfolios - Custom Clients in the AssetMark Custom High Net Worth service have the option to place restrictions against investments in specific securities or types of securities for their Account that are reasonable in light of the advisory services being provided. Requests for such restrictions are reviewed by AAM to ensure that they are reasonable and will not unduly impair AAM’s ability to pursue the Account’s investment objective. As may be limited by the Custodian’s policies and procedures, Clients can also pledge the securities in their Account or withdraw securities from their Account (transfer in-kind to another Account or Custodian), but must do so by giving instructions in writing to the Custodian. Savos Fixed Income Strategies For Savos Fixed Income Accounts, AAM acts as Investment Manager for Client Accounts. The available Mandates for the Savos Fixed Income Accounts are as follows: A Savos Personal Portfolio – Custom Account can be customized within a specific range across equity, fixed-income and tactical allocations. The Client, with the assistance of their Financial Advisor, can select from various Savos Strategies. In doing so, and by selecting within the range of pre-determined allocations, a Savos Personal Portfolios – Custom Account will be established. Each equity, fixed-income and tactical allocation is referred to as a “sleeve” allocation. • Laddered Bond Mandates. These Strategies invest the Account in either U.S. Treasury, U.S. Agency or U.S. Treasury Inflation Protected bonds, with an intermediate or short duration, typically on a buy and hold basis. AAM will make available the specific range of pre-determined allocations, which range will be updated from time to time. The number of sleeves selected can vary from a minimum of one to a maximum of nine sleeve selections, to comprise the entire Savos Personal Portfolios - Custom Account. There is an investment minimum of $20,000 in the equity and tactical sleeve, and $10,000 for the fixed- income sleeve. • Municipal, Duration-based and the High Income Mandates. These standard Strategies invest the Account in closed-end funds, ETFs or mutual funds to obtain relevant exposure specific to desired asset categories. The Custom Savos Personal Portfolio Strategy can be customized based on a tax-managed transition plan. The Financial Advisory Firm and the Financial Advisor will be solely responsible for determining the Risk Return profile, additional customization and the suitability for the Client Account. AAM, in its discretion, will determine the implementation of the AAM Personal Portfolio – Custom. AAM does not provide any individualized investment advice to Savos Personal Portfolios – Custom. The asset allocation classification of the custom models developed by the Financial Advisory Firm may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure. Profiles numbered one (1) through six (6), are available for the Savos Personal Portfolios Custom Account. • Advisor – Custom Accounts. The Client can choose to participate in a program in which their Financial Advisor, in consultation with AAM, can request further customization for their Client’s Account (“Advisor – Custom Accounts” or “ACA”). The Financial Advisory Firm will be solely responsible for determining the additional customization and the suitability for the Client. AAM, in its discretion, will determine the implementation of the ACA. The Financial Advisory Firm can re- quest that AAM recommend to the Financial Advisory Firm asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the custom models developed by the Financial Advisory Firm may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for the Fixed Income strategies described above, and the AAM Fixed Income Platform Fee schedule will be charged to the Client Account, unless otherwise negotiated between the Financial Advisory Firm and AAM. Referral Disclosure BrochureThis must remain with the Client Page 32 of 37 SAVOS DYNAMIC HEDGING FEATURE ASSETMARK GUIDED INCOME SOLUTIONSSM The Dynamic Hedging feature is offered within certain Solution Types managed by AAM. The primary investment objective of the Dynamic Hedging feature is to mitigate losses resulting from a severe and sustained decline in the broad-based equity markets. AAM will implement the Dynamic Hedging feature by investing in any number of hedging, fixed income or other protective investment vehicles. Investment Objective The goal of the Dynamic Hedging feature is to participate in the growth of equity markets while also providing risk management protection during periods of sustained and severe equity market decline. The Dynamic Hedging feature seeks to allow investors to stay invested for the long term by partially offsetting extreme declines in the equity markets while also seeking to provide positive total returns in rising markets. Risks The Guided Income Solutions are designed to provide Clients with a regular income stream from their investment Account based on the Client’s objectives and specified criteria. In this program, the Financial Advisor provides the Client criteria, such as desired income and frequency. Based on these responses, a Guided Income Solutions portfolio and portfolio risk profile, seeking to generate the targeted level of distributions, will be suggested for the Client. The Financial Advisor can accept that portfolio or amend the Client criteria based on the Client objectives, risk tolerance or other factors before making a final Guided Income Solution portfolio election. Each risk profile is linked to the portfolio’s remaining life. A portfolio that is within 10 years of its end date is deemed to be Profile 1, a portfolio that has more than 10 years but less than 20 years until its end date is deemed to be Profile 2, and a portfolio that has more than 20 years until its end date is deemed to be Profile 3. The portfolio will be broadly diversified and seeks to meet the portfolio’s stated investment time horizon; however, there is no assurance that the time horizon can be met. On an annual basis, the portfolios will be reviewed and the portfolio risk profiles will be adjusted to reflect the remaining life of the portfolio. No Guarantee; Expressed or Implied The Guided Income Solutions advisory service will primarily invest in three GuidePath Funds. GuidePath Funds do not charge a 12b-1 fee and there is no Platform Fee for the Guided Income Solutions. See Servicing Fees Received by Custodians, including AssetMark Trust Company and Share Class Use in Fees and Compensation section, and the Fees & Minimum table at the back of this Disclosure Brochure. Each GuidePath Fund is managed to a stated investment objective as outlined in the Fund prospectus. Please refer to the Fund prospectus for more information, including any fees. The phrase “risk management protection” or simply “protection” should in no way be regarded as a guarantee against losses or even the mitigation of losses. Similarly, the word “participation” should in no way imply positive gains during periods of rising equity markets. The primary goal of the Dynamic Hedging feature is to provide some degree of mitigation of losses during sustained and severe declines in the broad- based equity markets, (and participation in gains during rising markets), but this is not a guarantee. AAM may or may not be successful in achieving the investment objective in any individual calendar year. The Dynamic Hedging feature should not be expected to mitigate losses occurring over short periods of time, nor should the Dynamic Hedging feature be expected to mitigate losses occurring from market declines that are relatively small or minor. For each Guided Income Solutions portfolio, AssetMark will allocate assets across three “buckets” whereby each bucket will be invested in a specific GuidePath Fund. The allocation across the buckets shift in conjunction with changes in the remaining time horizon, long- term market conditions, or other factors as deemed appropriated by AssetMark. Limiting Circumstances for Participation in Upside Equity Market Movements Another goal of Dynamic Hedging is to allow growth in the equity portion of a Client’s Account to increase the value of the overall Account. This is the “participation” portion of Savos’ “participation and protection” objective. Clients who elect Dynamic Hedging should know that the “cost” of the protection is likely to reduce returns when equity markets are increasing in value. For Accounts established at Custodian AssetMark Trust, the Financial Advisor can also elect to have the Client’s regular income stream adjusted for inflation. For the inflation adjusted models, on an annual basis, AssetMark will adjust the expected income distribution to reflect any increase in the U.S. rate of inflation. The inflation adjustment will begin at the beginning in the year following the Client’s participation in the Guided Income Solution Strategy. The annual adjustment will be based on AssetMark’s long-term inflation projection. Clients invested in the Guided Income Solutions should understand that their regular income stream can include principal and the principal balance of the Account can be depleted prior to the portfolio’s target end-date and therefore, distributions can end earlier than expected. Income distributions refers to cash distributions of earnings and/or principal. This drag would generally result because (i) the hedging vehicles used by AAM to implement the Dynamic Hedging feature moves inversely to equity markets, and (ii) the cost of the hedging vehicles used in the Dynamic Hedging feature are more likely to increase in declining equity market conditions. As a result, the level of participation and protection of a Client’s Account will vary depending upon market environment and the specific path of market returns. Dynamic Hedging can fall while the overall equity market is rising in certain time intervals, and will fall more than the overall equity markets in certain intervals. Referral Disclosure BrochureThis must remain with the Client Page 33 of 37 EXHIBIT C – PROPRIETARY MUTUAL FUND SOLUTIONS - CONFLICTS OF INTEREST DISCLOSURES MUTUAL FUNDS FEES RETAINED BY ASSETMARK The Accounts of Clients who select a GPS Fund Strategy will be invested in mutual funds advised by AssetMark. This creates a conflict because AssetMark receives Management Fees and Administrative Service Fees from these mutual funds, the Management Fees retained by AssetMark can differ and AssetMark will determine the allocations of Account value among these funds. AssetMark addresses this conflict by providing additional information below regarding the maximum fees AssetMark can retain. The maximum net Management Fee retained by AssetMark from a fund in GPS Fund Strategies is 0.40% of average daily net assets, and the maximum Administrative Service Fee paid AssetMark is 0.25%. Therefore, the maximum fee that AssetMark can retain from a mutual fund in a GPS Funds Strategies account is 0.65% of average daily net assets. AssetMark is also compensated by the Platform Fee charged for the GPS Fund Strategies, which is less than that charged for strategies with third party funds and ranges from 0.25% to 0.10% (depending upon Account assets, with the first $250,000 of Account value always being charged the highest 0.25% fee). The Platform Fee for the GPS Fund Strategies does not include a charge for advisory (or management) services but pays for custodial, trading, administrative and other services. In selecting a GPS Fund Strategy, the Client agrees to the receipt by AssetMark of the maximum 0.65% Management Fee plus Administrative Fee (paid by the fund) plus the applicable Platform Fee (charged at the Account level) and that this fee is reasonable compensation to AssetMark. AssetMark’s management of a GPS Fund Strategy can result in internal fund fees to AssetMark lower than the 0.65% authorized by the Client. Listed below are the mutual funds advised by AssetMark in which AssetMark can invest GPS Fund Strategy accounts and the maximum fee that AssetMark can retain from each fund as a percentage of average daily net assets of the mutual funds. If a fund has a sub-adviser, the minimum that AssetMark can pay the sub-adviser is deducted in the amount shown as retained by AssetMark. AssetMark can waive part or all of its management fee, and AssetMark can also recoup previously waived fees and assumed expenses, but these possibilities are not considered in the below-reported maximum retained fees. Some funds invest in shares of other funds; the fees paid these underlying funds are not included in the below-reported fees. The Client should refer to the funds’ prospectuses and other shareholder materials for information, including fees, regarding the funds. Additional mutual funds can be added to those that receive allocations. If an added fund results in a fee greater than 0.65% being paid to AssetMark, the Client will be given notice. MUTUAL FUNDS MAXIMUM FEES RETAINED BY ASSETMARK GuidePath Growth Allocation Fund 0.50% GuidePath Conservative Allocation Fund 0.50% GuidePath Tactical Allocation Fund 0.60% GuidePath Absolute Return Fund 0.60% GuidePath Managed Futures Strategy Fund 0.60% GuidePath Flexible Income Allocation Fund 0.50% GuidePath Multi-Asset Income Allocation Fund 0.60% GuideMark Large Cap Core 0.60% GuideMark World ex-US 0.60% Since the amount that AssetMark is paid by each mutual fund varies, changes by AssetMark to the allocations of mutual funds in Client Accounts can change what AssetMark receives in fees from the funds. GPS Fund Strategies include strategies with “Accumulation of Wealth,” “Distribution of Wealth” and “Focused” investment objectives. AssetMark anticipates making periodic changes to allocations among mutual funds in the Accumulation of Wealth and Distribution of Wealth investment objectives but does not anticipate any material allocation changes for Accounts invested in the Focused investment objectives. Listed below, for each Profile in each Strategy offered in the Accumulation of Wealth and Distribution of Wealth investment objectives is the maximum retained fee and the range of retained fees that AssetMark can receive assuming the possible asset allocations that AssetMark anticipates for that Profile and objective. For the strategies in the Focused investment objectives, only the maximum possible retained fee is listed because AssetMark anticipates that a change, if any, in the allocations will not materially affect the maximum fee. If an allocation change or the addition of a new mutual fund results in a maximum retained fee for a Strategy greater than that listed below, the Client will be given notice. The Maximum Net Revenue for the GuidePath Absolute Return Fund reflects a fee waiver currently in place for the Fund. GPS FUND STRATEGIES MAX NET REVENUE RANGE OF NET REVENUE GPS ACCUMULATION OF WEALTH 1 0.59% 0.54% - 0.59% 2 0.59% 0.54% - 0.59% 3 0.58% 0.53% - 0.58% 4 0.57% 0.52% - 0.57% 5 0.58% 0.53% - 0.58% Referral Disclosure BrochureThis must remain with the Client Page 34 of 37 GPS DISTRIBUTION OF WEALTH 2 0.61% 0.56% - 0.61% 3 0.64% 0.59% - 0.64% 4 0.64% 0.59% - 0.64% GPS FUND STRATEGIES MAX NET REVENUE GPS FUND STRATEGIES MAX NET REVENUE GPS ACCUMULATION - NO ALTERNATIVE EXPOSURE GPS FOCUSED CORE MARKETS 1 0.54% 1 0.50% 2 0.54% 2 0.49% 3 0.53% 3 0.49% 4 0.52% 4 0.49% 5 0.53% 5 0.49% GPS DISTRIBUTION, NO ALTERNATIVE EXPOSURE GPS FOCUSED LOW VOLATILITY 2 0.57% 1 0.54% 3 0.60% GPS FOCUSED TACTICAL 4 0.60% 5 0.59% GPS FOCUSED TACTICAL GPS FOCUSED MULTI-ASSET INCOME 2 0.55% 2 0.55% 3 0.56% 3 0.59% 4 0.58% 4 0.56% Mutual funds advised by AAM are available only through the AssetMark Platform and are dependent on the continued vitality of the AssetMark Platform for their commercial viability. GPS SELECT Part of Platform Fee is credited to Account AAM serves as investment manager for GPS Select and will allocate account value across investment Strategies, and among Strategists and investment managers within those investment Strategies. Included within these investment options are strategies managed by AAM and the investment options include allocations to mutual funds advised by AAM. AssetMark pays fees to various strategists and investment managers that it allocates account value to but does not pay such fees to third parties when it allocates account value to Strategies it manages. Further, AssetMark receives compensation from mutual funds they advise. For GPS Select, the Platform Fee is 0.95%. In selecting GPS Select, the Client agrees to the receipt by AssetMark of this 0.95% fee and that this fee is reasonable compensation to AssetMark. However, an amount of 0.30% is credited back to the Account, resulting in a net Platform Fee of 0.65% for assets invested in GPS Select. The purpose of the 0.30% credit is to ensure that, regardless of the allocation decisions made by AAM, the Client will receive a Platform Fee credit that is at least as much as any additional compensation AssetMark might retain due to the allocations that AssetMark is permitted to make pursuant to the GPS Select investment guidelines. MARKET BLEND MUTUAL FUND STRATEGIES Mutual Fund Fees retained by AssetMark The Accounts of Clients who select a GuideMark Market Blend Mutual Fund Strategy will be invested in Proprietary Funds advised by AssetMark. AssetMark will receive Management Fees and Administrative Service Fees from these funds, the Management Fees retained by AssetMark can differ and AssetMark will determine the allocations of Account value among these funds. AssetMark addresses this conflict by providing additional information below regarding the maximum fees AssetMark can retain. The maximum net Management Fee retained by AssetMark from a fund in a GuideMark Market Blend Mutual Fund Strategy is 0.45% of average daily net assets, and the maximum Administrative Service Fee paid to AssetMark is 0.25%. Therefore, the maximum fee that AssetMark can receive from a mutual fund in a GuideMark Market Blend Mutual Fund Strategy is 0.70% of average daily net assets. AssetMark is also compensated by the Platform Fee charged for the GPS Fund Strategies, which is less than that charged for strategies with third party funds and ranges from 0.25% to 0.10% (depending upon Account assets, with the first $250,000 of Account value always being charged the highest 0.25% fee). The Platform Fee for the GPS Fund Strategies does not include a charge for advisory (or management) services but pays for custodial, trading, administrative and other services. Referral Disclosure BrochureThis must remain with the Client Page 35 of 37 In selecting a GuideMark Market Blend Mutual Fund Strategy, the Client agrees to the receipt by AssetMark of the maximum 0.70% Management Fee plus Administrative Fee (paid by the fund) plus the applicable Platform Fee (charged at the account level) and that this fee is reasonable compensation to AssetMark. AAM’s management of a GuideMark Market Blend Mutual Fund Strategy can result in internal fund fees to AssetMark lower than the 0.70% authorized by the Client. Listed below are the Proprietary Funds in which AssetMark is permitted to invest GuideMark Market Blend Mutual Fund accounts and the maximum fee that AssetMark can retain from each fund as a percentage of average daily net assets of the mutual funds. If a fund has a sub-adviser, the minimum that AssetMark can pay the sub-adviser is deducted in the amount shown as retained by AssetMark. AssetMark can waive part or all of its management fee, and AssetMark can also recoup previously waived fees and assumed expenses, but these possibilities are not considered in the below-reported maximum retained fees. The Client should refer to the funds’ prospectuses and other shareholder materials for information, including fees, regarding the Funds. Mutual funds can be added to those that receive allocations. If an added fund results in a fee greater than 0.70% being paid to AssetMark, the Client will be given notice. MUTUAL FUNDS MAXIMUM FEES RETAINED BY ASSETMARK GuideMark Large Cap Core 0.60% GuideMark Small/Mid Cap Core 0.70% GuideMark Core Fixed Income 0.60% GuideMark Emerging Markets 0.61% GuideMark World ex-US Service 0.60% Since the amount that AssetMark is paid by each Proprietary Fund, changes by AssetMark to the allocations of Proprietary Fund in Client Accounts can change what AssetMark receives in fees from the funds. Listed below, for each Profile in each Strategy offered in Market Blend Mutual Fund Strategies, is the maximum retained fee that AssetMark can receive, assuming the possible asset allocations that AssetMark anticipates for that Profile and objective. If an allocation change or the addition of a new Proprietary Fund results in a maximum retained fee for a Strategy greater than that listed below, the Client will be given notice. MARKET BLEND STRATEGIES MAX NET REVENUE GLOBAL GUIDEMARK MARKET BLEND 2 0.59% 3 0.60% 5 0.60% 6 0.61% US GUIDEMARK MARKET BLEND 2 0.60% 3 0.61% 5 0.61% 6 0.62% Additionally, if AssetMark Trust is chosen as Custodian, AssetMark Trust will be paid Shareholder Service Fees. The third-party Platform Custodians (Custodians other than AssetMark Trust) also receive service fee payments from the mutual funds in the Market Blend Mutual Fund Strategies. GUIDED INCOME SOLUTIONS The Accounts of Clients who select a Guided Income Solution will be invested in the following Proprietary Funds. MUTUAL FUNDS MANAGEMENT FEE BY ASSETMARK GuidePath Conservative Income Fund 0.35% GuidePath Income Fund 0.45% GuidePath Growth and Income Fund 0.45% AssetMark will receive Management Fees and a 0.25% Administrative Service Fee from these mutual funds. There is no Platform Fee for the Guided Income Solutions. Referral Disclosure BrochureThis must remain with the Client Page 36 of 37 i t s e h g h s F M M 1 $ % 0 9 . 0 % 5 9 . 0 % 9 9 . 0 % 9 9 . 0 % 4 0 1. % 0 1 1. % 0 1 1. l a n o i t a N y t i C e l a d h c o R e h t : ) y l n o i l a u d i v i d n I % 5 2 . 0 % 5 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 0 0 0 , 0 1 $ 8 . s e r u s o l c s i d t n a t r o p m i . d e t s s e v e c e r i l l e d o M r o f r o m o t s u C % 5 0 . 0 M 1 $ - K 0 0 5 $ % 5 7 . 0 % 5 8 . 0 % 0 9 . 0 % 4 9 . 0 % 9 9 . 0 % 5 0 1. % 5 0 1. m o t s u C s a s e e f i i m u m n m r o s i v d A e h t t n e m e g a n a m e g a p t x e n e e s e e f m o t s u C C B I C 3 s o i l o f t r o P M 1 $ % 0 8 . 0 % 0 9 . 0 % 5 9 . 0 % 5 9 . 0 % 0 0 1. % 0 0 1. % 0 0 1. 4 p e e w S l a i d o t s u C s F M y t r a P - d r i h T l a u d i v i d n I / s t c c A e v i t a r t s i n i m d A 3 s e i t i r u c e S l a r e n e G % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 0 0 0 , 0 1 $ d e c u d e r e e F l r e d n u i e s a e l P r i i l 8 s t n u o c c A d e g a n a M y l l a u d i v i d n I r a i l l l e v e c e r a B m a m u m n m o d i l l i i m o t s u C c i r t e m a r a P 3 . t r o P m o t s u C a t n e m e p p u S W K 0 5 7 $ - K 0 5 2 $ % 0 5 . 0 % 0 6 . 0 % 0 6 . 0 % 0 6 . 0 % 5 6 . 0 % 5 6 . 0 % 5 6 . 0 l a n o s r e P s o i l o f t r o P % 5 7 . 0 % 5 7 . 0 % 5 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 6 . 0 0 0 0 , 0 5 1 $ t s r fi l a u n n a r e d n u e l b a l i a v a ( s o i l t n o p k a e r b e h T . : s e c i 0 0 1 $ k s i R S U d e l l o r t n o C % 0 9 . 0 % 5 7 . 0 % 0 7 . 0 % 5 6 . 0 % 5 6 . 0 % 5 6 . 0 % 5 5 . 0 0 0 0 , 5 2 $ l h c a e S P G m o t s u C t c e e S % 0 1 . 0 % 0 2 . 0 % 0 3 . 0 % 0 4 . 0 S P G m o t s u C t c e l e S % 5 6 . 0 % 5 6 . 0 % 0 6 . 0 % 5 5 . 0 % 5 4 . 0 % 0 4 . 0 % 5 3 . 0 0 0 0 , 0 5 2 $ d e r e i t t n u o c c a 0 0 0 , 0 1 $ a d n a % 9 2 . 0 - r e v o P M P / S M G % 0 0 1. % 0 8 . 0 % 5 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 6 . 0 0 0 0 , 5 2 $ % 5 2 a d n a % 0 1 . . 0 e r a e v o b a 0 o f t r o P d e g a n a M : s t e s s a t c e l e S S P G % 5 6 . 0 % 5 6 . 0 % 0 6 . 0 % 5 5 . 0 % 5 4 . 0 % 0 4 . 0 % 5 3 . 0 K 0 0 1 $ - K 0 5 $ : e e f r o s i t a l l s o v a S n o i t a v r e s e r P % 5 7 . 0 % 0 5 . 0 % 0 5 . 0 % 5 4 . 0 % 5 4 . 0 % 0 4 . 0 % 0 3 . 0 0 0 0 , 5 2 $ s e e f e h T d n a e e f v d A e e F t a F v r e S t n e m e g a n a M x a T F R T I F k r a l C % 5 5 . 0 % 5 5 . 0 % 0 5 . 0 % 5 4 . 0 % 5 3 . 0 % 0 3 . 0 % 5 2 . 0 0 0 0 , 0 5 2 $ P M P d n u F S P G s e i g e t a r t S % 5 2 . 0 % 5 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 0 0 0 , 0 1 $ i e e F l d e l l o r t n o C k s i R S U s o v a S d e x i F e v i t c A 3 e m o c n I % 0 2 . 0 % 0 3 . 0 % 0 3 . 0 % 5 2 . 0 % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 K 0 5 2 $ - K 5 2 $ 3 e m o c n I d e x i F e v i t c A s o v a S , i , t h g i r W s r o s i v d A d n E t s e W l , 8 e m o c n I d e x i F d e r e d d a L y e s r o D S M G s o v a S , x e l u J t n o m u a e B a t n e m e p p u S s o i l o f t r o P d e d i u G e m o c n I d e d i u G s n o i t u l o S % 0 % 0 % 0 % 0 % 0 % 0 % 0 0 0 0 , 0 5 $ — s m u m n M l a t i p a C k r a l C 2 F M F M l e e F % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 % 5 1 . 0 % 5 1 . 0 % 5 1 . 0 % 5 1 . 0 0 0 0 , 5 2 $ y r a t e i r p o r P 5 3 e m o c n I d e x i F n e e v u N % 5 3 % 0 3 % 8 2 % 5 2 % 0 2 % 0 1 r e g a n a M , i n u M e t a i d e m r e t n , F T E y t r a P - d r i h T a n o i t u t i t s n I % 0 1 . 0 % 5 1 . 0 % 0 2 . 0 % 5 2 . 0 % 0 5 . 0 % 0 6 . 0 , F T E y t r a P - d r i h T l a n o i t u t i t s n I % 0 5 . 0 . 0 . 0 . 0 . 0 . 0 . 0 0 0 0 , 5 2 $ l I d e r e d d a L , , p u o r G l l a t i . s t n e i l , ) e e r F - x a T d n a x a T s t n u o c c A d e g a n a M y l l a u d i v i d n I y t r a P - d r i h T 3 e m o c n I d e x i F % 7 2 . 0 % 7 2 . 0 % 7 2 . 0 % 2 2 . 0 % 2 2 . 0 % 2 2 . 0 % 2 2 . 0 K 0 5 2 $ - K 5 2 1 $ a t n e m e p p u S p a C ( c F T E y r a t e i r p o r P F M % 5 0 . 0 % 5 1 . 0 % 5 4 . 0 F T E y r a t e i r p o r P 5 F M % 0 4 . 0 % 5 3 . 0 % 0 3 . 0 % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 0 0 0 , 5 2 $ i , e m o c n I y r o s v d a n a g r o M P J s A M S % 0 7 . 0 % 0 7 . 0 % 7 6 . 0 % 4 6 . 0 % 0 6 . 0 % 5 5 . 0 % 0 5 . 0 K 0 0 1 $ - K 0 5 $ s A M S % 5 0 . 0 % 0 1 . 0 h t i d e x i F , t n e m t s e v n I ) s A M S ( G S E 6 1 k r a M e d i u G % 5 2 . 0 % 5 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 0 0 0 , 0 1 $ , 2 r e d l i , s t l A c i t s i n u t r o p p O w e s u , I n w o r B , F T E ( l r e g r e b u e N , A M d e t a r e d e F c i t a m e h T k c E n a V k c E n a V i n a g o L 2 s e u l a V , k c o R k c a l B r o s v d a , p u o r G l e e F e e F ( k c o R k c a l B n o t e p m e T n i l k n a r F l l i t e e r t S e t a t S u B t e s s A k r a M t e s s A l a t i p a C t h g i r , a r e i F W i s r o s i v d A d n E t s e W l l i i , s e v i t a n r e t l A t s u r T t s r i F , e n i L e l b u o D a c n a n fi i i l , ) n o i t a c o l l , n i e t s n r e B e c n a i l l a t n e m e p p u S A , y r o s i v d A , s e m r e H , n a g r o M P J , d r o f t r a H , e g d E l a p i c n i r P , n a m r e B l a p i c n i r P , n a i d a c A l a n o s r e P k r a M t e s s A K 0 5 2 $ < K 0 0 5 $ - K 0 5 2 $ M 1 $ - K 0 0 5 $ M 2 $ - M 1 $ M 3 $ - M 2 $ M 5 $ - M 3 $ + M 5 $ m u m n M s e i g e t a r t S K 0 5 2 $ < a t n e m e p p u S s t n u o c c A d e g a n a M y l e t a r a p e S , x e l p m S a h p A , ) I F R r a t s g n i n r o M , e l b i x e l F l a b o l G A , s e m e h T p o T t s u r T t s r i F , n o i t p u r s i D r e i t n o r F w e N y e s r o D , x e l u J t n o m u a e B K 0 0 5 $ - K 0 5 2 $ M 1 $ - K 0 0 5 $ M 2 $ - M 1 $ M 3 $ - M 2 $ M 5 $ - M 3 $ + M 5 $ m u m n M 4 2 0 2 R E B M E C E D F O S A r o F & s e e F Referral Disclosure BrochureThis must remain with the Client  Page 37 of 37 . l O C M I P 9 s d n u F e n o t S l , . c n d e c n a h n E I f o e t a i l , e t i r i i l i f f a a u d v d n e n i L e l b u o D r e l l i h S , E P A C r e g r e b u e N n a m r e B W t u P S D N E R T d e g a n a M , s e r u t u F d e fi i s r e v i D e g d i R s e v i t a n r e t l A I a u t u M n a , , k r a M t e s s A I f o d n a A R N F p u o r G F T E k r a l C , e m o c n I , e m o c n I e v e e s h c a e o t n o i t a c o e v i l l i i i 3 e m o c n l a t i p a C e t a i d e m r e t n I , i n u M l a t i p a C e l b a x a T e e r F - x a T d e x i F , n e e v u N e v i t c A s o v a S d e x i F s o v a S s r e d d a L i t c A d e x F I r e b m e m n o s v d a , e r u s o l c s i D e h t o t C L L 5 , 3 e m o c n y r a t e I r e f e r d e x , t n e m e g a n a M i . s d n u f i l d n o B s o v a S s r e d d a L i r p o r P d e r e d d a L F . s e c n a t s n i — s t n u o c c A d e g a n a M y l e m o s l l n i , s n o i t u o s 3 e m o c n 8 e m o c n I I l i l t e s s A k r a M t e s s A , M T e g a r e k o r B k r a M t e s s A y b a u d v i d n i c i r t e m a r a P y t r a P - d r i h T d e r e d d a L d e x i F I d e x i F a u t u m y r a t e i r p o r p i l . s e s s a c e r a h s i l i i t n e m t s e v n e e F m r o f t a P e h t i d e t u b i r t s d m a i l l i , e g d E a r e i F i W n i l k n a r F , p u o r G e r a i . e d a r t l e r u s o , n i e t s n r e B e c n a i l l ) s A M S , n a i d a c A A , k c o R k c a l B , y r o s i v d A n w o r B l a t i p a C d e t a r e d e F , s e m r e H , l a t i p a C , n o t e l p m e T , d r o f t r a H , n a g r o M P J , n a g o L , r a t s g n i n r o M r e g r e b u e N , n a m r e B , l a p i c n i r P l a p i c n i r P , k c E n a V r i a l B y l e t a r a p e S d e g a n a M s t n u o c c A ( . s e n a p m o c i l c s i s ’ k r a M t e s s A e s u t a h t r e p 0 2 $ y d e t a . s r o s v d a l l i s u o i r a v e h t . n o s s m m o C e g n a h c x E d n a i i i s e v a w k r a M t e s s A i l m a i l l i d / o f n i / r o f i l i f f a n u a t e r d n a e r a h s A g n d u c n a c p y t W i n a t r e c s e g e t a r t s , , h t r o W o t d n a e r a n o s d n u F ® h t a P e d u G d n a m o c . s e i t i r u c e S y l l a u d i v i d n l k r a M t e s s A h g i H m o t s u C t e N l a t i p a C k r a l C d e z i l a n o s r e P A M U r i a l B m o t s u C I d e g a n a M 8 s t n u o c c A . l e b a . s e e f l i i l a v a e t a r a p e s l , y r u s a e r T % 0 0 1 S U e h t n i i l i e s e h T r o f s e r u s o c s d e r a h t i s o ® k r a M e d u G i l e m o c n I e r a . n r u t e R i i i s t s i g e t a r t s l l ) . s t n u o c c A y g e t a r t S e p i t l u M d n a t s e r e t n n a g r o M P J A k r a l C s u l p ( d e x i F l a t o T s o v a S d n a A M U ) s e i g e t a r t s s e i g e t a r t S e h t e l b a t e l b a l i a v a S P G m o t s u C t c e l e S S P G m o t s u C t c e l e S d e d u G o f t r o P i . t n u o c c a i f o s d n u F ) e e F n o i t c a s n a r T o N s t s g e t a r t s s e s n e p x e d n a , s e e f . s e g e t a r t s d n a e h t w d e r e t s g e r , s d n u F s t c o t ( F T N i l d e x i F , i d n u F - T i l f n o c , d r a d n a t S r e s v d a e b a c . d e v r e s e r d n E t s e W s e d o m S B O k r a M t e s s A O C M I P , , t h g i r i l y t r a p - d r i h t w e N t n e m t s e v n i i W , t n o m u a e B k r a m t e s s a w w w o t o g e s a e l , x e l p m S a h p l A c i t s i n u t r o p p O - i t l u M A T , p p a i 2 F M d n a l a b o l G p , I s t h g i r n a c i r e m A n o , k c E n a V , s m u m n m e b l l n o t g n i s n e K l t n a t r o p m , n r u t e R e t u l o s b A f o d e s i r p m o c , ) s t l A / A y e s r o D i , w , ) n o i t a c o l l y t n e m t s e v n 6 2 0 2 / 1 1 P X E G S E n e e v u N i i | y a m r o f . c n I i n a G S E A T , I F R k r a M t e s s A y b C l i r a m , x e l u J , ) I s . s t n e d e v a w s i k r a M t e s s A l i i i l l a n o i t u t i t s n 4 2 0 2 y r a t e i r p o r p s ’ m , s e e f F, T E y t r a P - d r i h T I / G S E , F T E , e v i s s a P / e v i t c A i c , s d n u F n a c i r e m A A M ( k c o R k c a l B , s t l A r e g a n a M R T I F k r a l C t s u r T t s r i F , e n i L e l b u o D w o L t s u r T t s r i F , s e v i t a n r e t l A t s r i F , e m o c n I d e x i F n o i t a r u D t s r i F , e r o C k s i R c i g e t a r t S t s u r T t s u r T t s r i F , s e m e h T p o T t s u r T r e f f u B y t i u q E S U d e r e d d a L t s e V , n o t e l p m e T n i l k n a r F , l e d o M F T E ( n a g r o M P J , e l b i x e l F l a b o l G A M r a t s g n i n r o M , e m o c n I d e g a n a M ( A e m o c n I , r e i t n o r F , t e e r t S e t a t S s r o s i v d A k c o R k c a B g n d u c n i . c n . c n 1 1 e e f I I , . s d n u f l i r p e r a | l l i , t n e m u c o d s i d e t c e e s r i f e h t . s d n u F ® k r a M e d u G e h t y a w a . t i b h x E o t e b a t n u o c c A d e g a n a M y i . r o s i v d a l a i c n a n fi r u o y t c a t n o c e s a e l p s h T i h t l i l l ( o t t e k r a M d n u f , a v a . k r a M t e s s A y b d e r e f f o e s o h t l e d a r t y r o s v d a i i r e f e R i 0 5 3 $ s e d u c n o t , k r a M t e s s A i , k r a M t e s s A , k r a M t e s s A 4 2 0 2 © 1 9 9 2 1 7 8 6 f o n o e r a : i a e h t n o d e s a b d e t h g e w d n a d e t c e e s t s g e t a r t s h c a e r o f e u d e h c s e e f y g e t a r t s - e g n s e v o b a e h t n o d e s a b e r a t n u o c c a A S M n a r o f d e g r a h c s e e f e h T e m o c n I l a n o s r e P h t i k r a M t e s s A a u d v d n r e s v d a s o i l o f t r o P I : ) i k r a M t e s s A l k r a M t e s s A r e f e r 5 F M F, T E y r a t e F T E i l g n d u c n i s r e v i s d n u F i A S M ( l w e s u s e g e t a r t s e s e h t n h t i s e p y t , 2 r e d l i u B t e s s A k r a M t e s s A i r p o r P d n e l B M S r e d l i u B h t l a e W k r a M t e s s A , r e d l i u B s n o i s n e m D t e k r a M , s o i l o f t r o P , s o i l o f t r o P S F E / A F D S B O k r a M t e s s A , 2 s e u l a V t e k r a m y e n o m = e m o c n - l , s e e f i I t n e m t s e v n t n u o c c a t u o b a n o i t a m r o f n i i : s n o i t u o S d n u F a u t u M l l t n e r r u c l i e h t a u t u m ® k r a M e d u G s n a t n o c . c n r o s v d a d e x F I , y p o c a e v i e c e r o T s n o i t u o s i l i i r o p e e w s i i i 5 4 4 2 0 2 5 4 9 A C l e e F m r o f t a P m u m n M w d e s u s d n u F i a u d v d n I l l l ® k r a M e d i u G y g e t a r t s l i e t e l p m o c t s o m e h t i i d n a m o t s u C k r a M t e s s A y r a t e i r p o r P d e s a b - n o i t c a s n a r T a d o t s u C r e h t O , k r a M t e s s A t e e r t S t n a r G 5 5 6 1 r o o F h t 0 1 , d r o c n o C 5 4 3 5 - 4 6 6 - 0 0 8 a u n n A a u t u M s h T , 7 d n e l B t e k r a M s d n u F ® k r a M e d i u G , 7 d n e l B t e k r a M s e i g e t a r t S 6 , 1 k r a M e d u G , 7 r e i t n o r F w e N l a b o l G ® k r a M e d i u G S U l a u d i v i d n I , s d n u F ® h t a P e d i u G Y R O G E T A C Y B S M R I F T N E M T S E V N . 8 . 9 t n u o c c A y g e t a r t S e p i t l u M a u t u M y r a t e i r p o r P I r o F . e r u h c o r B a c n a n fi r o F . 1 . 2 . 3 . 4 . 5 . 6 r o F . 7 Referral Disclosure BrochureThis must remain with the Client 

EFFECTIVE MARCH 26, 2025 Efficient Edge Disclosure Brochure Form ADV – Appendix 1 For Efficient Edge Advisory Services SEC File Number − 801 56323 IA Firm CRD Number - 109018 ITEM 1 – COVER PAGE This AssetMark Disclosure Brochure provides information about the qualifications and business practices of AssetMark, Inc. (“AssetMark”). If you have any questions about the contents of this Brochure, please contact AssetMark using the above information. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. AssetMark is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. AssetMark, Inc. Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 800-664-5345 assetmark.com Additional information about AssetMark also is available on the SEC’s website at www.adviserinfo.sec.gov. R304_AssetMarkADVEffEdge_2025_03  AssetMark Efficient Edge Disclosure Brochure Page ii ITEM 2 – MATERIAL CHANGES This section provides a summary of material changes that were made to this brochure since the last update. It includes changes to AssetMark’s Platform and is intended to help Clients determine if they want to review this brochure in its entirety, or contact their Financial Advisor with questions about the changes. AssetMark may make interim updates to this brochure throughout the year. However, you will receive notice of any material changes, which must also be filed with the SEC. To request a copy of the most recent disclosure brochure, write to: AssetMark, Inc. Attention: Adviser Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 800-664-5345 assetmark.com advisorcompliance@assetmark.com There have been no material changes since the last Form ADV Part 2A update in September 2024. This must remain with the Client  Page 1 of 7 ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I ITEM 2 – MATERIAL CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II ITEM 3 – TABLE OF CONTENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ITEM 4 – SERVICES, FEES AND COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 9 – ADDITIONAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 AssetMark Efficient Edge Disclosure BrochureThis must remain with the Client Page 2 of 7 ITEM 4 – SERVICES, FEES AND COMPENSATION you do not wish to accept the changes to your selected Model, you will be given alternative options as described in your Variable Contract. You should consult with your registered representative and/or your financial adviser on your decision regarding which Model to select. Your registered representative can assist you in determining which Model will be best suited to your financial needs, investment time horizon and willingness to accept risk. AssetMark does not bear this responsibility. AssetMark, Inc. (“AssetMark”) is an investment adviser registered with the U.S. Securities and Exchange Commission providing various investment advisory services since 1999. AssetMark Asset Management (AAM) is responsible for AssetMark ‘s proprietary investment strategies. AssetMark is wholly owned subsidiary of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc. is an independent, U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. ASSETMARK’S EFFICIENT EDGE ADVISORY SERVICE OVERVIEW OF ASSETMARK’S EFFICIENT EDGE ADVISORY SERVICE INTRODUCTION Asset allocation is an investment strategy for distributing assets among asset classes (and, where applicable, amongst sub-asset classes) to help attain an investment objective. One of the theories supporting an asset allocation strategy is that diversification among asset and sub- asset classes can help reduce volatility over the long term. This disclosure brochure contains information about AssetMark’s investment strategies and the conditions and procedures applicable to the Efficient Edge advisory service, some of which is subject to change. AssetMark’s Efficient Edge service offers five Portfolio-Specific Models, each based on different investor profiles and investment objectives. In these five Portfolio-Specific Models, AssetMark analyzes the set of mutual fund portfolios currently made available for use in the Portfolio-Specific Models (the “Available Portfolios”). The Efficient Edge Advisory Service (“Efficient Edge”) is offered by AssetMark exclusively to owners of variable annuity contracts (“Variable Contracts”) issued by Genworth Life and Annuity Insurance Company (“GLAIC”) and Genworth Life Insurance Company of New York (“GLICNY”) (collectively, the “Insurance Companies,” each an “Insurance Company”). Efficient Edge is a service through which owners of Variable Contracts may have the value in their Variable Contract subaccounts allocated pursuant to the investment objective, or “Model,” they select. There is no separate, additional charge to Variable Contract owners for the Efficient Edge service. The set of Available Portfolios is a list of open-end registered mutual funds that have been selected by the Insurance Companies for use by the Efficient Edge service in the development of the Portfolio-Specific Models. The Insurance Companies reserve the right to adjust the list of Available Portfolios from time to time. While AssetMark does not participate in the determination of the list of Available Portfolios, AssetMark does, as part of its Efficient Edge service, perform an investment analysis of each fund on the list of Available Portfolios, to determine which funds, from the available universe of funds, will receive allocations within each Portfolio-Specific Model. AssetMark serves as the investment adviser solely for the purposes of providing asset allocation and fund selection recommendations on the Portfolio-Specific Models (except for the Build Your Own Asset Allocation Model) and for making periodic updates to the Portfolio-Specific Models. When Portfolio-Specific Models are updated, the Insurance Companies will provide written notice of the updates to the Models at least 30 days in advance of the effective date of the updates. If you wish to accept the changes to your selected Model, you will not need to take any action. If PORTFOLIO-SPECIFIC MODELS MODEL A CONSERVATIVE MODEL C MODERATE MODEL E AGGRESSIVE MODEL B MODERATELY CONSERVATIVE MODEL D MODERATELY AGGRESSIVE I S E L F O R P R O T S E V N I Investor is willing to accept a high level of risk has a long term (more than 15 years) investment time horizon and has the temperament to ride out market swings. Investor is willing to accept a low level of risk, has a short term (less than five years) invest- ment time horizon and is looking for an investment that is relatively stable in value. Investor is willing to accept a moderate to high level of risk, has a long term (15 to 20 years) investment time horizon and is looking for a growth oriented investment. Investor is willing to accept a low to moderate level of risk, has a moderately short term (less than ten years) investment time horizon and is looking for an investment to keep pace with inflation. Investor is willing to accept a moderate level of risk, has a moderately long term (10 to 20 years) investment time horizon and is looking for an investment with the opportunity for long term moderate growth. I Growth of capital. Target allocation mix is 100% equities. Growth and current income. Target allocation mix is 40% equities and 60% fixed income. T N E M T S E V N S High level of current E V T C E J B O I income with preservation of capital. Target allocation mix is 20% equities and 80% fixed income. Growth of capital with a low to moderate level of current income. Target allocation mix is 60% equities and 40% fixed income. Growth of capital but without the price swings of an all equity portfolio. Target allocation mix is 80% equities and 20% fixed income. AssetMark Efficient Edge Disclosure BrochureThis must remain with the Client  Page 3 of 7 THE PORTFOLIO-SPECIFIC MODELS The Efficient Edge Advisory Service develops Portfolio-Specific Models. The investor profiles and investment objectives consistent with these Portfolio-Specific Models are described below. There is no guarantee that these objectives will be met. You should review this information carefully before selecting the Portfolio-Specific Model that is most appropriate for you. CHOOSING A PORTFOLIO-SPECIFIC MODEL Asset allocation strategies reflect the theory that diversification among asset and sub-asset classes can help reduce volatility and potentially enhance returns over the long term. An asset class is a category of investments having similar characteristics, such as stocks and other equity investments, and bonds and other fixed income investments. There are also further divisions within asset classes, often referred to as “sub-asset classes,” such as divisions according to the size of the issuer (e.g., large cap, mid cap or small cap), the type of issuer (e.g., government, municipal or corporate), or the location of the issuer (e.g., domestic or foreign). If you are an Efficient Edge client, you must select one, and only one, Portfolio-Specific Model. All of the contract value in your Variable Contract and all purchase payments will be allocated in accordance with the Model you choose. In addition, you will not be able to invest or allocate any of your contract value in your Variable Contract or any of your purchase payments to the Insurance Company’s Guarantee Account (as defined in your Variable Contract). Each Portfolio-Specific Model managed by AssetMark under the Efficient Edge service offers a specific fixed allocation between the broad asset classes of equity and fixed income, appropriate for the level of risk, investment time horizon and investment objective specified appropriate to that model. The investment objective for each Model is listed on page two in the table entitled “Portfolio- Specific Models.” If you are a Variable Contract owner who has not elected one of the optional living benefit riders available under your Variable Contract, you may choose any one of the five available Portfolio-Specific Models. The Build Your Own Model, however, is not available to these contract owners. Please see your Variable Contract and its current prospectus for more information. To provide further diversification benefits beyond the broad asset class allocations, AssetMark conducts an optimization analysis to determine the appropriate allocations to sub-asset classes for each Portfolio-Specific Model. While generally AssetMark exercises its own broad discretion in allocating to sub-asset classes, AssetMark may be required by the Insurance Companies to limit certain levels of sub- asset class allocations in order to achieve a level of risk consistent with certain of the optional living benefit riders offered under the Insurance Companies’ Variable Contracts. If you are a Variable Contract owner who has elected one of the optional living benefit riders available under your Variable Contract, there may be certain limits, restrictions or conditions on the particular Models that are available to you. Please carefully review your Variable Contract and its current prospectus for more information. Please note that other specified investment options may be available with certain optional riders. Such investment options, however, are not a part of the Efficient Edge Advisory Service. You must determine which Portfolio-Specific Model is best for you given your financial situation and investment objectives. The Insurance Companies and AssetMark will not make this decision for you. After the asset class and sub-asset class exposures have been identified for each Portfolio-Specific Model, a determination is made as to how the Available Portfolios can be used to implement the asset and sub-asset class allocations. As mentioned previously, the Available Portfolios considered by AssetMark are all those currently available for contributions of new purchase payments by all Variable Contract owners. Part of the process used by AssetMark in determining the allocation to Portfolios in the Portfolio-Specific Models is an evaluation of the asset and/or sub-asset class(es) exposures given by each Portfolio in order to combine Portfolios to arrive at the desired asset and sub-asset class allocation levels. Your registered representative can help you determine which Model is best suited for your financial needs, investment time horizon and willingness to accept investment risk and they can assist you in completing the proper forms. You should periodically review with your registered representative your financial situation and investment objectives to determine if you should change Models or discontinue the Efficient Edge service. When consulting with your registered representative, you may use an investor profile questionnaire, available from the Insurance Company, which is designed to help you and your registered representative assess your financial needs, investment time horizon and willingness to accept investment risk. However, even if you use the investment profile questionnaire, it is still your decision as to which Model to select. Neither the Insurance Company nor AssetMark is responsible for this decision. AssetMark considers various factors in determining allocations to each Portfolio for each Portfolio-Specific Model, which includes historical style analysis and asset performance and multiple regression analysis, as well as qualitative assessments of a Portfolio’s portfolio manager and expected future market and economic conditions. Portfolios are not required to report their individual securities holdings directly to AssetMark; therefore, this analysis includes a review of the historic security holdings of the Portfolios, as described in public documents. Based on AssetMark’s analyses, Available Portfolios are evaluated based on their potential to optimize returns for each Model, given a particular level of risk tolerance. This evaluation could, in some cases, result in an allocation to a Portfolio in a Model based on its specific asset class, or sub-asset class, exposure or other specific optimization factors, even when another Available Portfolio has exhibited better historical investment performance. MANAGEMENT OF THE PORTFOLIO-SPECIFIC MODELS BY ASSETMARK AssetMark’s management of the Portfolio-Specific Models involves a multi-step process designed to optimize the allocations across the list of Available Portfolios for a given level of risk tolerance, in an effort to maximize expected returns and limit the effects of expected market volatility. In addition, in allocating to Portfolios for a Model, AssetMark can receive (but is not obligated to follow) recommendations from GLAIC and/or GLICNY. One exception is that the Insurance Companies have placed restrictions on the level of risk taken and/or asset class exposure for the Models, based in part on their availability in investment strategies required by Variable Contract optional living benefit riders. These recommendations are based on various factors, including AssetMark Efficient Edge Disclosure BrochureThis must remain with the Client Page 4 of 7 whether the investment adviser or distributor of a Portfolio pays GLAIC and/or GLICNY fees for certain administrative and other services provided to the Portfolio and whether Capital Brokerage Corporation, an affiliate of the Insurance Companies and the principal underwriter of the Variable Contracts, receives 12b-1 fees from the Portfolio. Additionally, AssetMark can develop more than one version of each Model, by allocating to some Portfolios in one version and allocating to other Portfolios in another version of the same Model, but you may be offered only one version of each Model because of the Portfolios available in your Variable Contract. The Portfolios available for allocation in versions of a Model may differ because of the distribution or marketing of the Variable Contracts or other factors. Additionally, sub-asset class allocations may differ slightly between versions of the same Model. AssetMark is also subject to competing interests that have the potential to influence its decision making with regard to the Efficient Edge Advisory Service. For example, GLAIC and GLICNY may believe that certain Portfolios could benefit from additional assets or could be harmed by redemptions. there may be certain limits, restrictions or conditions on the investment you can make and the benefits you receive under such rider may be adversely affected. Your options will be explained to you in your Variable Contract and its prospectus. Please read your Variable Contract and its prospectus for more information. If you have purchased an optional living benefit rider to your Variable Contract that requires your contract value and purchase payments to be invested in an “Investment Strategy,” you should consider how to invest your contract value and purchase payments in accordance with an appropriate level of risk. If you want to make changes to your allocations, you must do so pursuant to the terms of your Variable Contract. You may however, continue to receive written materials about any changes proposed to be made to the Models by AssetMark, and you may notify the Insurance Company in writing to and request allocation of your variable subaccounts in accordance with such materials and consistent with the terms of your Variable Contract. If you would later like to sign up again for the Efficient Edge Asset Allocation services you may do so by contacting your Insurance Company subject to the terms of your Variable Contract. Please use the contact information provided by the Insurance Company. If you are a prospective or new Efficient Edge client selecting a Model within the 30 day period prior to implementation of a change, you will be given information regarding composition of both the current Portfolio-Specific Model you have chosen as well as the proposed changes to your Model. MONTHLY AND AUTOMATIC REBALANCING OF ASSET ALLOCATIONS The Portfolios underlying the subaccounts can invest, depending upon their investment objective and the decisions by their investment managers, in securities issued by Genworth Financial, Inc. AssetMark will not have any role in determining whether a Portfolio should purchase or sell Genworth securities. AssetMark may allocate portions of the Asset Allocation Models to Portfolios which have held, hold or may hold Genworth securities. AssetMark’s decision to allocate a percentage of a Model to such a Portfolio will be based on the merits of investing in such a Portfolio and a determination that such an investment is appropriate for the Model. CHANGES TO PORTFOLIO-SPECIFIC MODELS On the monthly anniversary of your Variable Contract, the Insurance Company will rebalance your Variable Contract subaccounts and return their allocations to the percentages specified by your current Model, including the allocations you have made in a Build Your Own Model. This monthly rebalancing addresses increases and decreases of contract value in each subaccount due to subaccount performance. The first monthly rebalancing will occur at the first monthly anniversary following the Contract Date. AssetMark will periodically, generally annually, evaluate the Portfolio- Specific Models to assess whether the percentage allocations to each Portfolio should be changed to better optimize the potential return for the level of risk tolerance intended for each Model. AssetMark anticipates that such changes will be made annually, unless more frequent changes are determined by AssetMark to be necessary or appropriate. On any Valuation Day (as that term is defined in your Variable Contract) after any transaction involving a withdrawal, receipt of a purchase payment or a transfer of contract value, the Insurance Company will rebalance your Variable Contract subaccounts and return their allocations to the percentages specified by your current Model. This automatic rebalancing addresses increases and decreases in each subaccount due to subaccount transfers, withdrawals (including if taken from specific subaccounts you designated) and purchase payments (including if allocated to specific subaccounts you designated). If AssetMark determines that the allocations in your Model should be changed, your Insurance Company will send you written notice of the changes at least 30 days before they are to be implemented. Please carefully review these notices. If you want the Model changes implemented, you do not need to take any action. Your Insurance Company will allocate the contract value in your Variable Contract, and any subsequent purchase payments, in accordance with the updated Model received from AssetMark. POSSIBLE RESTRICTIONS AND CHARGES FOR TRANSFERS If you reject the Portfolio-Specific Model change, you have created a self-directed portfolio. You have terminated your advisory relationship with AssetMark, and AssetMark is no longer providing investment advice or allocations for your Variable Contract. Your contract value and purchase payments will not be allocated according to the updated Model. The Insurance Companies may have certain rules and procedures related to the manner, number and permissibility of, and possible charges or fees for, transfers among the subaccounts in your Variable Contract. AssetMark’s Efficient Edge Advisory service has been designed so that transfers among subaccounts caused 1) by AssetMark’s update of the Models and 2) by the monthly rebalancing of the value in your subaccounts will be permitted by the Insurance Companies without charge. However, restrictions and charges may still be imposed by the Insurance Companies. Please review your Variable Contract prospectus for more information. If you do not want to accept the changes to your selected Model, you may transfer the contract value allocated to the Model from the Model to another available investment option in your Variable Contract or, if you have elected certain of optional living benefit riders under your Variable Contract, you can notify the Insurance Company in writing that you have elected to reject the change. If you have elected one of the optional living benefit riders available under your Variable Contract, The Efficient Edge service has not been designed to allow excessive withdrawals and transfers by the Variable Contract owner, in addition to the transfers prompted by AssetMark and the monthly rebalancing, AssetMark Efficient Edge Disclosure BrochureThis must remain with the Client Page 5 of 7 OVERVIEW OF ASSETMARK’S OTHER ADVISORY SERVICES AssetMark provides a variety of investment advisory services to clients as described below. This brochure discusses only AssetMark’s Efficient Edge Advisory service in detail. and still ensure that subaccount reallocations do not conflict with the possible restrictions on frequent transfers or are exempt from possible transfer fees applicable to the subaccounts of the Variable Contracts. Please review your Variable Contract prospectus for more information. AssetMark and AssetMark’s advisory personnel do not have access to your Variable Contract and its subaccounts. Any changes to your subaccount allocations must be made by your Insurance Company. INVESTMENT RISKS Investment Supervisory Services - Referral Model AssetMark receives client referrals through representatives of broker dealer firms and investment advisory firms (these firms are referred to as “Financial Advisory Firms”). AssetMark manages each client Account according to the client’s selected Investment Solution under the terms of the AssetMark Investment Management Services Agreement. AssetMark provides investment supervisory services to clients as described in AssetMark’s “Referral Disclosure Brochure.” AssetMark offers the following advisory services or Investment Solutions under the Referral Model platform: Mutual Fund Accounts Although the Portfolio-Specific Models are designed to optimize returns given the various levels of risks, there is no assurance that a Model will not lose money or not experience volatility. Investment performance of contract value could be better or worse by participating in a Portfolio- Specific Model than if the owner had not participated. A Model may perform better or worse than any single Portfolio, subaccount or asset class or other combination of Portfolios, subaccounts or asset classes. Model performance is dependent upon the performance of the component Portfolios. Contract value will fluctuate, and when redeemed, may be worth more or less than the original cost. ETF Accounts Privately Managed Accounts (“PMA”), including: • Individually Managed (“IMA”) Accounts, • Manager Select Accounts (“MSA”), • Savos Preservation Strategy, A Portfolio-Specific Model may not perform as intended. Although the Models are intended to optimize returns given various levels of risk tolerance, Portfolio, market and asset class performance may differ in the future from the historical performance and assumptions upon which the Models are based, which could cause the Models to be ineffective or less effective in reducing volatility. • Savos Fixed Income Accounts, and Unified Managed Accounts, including: • Privately Managed Portfolios (“PMP”) Accounts • GMS Strategies (“GMS”) Accounts, and Periodic updating of the Portfolio-Specific Models can cause the underlying Portfolios to incur transactional expenses to raise cash for money flowing out of the Portfolios or to buy securities with money flowing into the Portfolios. These expenses can adversely affect performance of the related Portfolios and the Models. • Active Return Opportunities (“ARO”) Accounts Investment Supervisory Services - Mutual Funds In addition to providing the foregoing investment supervisory services, AssetMark is also the investment adviser for: 1) GuideMark Funds (no-load sub-advised mutual funds) 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund). Each Portfolio has one or more investment advisers and/or sub- advisers. The Portfolios are managed through a variety of investment strategies and will invest in various types of securities depending on their investment strategy, including but not limited to, U.S. and non- U.S. equity and fixed income securities. Each Portfolio’s prospectus includes more complete information, including a discussion of the Portfolio’s investment techniques and the risks associated with its investments. No assurance can be given that a Portfolio will achieve its investment objective. Owners should read each Portfolio prospectus carefully before investing. COMPENSATION AssetMark receives compensation from the Insurance Companies for providing the Efficient Edge Advisory Service. There are no additional fees paid by Variable Contract owners who are AssetMark Efficient Edge clients for the Efficient Edge service. Other Services - Advisor Model Platform In addition to the investment supervisory services offered clients directly by AssetMark upon referral by Financial Advisory Firms, the Platform Investment Solutions are offered by Financial Advisory Firms serving as the individual investment advisor for their clients with accounts invested through the Platform. For these Financial Advisory Firms and their clients, AssetMark serves as the Platform sponsor and provides the Financial Advisory Firms with administrative and consulting services. These services are described in more detail in the Platform Disclosure Brochure. AssetMark can offer other advisory services on an exception basis. However, Variable Contract owners do pay charges and fees in connection with their ownership of the Variable Contracts and these fees may increase in connection with use of the Efficient Edge Advisory service. For example, transfer fees may apply on re- allocations of value among subaccounts of the Variable Contract. Additionally, the Insurance Companies may receive fees for certain administrative and other services provided to the Portfolio, and CBC and the Insurance Companies may receive 12b-1 fees from Portfolios, including those advised by third parties. AssetMark faces a number of conflicts of interest between its duty to serve its Efficient Edge clients and the advisory services it provides to other individual clients, other insurance contract owners and its mutual fund shareholders. For example, AssetMark faces a conflict as to the timing of its advisory recommendations for other clients as those recommendations relate to the recommendations for Efficient Edge clients, as well as conflicts arising regarding the availability of information as to what type of advisory recommendations – potentially containing useful information – are being performed for other clients. Additionally, As of 12/31/2024, the Efficient Edge Advisory Service had assets totaling $543.7 million. AssetMark Efficient Edge Disclosure BrochureThis must remain with the Client Page 6 of 7 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS AssetMark faces conflicts over its ability to take certain trades to market for other clients while in possession of information about the intended advice to be provided to Efficient Edge clients. AssetMark also provides services to its other mutual fund clients in the selection, review and termination of third-party investment management firms to serve as sub-advisers to its funds, a service provided for Efficient Edge clients through the evaluation of third-party fund managers. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Owners of a Variable Annuity Contract who have opted for the Efficient Edge Advisory Service will not generally have access to the AAM staff that constructs the Portfolio-Specific Models or that categorize the list of Available Portfolios into asset categories for purposes of the Build Your Own model. Clients will also not generally have access to the investment management staff at the mutual fund companies that manage the Portfolios in the list of Available Portfolios. Clients of the Efficient Edge Advisory Service should consult with their registered representative for information about the ongoing activities of their Portfolio-Specific Model. The Efficient Edge Asset Advisory Service is offered to owners of select variable contracts issued by the Insurance Companies. ITEM 9 – ADDITIONAL INFORMATION HOW TO BECOME AN EFFICIENT EDGE ADVISORY SERVICE CLIENT DISCIPLINARY INFORMATION This disciplinary information is with regard to AssetMark’s other advisory services, as described above. The services described in the AssetMark ‘s disciplinary information were not available through the Efficient Edge Advisory Service. You must own a Variable Contract issued by GLAIC or GLICNY for which AssetMark’s Efficient Edge Advisory Service is offered. You may sign up for the service with forms provided by the Insurance Company which issues your Variable Contract. You do not need to sign a separate agreement with AssetMark; however, AssetMark will only follow written instructions from you received by your Insurance Company in a form acceptable to the Insurance Company. The terms of your agreement with AssetMark are contained in this Disclosure Brochure. There is no minimum account value required for the AssetMark Efficient Edge service, although there may be minimum Variable Contract values imposed by the Insurance Companies. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION AssetMark Asset Management (“AAM”) requires that employees providing investment advice are required to have financial or analytical experience or to have qualified for registration as an Investment Advisory Representative as required by applicable state securities regulations, either by having passed the Uniform Investment Adviser Law Examination (Series 65) or by possessing other qualifying designations such as the Chartered Financial Analyst (CFA) designation. In addition to the foregoing, members of AAM are generally required to have a college education or equivalent experience, analytical or portfolio management experience, and/or to have obtained the CFA designation. On September 26, 2023, the SEC issued an Order Instituting Administrative Cease-and-Desist Proceedings against AssetMark. The SEC alleged that, from at least September 2016 through January 2021, AssetMark failed to fully disclose that AssetMark and affiliate AssetMark Trust Company together set the amount of the payment that AssetMark Trust would retain as compensation from the payment received by the banks that participated in the FDIC-Insured Cash Deposit Program (“ICD Program”) (the “ICD Program Fee”), which, in turn, determined the amount that would be distributed as interest by the banks to clients. The SEC alleged that AssetMark had failed to fully disclose the associated conflicts of interest related to its role in setting the ICD Program Fee. The SEC also alleged that AssetMark, from at least January 2016 through August 2019, did not fully disclose the associated conflicts of interest related to AssetMark’s receipt of custodial support payments funded through payments from certain no-transaction fee (“NTF”) mutual funds. The SEC alleged that these failures constituted breaches of AssetMark’s fiduciary duty to advisory clients. The SEC alleged that AssetMark violated Section 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 promulgated thereunder. AssetMark consented to the Order without admitting or denying the SEC’s findings. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The Insurance Companies are responsible for providing information to clients and/or to their registered representatives concerning all aspects of the Efficient Edge Advisory Service, including such items as investment performance, allocation changes, market updates and changes to the list of Available Portfolios. On August 25, 2016, the SEC announced a settlement with AssetMark in an order contained findings, which AssetMark neither admitted nor denied, that AssetMark violated Section 206(4) of the Advisers Act and Rule 206(4)-1(a)(5) by allowing its staff, from July 2012 through October 2013, to circulate to prospective clients who were considering an F-Squared managed account service offered by AssetMark, performance advertisements created by F-Squared relating to a different separately managed account service not offered by AssetMark and that misleadingly described that different service’s performance between 2001 and 2008, and that AssetMark violated Section 204(a) of the Advisers Act and Rule 204-2(a)(16) by failing to maintain records substantiating the performance in the advertisements created by F-Squared. There are no disciplinary items to report for the management of AssetMark. AssetMark Efficient Edge Disclosure BrochureThis must remain with the Client Page 7 of 7 FINANCIAL INDUSTRY AFFILIATIONS ASSETMARK’S CODE OF ETHICS FOR PERSONAL SECURITIES TRANSACTIONS AssetMark was previously named Genworth Financial Wealth Management, Inc. and was renamed following its separation from Genworth Financial, Inc. AssetMark is also the investment adviser for the GuideMark Funds (formerly known as the AssetMark Funds), and the GuidePath Funds. AssetMark Brokerage, LLC is a broker- dealer registered with the Financial Industry Regulatory Authority (“FINRA”) and acts as the distributor for the GuideMark Funds, and the GuidePath Funds. AFFILIATED COMPANIES The following are AssetMark affiliated companies under common control. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its clients. These companies are not relevant to AssetMark’s provision of the Efficient Edge Advisory Service. • Atria Investments, Inc. (d/b/a Adhesion Wealth) • AssetMark Trust Company (AssetMark Trust) • AssetMark Services, Inc. • AssetMark Brokerage, LLC (AssetMark Brokerage) Those that are relevant to its provision of the Efficient Edge Advisory Service are discussed below. AssetMark has adopted a Code of Ethics (the “Code”) that is intended to comply with the provisions of Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”), which requires each registered investment adviser to adopt a code of ethics setting forth standards of conduct and requiring compliance with federal securities laws. Additionally, the Code is designed to comply with Section 204A of the Advisers Act, which requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by any person associated with such investment adviser. The Code requires that all “Supervised Persons” (including officers and certain affiliated persons and employees of AssetMark) in carrying out the operations of AssetMark, adhere to certain standards of business conduct. Specifically, the Code requires that these persons: (i) comply with all applicable laws, rules and regulations, (ii) avoid any conflict of interest with regard to AssetMark and its Clients, (iii) avoid serving their personal interests ahead of the interests of AssetMark and its Clients, (iv) avoid taking inappropriate advantage of their position with AssetMark or benefiting personally from any investment decision made, (v) avoid misusing corporate assets, (vi) conduct all of their personal securities transactions in compliance with the Code, and (vii) maintain, as appropriate, the confidentiality of information regarding AssetMark’s operations. NON-AFFILIATED COMPANIES Insurance Companies The Efficient Edge Efficient Edge Advisory Service is offered by AssetMark exclusively to owners of Variable Contracts issued by Genworth Life and Annuity Insurance Company and Genworth Life Insurance Company of New York. Broker-Dealers Capital Brokerage Corporation (“CBC”) is a broker-dealer registered with the U.S. Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority (“FINRA”). CBC serves as the principal underwriter of the Variable Contracts. CLIENT REFERRALS The Insurance Companies make the Efficient Edge Advisory Service available to owners of select Variable Contracts they offer. AssetMark does not pay the Insurance Companies a specific fee for these referrals. PRIVACY POLICY The Code contains a number of prohibitions and restrictions on personal securities transactions and trading practices that are designed to protect the interests of AssetMark and its Clients. First, the Code prohibits trading practices that have the potential to harm AssetMark and/or its Clients, including excessive trading or market timing activities in any account that AssetMark manages, trading on the basis of material non-public information, and trading in any “Reportable Security” when they have knowledge the security is being purchased or sold, or is being considered for purchase or sale by the Accounts managed by AssetMark or any AssetMark-advised mutual funds. Second, the Code mandates the pre-clearance of certain personal securities transactions, including transactions in securities sold in initial public offerings or private placements. The Code also requires the pre-clearance of Reportable Security transactions for certain Access Persons (Access Persons is a segment of the Supervised Persons group that have access to AssetMark information). Finally, the Code requires Access Persons to submit, and the Chief Compliance Officer (the “CCO”) to review, initial and annual holdings, and quarterly transaction reports. The Privacy Policy supplied to you by your Insurance Company will govern the Efficient Edge Advisory Service. QUARTERLY REPORTS AssetMark utilizes StarCompliance to provide enhanced tracking of certain employee transactions and gives AssetMark the ability to analyze those employee trades against certain parameters and transactions in its managed Accounts or any AssetMark-advised funds. Access Persons also utilize this system to annually certify their receipt of, and compliance with, the Code and pre-clear their Reportable Security transactions, if they are required to do so by the Code. Efficient Edge Variable Contract owners will receive quarterly account statements from their Insurance Company which include information about the subaccounts in their Model. ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS All Supervised Persons under the Code are responsible for reporting any violations of the Code to the CCO. The Code directs the CCO to submit reports to the Board of Trustees of any AssetMark-advised mutual funds regarding compliance with the Code, and to impose sanctions on violators, as warranted. Not Applicable AssetMark will provide a copy of the Code to any Client or prospective Client upon request. AssetMark Efficient Edge Disclosure BrochureThis must remain with the Client

EFFECTIVE MARCH 26, 2025 Bank and Trust Company Platform Disclosure Brochure Form ADV Part 2A Appendix 1, Wrap Fee Program Brochure SEC File Number − 801 56323 IA Firm CRD Number - 109018 ITEM 1 – COVER PAGE This Disclosure Brochure provides information about the qualifications and business practices of AssetMark, Inc. (“AssetMark”). If you have any questions about the contents of this Brochure, please contact AssetMark using the information shown on the left. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. AssetMark is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about AssetMark is also available on the SEC’s website at www.adviserinfo.sec.gov. AssetMark, Inc. Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 800-664-5345 R315_BankPlatDsclBro_2025_03  Bank Trust Platform Disclosure Brochure Page ii ITEM 2 – MATERIAL CHANGES This section provides a summary of material changes that were made to this brochure since the last update. It includes changes to AssetMark’s Platform and is intended to help Clients determine if they want to review this brochure in its entirety or contact their Bank or Trust Company with questions about the changes. AssetMark can make interim updates to this brochure throughout the year. However, you will receive notice of any material changes, which must also be filed with the SEC. Information about AssetMark is available on the SEC’s website at www.adviserinfo.sec.gov or at www.assetmark.com. You can also request a copy by contacting us at: AssetMark, Inc. Attention: Adviser Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 800-664-5345 advisorcompliance@assetmark.com There have been no material changes since the initial Form ADV Part 2A Appendix 1 filed in September 2024. The following updates were made, in addition to clarifying edits in the disclosure brochure: • Item 4 – Services, Fees and Compensation - Savos Custom , GMS, PMP, Advisor – Custom or Personal Portfolios. - Additional information about refund of prepaid Account fees. • Item 5 – Account Requirements and Types of Clients - Investment Minimums – Account Size • Item 9 – Additional Information - Updates to FDIC-Insured Cash Programs - Additional information under Custodial Relationships • Exhibit B – AssetMark Asset Management – Solution Types - Upcoming management change for MarketDimensions and OBS Strategies. This must remain with the Client  Page 1 of 32 ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i ITEM 2 – MATERIAL CHANGES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii ITEM 3 – TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ITEM 4 – SERVICE, FEES AND COMPENSATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • WRAP FEE PROGRAM – THE FINANCIAL ADVISOR FIRM AND THE CLIENT SERVICES AGREEMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • ASSETMARK, INC. AND ITS OWNERSHIP STRUCTURE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • DESCRIPTION OF PLATFORM SERVICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • OTHER SERVICES AND NON-MANAGED ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 • INVESTMENT VEHICLES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 • ASSETS UNDER MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 • FEES AND COMPENSATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 • SELECTION AND REVIEW OF PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS . . . . . . . . . . . . . . . . . . . . . . . . 10 • ASSETMARK AS PORTFOLIO STRATEGIST OR INVESTMENT MANAGER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 • REVIEW OF ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 ITEM 9 – ADDITIONAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 • DISCIPLINARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 • OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 • CUSTODIAL RELATIONSHIPS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 EXHIBIT A – SOLUTION TYPES – MODEL PROVIDERS AND INDIVIDUAL MANAGED ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 EXHIBIT B – ASSETMARK PORTFOLIO SOLUTIONS SOLUTION TYPES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 EXHIBIT C – PROPRIETARY MUTUAL FUND SOLUTIONS - CONFLICTS OF INTEREST DISCLOSURES . . . . . . . . . . . . . . . . . . . . . . . . . . 28 FEES AND INVESTMENT MINIMUMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 2 of 32 ITEM 4 – SERVICE, FEES AND COMPENSATION WRAP FEE PROGRAM – BANK AND TRUST COMPANIES those of a Discretionary Manager and include the selection of securities for the Account (consistent with the Strategy (described below) selected by the Financial Advisor for the Bank’s client) and trade execution. A list of Portfolio Strategists/Model Providers and Investment/Discretionary Managers are provided in Exhibit A. Individual Solutions are available either through third-party Investment Management Firms (described below) or as proprietary Strategies managed by AAM. Strategists are also permitted to use AssetMark proprietary investment options or funds as part of a Strategy. DESCRIPTION OF PLATFORM SERVICES AssetMark, Inc. (“AssetMark”) is the sponsor of the AssetMark Platform (“Platform”) through which it offers its investment solutions and Platform services to Financial Advisory Firms, such as registered investment advisers, or banks and trust companies. This Disclosure Brochure describes the advisory and platform services offered by AssetMark to bank and trust companies (also referred to as “Bank” or “Firm” or “Trust” in this brochure). Representatives of the banks and trust companies such as bank representative or trust officer (also referred to as the “Financial Advisor”) consult with their Clients to assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet their Client’s financial needs. ASSETMARK, INC. & ITS OWNERSHIP STRUCTURE Bank and Trust Companies enter into an agreement with AssetMark to access the Platform for their Clients. As part of the Platform services, AssetMark provides account administration, custody, brokerage and advisory services; the Platform is therefore considered a “wrap program.” AssetMark has developed internet-based software which provides the Bank with the ability to directly monitor its Clients’ Accounts, download information concerning changes in the Platform, and access current information relating to the Platform. AssetMark is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since 1999 providing various investment advisory and consulting services to other advisors and investment Clients. AssetMark and AssetMark Trust Company (“AssetMark Trust”) are wholly owned subsidiaries of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc. is an independent, U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. AssetMark Wealth Solutions includes AssetMark’s Asset Management (AAM), Due Diligence, Investment Consulting, and other portfolio, wealth, and practice solutions. AAM is responsible for AssetMark’s proprietary investment strategies. Bank is a bank or trust company that acts as trustee to trusts and/or as agent for investment advisory clients and desires to use the Platform to assist it in providing investment advisory and related services to its Clients. Bank may invest a Client’s Account in a Strategy offered on the AssetMark Platform. One or more investment solutions, AssetMark, facilitates the client’s investment into that investment solution. The Bank will have responsibilities with regard to setting up each client account information within the AssetMark‘s System (also known as eWealthmanager) and Accutech Systems LLC (also known as “Cheetah”). RISK RETURN PROFILES If the Financial Advisor selects for the Client a Solution Type (or “Investment Solutions,” or “Solutions” described below) managed by AAM, AssetMark is responsible for the management of that Solution Type for the Client’s Account (described below). AssetMark also serves as the investment adviser for the GuideMark Funds and GuidePath Funds (each a “Fund” and collectively the “Proprietary Funds”) available in certain Solution Types on the Platform: 1) GuideMark Funds (no-load sub-advised mutual funds) One of the fundamental elements of the Platform is establishing the Client’s appropriate Risk/Return Profile. These Profiles range from most conservative (lowest estimated risk and lowest potential return) to most aggressive (highest estimated risk and highest potential return). Strategies on the Platform can only have a single risk profile or may have multiple risk profiles. 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund) The investment objectives for each of the six Risk/Return Profiles are listed below: • Profile 1 – Conservative: The profile is designed for an investor who wants to focus on preservation of capital as a primary goal and wishes to minimize downside risk. AssetMark is responsible for the selection and management of subadvisors for each of the GuideMark Funds. However, the Client and the Financial Advisor, and not AssetMark, are responsible for selecting the Solution Type that uses Proprietary Funds. • Profile 2 – Moderate Conservative: The profile is designed for an investor who seeks to preserve capital but wishes to assume moderate downside risk in order to earn a return sufficient to preserve purchasing power. • Profile 3 – Moderate: The profile is designed for an investor who seeks to balance risk of loss to capital with capital appreciation. • Profile 4 – Moderate Growth: The profile is designed for an investor who seeks enhanced capital appreciation and is willing to accept greater risk of downside loss and volatility of returns. AssetMark is not registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor, based on its determination that it will rely on certain exemptions from registration provided by the Commodity Exchange Act (“CEA”) and the rules thereunder. The CFTC has not passed upon the availability of these exemptions to AssetMark. AssetMark currently acts as a registered “commodity pool operator” (“CPO”) with respect to the GuidePath Managed Futures Strategy Fund and its wholly owned controlled foreign corporation, the GuidePath Managed Futures Strategy Cayman Fund. AssetMark is registered as a CPO under the CEA and the rules of the CFTC. • Profile 5 – Growth: The profile is designed for an investor who seeks significant capital appreciation and is willing to accept a correspondingly greater risk of loss and volatility of returns. • Profile 6 – Maximum Growth: The profile is designed for an investor who seeks the highest level of capital appreciation and is willing to accept the correspondingly greater risk of loss and volatility of returns. AAM acts as the Portfolio Strategist (described below) providing Model Portfolios (described below) for a number of Solutions. It is also among the Discretionary Managers (described below) offered on the Platform. With respect to those Strategies in which AssetMark acts as a Discretionary Manager, its obligations are accordingly Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 3 of 32 Generally, the percentage allocation to equity securities targeted for each Risk/Return Profile increases for each Profile from Profile 1, Conservative, which would represent the lowest target allocation of equity securities, through Profile 6, Maximum Growth, which would represent the highest target allocation of equity securities. INVESTMENT STRATEGIES • Individually Managed Accounts (“IMA”) – The Bank Client Account is managed and individual Bank Client Account trades are implemented on a discretionary basis by a “Discretionary Manager” (also referred to as an “Investment Manager”). For some IMAs, AssetMark serves as the Discretionary Manager; for others, a third- party manager serves as Discretionary Manager and AssetMark has no role in trading for the IMA. Another element of establishing the Client’s investment objective is to identify the appropriate mix of Investment Strategies to manage risk efficiently and meet the Client’s return objectives. Each Portfolio Strategist, Investment Manager and/or Solution Type is classified by AssetMark based on their Investment Strategy. There are four main types of investment strategies which can be used in a client portfolio: 1. Core: A mix of predominantly equities and fixed income across US or global markets and has multiple risk profiles. Other asset classes, including real assets and alternatives may be included to help manage risk. Strategies may focus on a total return or income mandates. Some Core Strategies may offer a tax aware option whereby tax-exempt fixed income investments are held within portfolios and in some cases tax-managed equity investments can also be held. For some Core Strategies, holding periods and turnover levels will be considered; however, AssetMark cannot guarantee that the portfolios will behave in a tax-sensitive manner over any given time period. • Individual Mutual Fund (“IMF”) – Bank Client accounts are allocated to a single mutual fund and is intended to complement other Solution Types available on the AssetMark Platform, as part of the Client’s overall Portfolio. The IMF’s used in this advisory service can be Proprietary or third-party funds. Each IMF is not available at all Platform Custodians. The Bank should make sure their clients are aware that the Platform Fees charged by AssetMark for this service can be higher or lower than those charged by others in the industry or directly from the third-party mutual fund provider, and that it can be possible to obtain the same or similar services from other investment advisers at lower or higher rates. AssetMark may waive the Platform Fee in its discretion. A Prospectus for any individual mutual fund made available under this Solution Type can be obtained upon request from AssetMark or the Bank and Trust Company. Clients should review fund prospectuses and consult with their Financial Advisor if they have questions regarding these IMF Solution Types. The mutual funds shares selected for use can be institutional or retail shares, and can include administrative service fees, sub-transfer agency fees and/or 12b-1 fees, that are fees borne by Clients. See Servicing Fees Received by Custodians, including AssetMark Trust and Share Class Use for a discussion of 12b-1 fees, administrative service fees and sub-transfer agency fees and the Fees & Investment Minimums table at the back of this Disclosure Brochure for the Platform Fees charged IMFs. The Bank client’s Investment Strategy can be customized and implemented with a number of features and alternatives, such as: 2. Equity: Strategies that are mainly invested in equities and are typically a single risk profile. Equity Strategies may focus on one of three investment mandates; total return (enhancing return over a diversified benchmark through active management - Enhanced Return Focus), income (ie equity dividends) or defense (limiting losses during market downfalls through reducing equity exposure – Limit Loss Focus - holding lower beta securities or using hedging strategies) • a range of Risk/Return Profiles; • selection of one or more Investment Strategies and Mandates; • a group of available Portfolio Strategists or Investment Managers; and 3. Bond: Strategies that are mainly invested in fixed income and are typically a single risk profile (Bond and Bond Alternatives). Some Bond Strategies may include some low volatility alternative or equity exposure. These Strategies can help manage risk through diversification benefits and may focus on either a total return, income or defensive (typically lower duration) investment mandate • various IMA’s, so that the Client, as advised by the Financial Advisor, can create a Strategy by which each of the Client’s Accounts under the Platform will be managed or maintained. 4. Alternative: Strategies that are mainly invested in non-correlated liquid alternative strategies to provide diversification benefits to help manage risk. Alternative Strategies are typically a single risk profile and can invest in traditional alternative strategies, niche strategies or trend following strategies (managed futures – Equity Alternatives). SOLUTION TYPES Some Solution Types are available through third-party Investment Management Firms unaffiliated with AssetMark. Other Solution Types are proprietary Strategies available through AAM, or Individual Mutual Funds as described above. AssetMark makes available fact sheets and other information to assist the Financial Advisor in making an informed decision. More detailed information about the proprietary solutions are provided in Exhibit B – AssetMark Portfolio Solutions – Solution Types. Overlay Manager Investment Strategies are available through three general “Solution Types” (or “Solutions”) on the Platform. For SMA Investment Solutions, The Bank shall select a model provided by a Portfolio Strategist and AssetMark will serve as the “Overlay Manager” (or Investment Manager or Discretionary Manager) for the Bank client subaccount. The Overlay Manager shall provide limited discretionary investment management services to the subaccount as discussed further below. The Bank grants the Overlay Manager the authority to buy and sell securities and investments for the subaccount. AssetMark has contracted with Portfolio Strategists to provide recommendations for exposures to specific asset classes or securities. • Model Portfolios – the Bank Client Accounts are allocated among securities and other investment vehicles on a non-discretionary basis pursuant to Model Portfolios provided by “Portfolio Strategists” (also referred to as “Model Providers”). Model Portfolios include mutual fund and ETF investment strategies and Separately Managed Accounts (“SMA”). SMA Model Portfolios are allocated among securities and other investment vehicles in accordance with the model and are typically selected for a specific asset class. AssetMark will serve as the Overlay Manager (described below) with regard to SMA accounts. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 4 of 32 In certain IMA Solutions, Clients will receive from the Investment Manager, and will be required to acknowledge receipt of, additional disclosures regarding specific investments, such as alternative investments, the use of the IMA managers mutual funds, or the use of options and/or certain fixed-income solutions. Use of Mutual Funds Managed by IMA Manager The SMA Model Portfolios have been constructed by Portfolio individual securities Strategists engaged by AssetMark using recommendations. The Overlay Manager will have limited discretionary authority to execute transactions in each Account necessary to (i) track any reallocations, rebalance or other adjustments to the SMA asset allocations constructed by the Portfolio Strategists, (ii) implement changes recommended by the Portfolio Strategists; (iii) effect sale transactions of specified securities as directed by the Client and purchases of replacement securities; and (iv) implement trades to support advisor-directed tax-loss harvesting requests for clients and (v) implement any individual securities restrictions imposed on the Account by the Client. As Overlay Manager, AssetMark intends to invest the Bank Client account consistent with the models provided by the Portfolio Strategist, unless circumstances indicate that modified allocations or investments are appropriate. The Client, with assistance of their Financial Advisor, can specify the initial Portfolio Strategist for the Bank Client account and will be given notice of any change to that Portfolio Strategist. Individually Managed Accounts (“IMA”) An IMA can be established as: • Equity/Balanced; IMA Managers can include in the Bank IMA Client accounts they manage mutual funds that they or an affiliate manage. In these situations, the IMA Manager typically receives fees from AssetMark for their management of the Client’s Account, and they or an affiliate typically receive investment adviser or other fees from the funds they or the affiliate manage. This is a conflict because it can create an incentive for the IMA Manager to select their own or affiliated funds. These fees can exceed what the IMA Manager would receive for using third-party mutual funds. The Bank should discuss this conflict of interest with their clients. Clients will also receive the IMA Manager’s Form ADV Disclosure Brochure which will disclose all conflicts of interests. The IMA Manager also provides additional disclosures regarding their rebate process in order to avoid collecting two fees on the same assets. In some instances, the IMA Manager will receive fees from AssetMark and rebate the portion of fees received from the funds they or the affiliate manages. In other cases, the IMA Manager will receive their fees from the funds they or the affiliate manages, and rebate the portion of the fees received from AssetMark. • Fixed Income; and Custom High Net Worth • Custom High Net Worth The Investment Manager will provide discretionary investment management services to the Bank Client Account and the Bank grants the Investment Manager the authority to buy and sell securities and investments for the Bank Client Account, vote proxies for securities held by the Account, to select the broker-dealers or others with which transactions for the Accounts will be effected, and such other actions that are customary or appropriate for an Investment Manager to perform. The Investment Manager is responsible for selecting the securities for Client investment, including the share class if the investment is in mutual funds. Custody fees, if charged, are asset based. Usually, transaction fees are not charged to IMA accounts. Step Out or Trade Away Trades for IMAs For Custom High Net Worth (“HNW”) accounts, the Bank selects an Investment Manager to manage the Bank individual Client Account and to provide discretionary investment management services to the Account. The Bank grants the Investment Manager the authority to buy and sell securities and investments for the Account, to re-balance and re-allocate assets within the Account, to vote proxies for securities held by the Account and such other discretionary authorities as determined between the Bank Client, their Bank and the Investment Manager. As such, the Bank Client’s personalized investment objective can go beyond the standard investment objectives listed for each of the six Risk/Return Profiles as described earlier in this section, and as developed by the Investment Manager for the Bank Client. The Investment Manager, in its discretion, will maintain investment decision records with regards to the Bank Client’s HNW Account. If a Client’s investment objective and/or Risk/Return Profile changes, the Bank is responsible for notifying AssetMark of the change. FINANCIAL ADVISOR – CUSTOM ACCOUNTS Multiple Strategy Accounts The Investment Manager has the authority to “step-out” or “trade away” a trade and use a brokerage firm other than that usually used with the Bank Client’s Custodian, and such trading will result in additional fee(s) from the Platform Custodian, unless such fees are waived (refer to Item 9 under “Brokerage Practices”). If a Discretionary Manager of an IMA determines to “step out” or “trade away” a trade, the Custodians are permitted to assess a fee of $20.00 per trade. This transaction fee would be in addition to any commission or trading costs. If an Account is invested in fixed income investments, e.g., a Parametric bond ladder IMA, the Client should expect this $20.00 fee on each security transaction. Commission charges, dealer spreads, markups/ downs, and foreign currency conversion rates associated with these transactions may not be visible to you in your program documents. Certain Model Solutions discussed above are also available as sleeve- level options within a Multiple Strategy Account. In a Multiple Strategy Account, an Account can be customized with no set allocation limits. The Bank can select from various Portfolio Strategists and Investment Managers, including AAM, and AssetMark-advised mutual funds (“Proprietary Funds”) for their clients. In selecting and determining the allocations in each sleeve, a Multiple Strategy Account will be established. The number of sleeves selected can vary from a minimum of two to a maximum of eight selections, to comprise the Multiple Strategy Account and will be evaluated on a quarterly basis for rebalancing across the sleeves. The standard minimum account by sleeve will vary. The fees charged for the Multiple Strategy Account will be based on the single-strategy fee schedule for each Strategist selection and based on the allocation to each sleeve. For Banks selecting an IMA for their client’s account, the bank client’s account will be managed by an Investment Manager consistent with the Strategy selected by the Bank. The Investment Manager shall provide discretionary investment management services to the Bank Client Account, and the Bank grants the Investment Manager the discretionary authorities discussed above. AssetMark can replace the Investment Manager at its discretion. Certain Custom IMAs are available in the Core Markets Investment Approach and the six Risk/ Return Profiles, as described above under Risk/Return Profiles. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 5 of 32 Custom GPS Select Advisor As Strategist Program and Advisor Managed Portfolios Program A Bank may participate in the Advisor as Strategist or Advisor Managed Portfolios program (“AAS” or “AMP” program). In these programs, A Bank has discretionary authority to manage the “Custom Account” for their client. The Bank will be solely responsible for determining account assets and giving instructions for trades and rebalances. AssetMark does not provide any investment advice to Custom Accounts, does not have or exercise any discretionary authority with regard to Custom Accounts and does not supervise the Custom Accounts or the Bank in its management of Custom Accounts. GPS Select, as described in Exhibit B – AssetMark Asset Management – Solution Types, can be customized within a specific range from the baseline to various Investment Strategies. The Bank can select from various Investment Approaches from Portfolio Strategists and Investment Managers, including AAM, and Proprietary Funds. In doing so, and by selecting within the range of pre-determined allocations, a Custom GPS Select account will be established. Each Portfolio Strategist, Investment Manager or mutual fund selection is referred to as a “sleeve” allocation. If a mutual fund Solution Type is selected, the share class used will be consistent with the underlying single strategy solution. The Bank is responsible for advising the Client on an ongoing basis whether or not to maintain or change the Investment Strategy, the Portfolio Strategist and the Investment Manager for the duration of the account. AssetMark does not advise the Bank Client about the Investment Strategy, the Portfolio Strategist or the Investment Manager appropriate for that Bank Client’s Account. The asset allocation classification of the Custom Accounts and any models used by the Bank may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for Platform Accounts. The Platform Fee schedules will be charged to the Bank, unless otherwise negotiated between the Bank and AssetMark. INVESTMENT CONSULTING AssetMark will make available the specific range of pre-determined allocations, which range will be updated from time to time. The number of sleeves selected can vary from a minimum of three to a maximum of eight sleeve selections, to comprise the entire Custom GPS Select account. The standard minimum account by sleeve varies and AssetMark’s revenue will increase or decrease based on the sleeve allocation agreed upon between the Client and the Bank. Savos Custom GMS, PMP, Advisor – Custom, or Personal Portfolios (Refer to Exhibit B – AssetMark Asset Management – Solution Types for more detailed information regarding the selection of AAM strategies to be used within these custom accounts.) A Bank or a Bank representative can request that AssetMark consult on the creation of practice-based models that include Platform Solutions to meet specific goals and/or objectives sought by the Bank or Bank representative. These models can include proprietary and/or third-party Solutions. The Bank and its representative will continue to be responsible for determining the final combination of Solutions used in their practice-based models and the suitability of these Solutions for their Client(s). AssetMark does not provide individualized investment advice to Clients or to the Bank for individual client accounts. There is typically no fee for this service, but the Bank representative is expected to make an asset commitment to the Platform, which creates a conflict of interest for the Bank representative. The inclusion of a proprietary Solution creates a conflict of interest for AssetMark if selected by the Bank and its representative because AssetMark receives fees for the management of proprietary Solutions. • Custom GMS and Privately Managed Portfolios (“PMP”): The Bank can request that AAM deviate from standard allocations for the selected GMS or PMP Strategy. Such an Account is considered a Custom GMS or PMP Strategy. TAX MANAGEMENT SERVICES • Advisor – Custom Accounts: The Bank can choose to participate in a program that allows the Bank to request further customization for their Bank Client’s Account (“Advisor – Custom Accounts” or “ACA”) in consultation with AAM. The Bank will be solely responsible for determining the additional customization and the suitability for the Bank Client’s Account. AAM, in its discretion, will determine the implementation of the ACA. The Bank can request that AAM recommends to the Bank asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the ACA developed by the Bank may not be consistent with the Investment Strategies or Risk/Return Profiles described in this Disclosure Brochure for the GMS or PMP Accounts described in Exhibit B – AssetMark Asset Management – Solution Types. The GMS or PMP Platform Fee schedules will be charged to the Client Account, unless otherwise negotiated between the Bank and AssetMark. • Savos Personal Portfolios – Custom: – A Savos Personal Portfolios - Custom Account can be customized within a specific range across equity, fixed-income and tactical allocations. The Bank can select from various Savos strategies. In doing so, and by selecting within the range of pre-determined allocations, a Savos Personal Portfolios - Custom Account will be established. Each equity, fixed-income and tactical allocation is referred to as a “sleeve” allocation. The Tax Management Services (TMS) is expected to be offered in 2025 and is designed to improve the after-tax return for the client’s account. Clients can submit account restrictions, such as GICS sub- industry restrictions for individual stocks, not mutual funds or ETFs. The application of TMS will cause the account to deviate from its selected investment strategy and may also affect the risk profile and overall performance of the account. Municipal securities held in TMS accounts can be replaced with non-municipal or non-state specific securities as portfolio holdings, resulting in interest income that may be subject to federal, state, and/or local income taxes. If you select TMS with a high tax sensitivity, you should expect the account to deviate from the selected strategy to a higher degree than if a lower tax sensitivity is selected. If additional customizations or restrictions are added to your TMS account, they may impact the account’s tax and investment results and the effectiveness of TMS. The application of TMS can cause the account to stray from the Strategy and Risk/Return Profile selected for the Account. AssetMark does not provide tax planning, accounting, or legal advice or services. The Tax Management Services fee is ten basis points (0.10%) with a $100 minimum annual fee per account. TMS fees can be negotiable. Accounts enrolled in TMS can trade at different times than other accounts on the AssetMark Platform invested in than same strategy and can hold higher cash allocations due to minimum trade size, rounding and other factors. TMS accounts will not be automatically rebalanced if the cash allocation exceeds a 2% threshold. The cash allocations will be invested in the cash “sweep” vehicle at the client’s selected custodian, which for AssetMark Trust is usually its Insured Cash Deposit (“ICD”) Program. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 6 of 32 OTHER SERVICES AND NON-MANAGED ACCOUNTS Administrative and General Securities Accounts decisions based on such analysis. AssetMark does not recommend specific Portfolio Strategists, Investment Managers or Investment Management Firms to Clients. MUTUAL FUND MODEL PORTFOLIOS The Bank can usually establish a Bank Client Account at the Custodian to hold “non-managed” assets (an “Administrative/Non-Managed Account”), and such Account can include a Cash Account or a General Securities Account. An Administrative/Non-Managed Account is provided as an administrative convenience for the Bank Client. Assets in an Administrative/Non-Managed Account are not managed or advised by AssetMark, and AssetMark is not responsible for their investment or management. The Bank will be solely responsible for directing the investments in the Administrative/Non-Managed Account. Non-Managed assets are subject to the terms of the Client Bank’s agreement with their Custodian. In addition to reporting by the Bank Client’s Custodian, the assets of an Administrative/Non- Managed Account will be included in periodic AssetMark reports that the Financial Advisor can provide to the Client. For Banks selecting a Mutual Fund Account for their clients, the Account will be invested in institutional mutual funds retail NTF funds and/or mutual funds that generally do charge a sales load but where the sales charge has been waived. Third-party mutual funds and AssetMark Proprietary Funds are used. (Refer to Servicing Fees Received by custodians, Including AssetMark Trust and Share Class Use below). The Account will be invested consistent with allocations provided by a Portfolio Strategist for the Risk/Return Profile selected by the Client based on the advice of the Bank. Certain Portfolio Strategists compose their mutual fund allocations utilizing only those mutual funds managed by the Portfolio Strategist, Investment Manager or an affiliate of the Portfolio Strategist or Investment Manager. One or more of the Portfolio Strategists will construct their allocations exclusively using Proprietary Funds managed by AssetMark, including the GuideMark and GuidePath Funds. AssetMark does not advise the Client about the Portfolio Strategist or the Risk/Return Profile appropriate for that Client’s Account. Since Bank uses AssetMark Trust as their Platform Custodian, they will be offered a FDIC-Insured Cash Program and Certificates of Deposit for their Administrative account. This option, other cash management services from AssetMark Trust and the conflicts of interest involved in AssetMark affiliate AssetMark Trust offering these services are discussed in Item 9 of this Brochure. SERVICES NO LONGER OFFERED Multiple Investment Strategies are available as a model portfolio. Information regarding the Solutions and the Portfolio Strategists available for each of the Investment Strategies is available from the Client’s Bank. AssetMark also continues to manage other advisory services which are no longer offered to new Clients. Clients with these services can contact AssetMark for more information. INVESTMENT VEHICLES If a Mutual Fund account is chosen, it can also include non-mutual fund investments. For example, non-mutual fund investments could include cash alternatives and/or ETFs held by the Account, in addition to, depending upon the Custodian chosen, a standard allocation to cash. The Solution Types can be comprised of: (i) closed-end mutual funds; (ii) open-end mutual funds; (iii) ETFs; (iv) individual securities (stocks, bonds, preferred stocks, treasury bills and notes, bank notes) and (v) alternatives. The Client Accounts managed by Investment or Discretionary Managers can also include options and alternative investments, as advised by the Financial Advisor and the Investment Manager. Portfolio Strategists select from mutual funds that are AssetMark Proprietary Funds, third-party funds, NTF funds, load-waived, or retail mutual fund share classes that are available on each Custodian’s platform. There are no per-trade transaction fees charged to the Client in the mutual fund Solution Types on the AssetMark Platform. See Servicing Fees Received by Custodians, Including AssetMark Trust Company and Share Class Use under Fees and Compensation for more information on indirect fees the Client pays through their investment in mutual funds. Use of Portfolio Strategist and IMA Manager Proprietary Mutual Funds The Portfolio Strategists select and monitor the performance of the mutual funds, ETFs, and securities within their asset allocations and will periodically adjust and/or rebalance the asset allocations in accordance with their investment strategies. Each Investment Solution will maintain a 2% target cash allocation for the payment of fees, to cover withdrawals and other fees applicable to the Account. However, Portfolio Strategists and IMA Managers can determine to allocate a higher percentage to cash. AssetMark will reallocate the Account to the cash target when the Account passes certain thresholds (under 1.5% or over 2.5% for most Investment Solutions). From time to time, AssetMark will add to or delete certain investment vehicles from the Platform: a) Mutual Funds and ETFs model portfolios available through the Platform; b) Investment Managers available for the IMA Accounts; c) Portfolio Strategists available on the Platform; and Portfolio Strategists and IMA Managers are permitted to use their funds that they or an affiliate advises in the Model Portfolios or IMA accounts they manage. In these situations, the Portfolio Strategist and the IMA Manager typically receive fees from AssetMark for the Model Portfolio or the management of the Client’s IMA Account, and they typically receive investment adviser or other fees from the funds they or an affiliate advise. These fees can exceed what the Portfolio Strategist or IMA Manager would receive for using third-party mutual funds. This is a conflict for the Portfolio Strategist or IMA Manager because it can create a financial incentive for the Portfolio Strategist or IMA Manager to select their own proprietary or affiliated funds. Clients should discuss this conflict with their Financial Advisor. Clients will also receive the IMA Manager’s Form ADV Disclosure Brochure in which the IMA Manager is required to disclose all conflicts of interests. d) other Investment Management Firms providing asset allocations and asset selections for Solution Types. AAM uses Proprietary Funds in various investment solutions. Information about the Proprietary Funds, including fees and expenses, are described in more detail in the Proprietary Funds’ prospectus. The Bank reviews the Portfolio Strategists’, Investment Managers’ and Investment Management Firms’ and the Strategies’ performance on behalf of the Client and makes or recommends investment Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 7 of 32 ETF MODEL PORTFOLIOS The administrative services include but are not limited to arranging for custodial services to be provided by AssetMark Trust Company pursuant to separate agreement between Bank Trust Client and Custodian; preparation of quarterly performance review (to complement account statements provided by Custodians); and maintenance and access to electronic or web-based inquiry system that provides detailed information on each Client Account on a daily basis. An ETF is an investment fund traded on stock exchanges and holds assets such as stocks, commodities, or bonds, and can be traded over the course of the trading day. Each investor owns shares, which represent a portion of the holdings of the fund, and ETFs, like mutual funds, have management fees paid to the manager of the ETF. There are no separate share classes for ETFs. ETF Solutions invest in third- party ETFs, which are not advised by AssetMark. The annual rate of the ongoing Platform Fee is based on the amount and type of assets. Each fee schedule is tiered so that, subject to certain exceptions, the first dollar under management receives the highest fee and only those assets over the breakpoints receive the reduced fees. Under certain circumstances, assets held in one Investment Solution Account are considered when determining assets under management for breakpoint purposes relating to another Investment Solution Account held for the benefit of the same or a related person. Some of AssetMark’s Platform Fees are negotiable, and exceptions to the Fees & Investment Minimums schedule are subject to approval. As a standard practice, AssetMark grants exceptions to its fee schedule for accounts of employees and employees of broker-dealer, investment advisory or other firms with whom AssetMark maintains an active agreement, any of which can be offered discounted fees. The Bank can also select from ETF Solution Types, and the Account will be invested in ETFs consistent with allocations provided by a Portfolio Strategist for the Risk/Return Profile selected by the Client. A Portfolio Strategist can compose their ETF asset allocations utilizing ETFs managed by the Portfolio Strategist or an affiliate, by unaffiliated investment managers, or a combination of both. ETFs are traded daily at market determined prices on a national exchange in a similar manner to other individual equity securities. ETF Solution Types also invest in exchange-traded notes (“ETNs”), which are senior, unsecured debt securities issued by an underwriting bank. AssetMark is responsible for trading the ETF Solution Types based on the recommendations of Portfolio Strategists. The ETF trading practices are discussed further in Item 9 under “Brokerage Practices” in the Trade Execution and Brokerage Allocation section. CUSTODIAL AND BROKERAGE SERVICES Multiple Investment Strategies are available as an ETF Model Portfolio. Information regarding the Solution and Portfolio Strategies available for each of the Investment Strategies is available from the Client’s Bank. A Client Account is also permitted to include some non-ETF investments or an allocation to proprietary mutual funds managed by the Portfolio Strategist. In addition, the Bank Client retains all indicia of beneficial ownership, including, without limitation, all voting power and other rights as a security holder in each of the funds held for the Bank Client. The Platform Fee charged Client Accounts includes compensation for custodial and brokerage services. Pursuant to agreements that AssetMark has negotiated with AssetMark Trust (AssetMark’s affiliated Custodian), AssetMark pays the Custodian for the custodial and brokerage services provided to Bank Client Accounts. (The Custodians also have other income sources.) The Bank Client does not pay transaction fees on trades made in most of the Solution Types available on the Platform. Separate transaction fees will be charged in Fixed Income IMA Solutions and in some equity IMA Solutions. Additionally, AssetMark generally receives more revenue when AssetMark Trust as is the Custodian. ASSETS UNDER MANAGEMENT MINIMUM ACCOUNT PLATFORM FEE As of December 31, 2024, the Bank Trust Platform had $55 million in assets under administration on the AssetMark Platform. This includes investments in proprietary mutual funds and Proprietary Solution Types, in which AAM is the discretionary manager. FEES AND COMPENSATION The fees described here are for advisory and platform services offered by AssetMark to the Bank and Trust Companies. The Platform Fee includes: Certain ETF and mutual fund investment solutions are charged an annual Minimum Platform Fee of $350, or a quarterly prorated amount based on the number of days in that quarter. If the quarter end value of an Account multiplied by the fee rate is less than the calculated quarterly minimum fee, then the account will be charged the prorated quarterly minimum fee based on the number of days in the quarter. The Minimum Platform Fee is typically charged to accounts that no longer maintain the Investment Minimums in certain strategies. The Minimum Platform Fee, if charged, could represent a higher percentage fee than the stated Platform Fee for the strategy. Clients should consult with their Financial Advisor to understand the impact of fees when Investment Minimums are not met. (i) payment for advisory services (including the Strategist’s or Manager’s Supplemental Fee, if applicable) and administrative services; and (ii) payment for custodial and brokerage services (although additional fees are payable for certain third-party mutual funds, Actively Managed Fixed Income Strategies, and Funding Accounts (an account used to receive cash and assets transferred in kind before sale or transfer to an advised Account. The Platform Fee Schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimums schedule located at the end of this Disclosure Brochure. The Fees & Investment Minimums table will be updated from time to time, to include the addition of new products and services, to remove any terminated strategies, or to make updates. Information regarding the Fees & Investment Minimums will also be posted at www.assetmark.com/info/ disclosure, and you should consult this site for the most up-to- date information about the Fees & Investment Minimums. The Platform Fee provides compensation to AssetMark for maintaining the Platform and for arranging for advisory, administrative, custodial and brokerage services to the Account. The advisory services include the Model Portfolios provided by the Portfolio Strategists and the account management services provided by the Discretionary Managers. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 8 of 32 STRATEGIST’S OR MANAGER’S SUPPLEMENTAL FEE SERVICING FEES RECEIVED BY ASSETMARK AND SHARE CLASS USE For an Account invested in a third-party Investment Solution, a supplemental Strategist or Investment Manager Fee can be payable to the Strategist or Discretionary Manager. The Investment Manager Fee provides compensation for services provided by the Discretionary Manager that are customary for a Discretionary Manager to provide, including but not limited to, selecting, buying, selling and replacing securities for the Account and selecting the broker-dealers with which transactions for the Account will be effected. Portfolio Strategists select from the mutual funds available on each Custodian’s platform to be used in the Mutual Fund Accounts. The Custodian determines and then makes available the universe of mutual funds to be used in the AssetMark Solutions. If a mutual fund is not available, the Portfolio Strategist works with AssetMark and the Custodian to make the fund available, where possible. Mutual fund families offer a variety of funds with varying fee structures and different share classes. The funds available at the Custodians for use with the AssetMark Platform will vary among different mutual fund share classes and will generally fall into these two share class categories. For certain Solution Types, the Account will be charged a Supplemental Investment Manager Fee on the basis of the applicable Discretionary Manager. These fees are payable by the Bank Client on Account assets at the annual rates set out on the Fees & Investment Minimum fee table located at the end of this Disclosure Brochure. • Retail share class – Retail share class funds charge a 12b-1 fee of generally 0.25%, which is paid to the Custodian. Retail shares also include administrative fees, shareholder servicing and sub-transfer agent fees, which are also paid to the Custodian. There are a range of retail share classes available on the custodial platforms that also charge 12b-1 fees or administrative fees. These share classes are generally known as no-load or service shares (C shares), or load- waived A shares, Investor Shares, or NTF mutual funds, available through NTF programs at various Custodians. The Strategist’s and Manager’s Supplemental Fee can be negotiated at the sole discretion of the Discretionary Managers. Each Discretionary Manager’s investment process and philosophy are described in their Form ADV Part 2A Disclosures Brochure, which is provided to the Bank and Trust Company when they open an Account. To request another copy, the Bank Trust Company can contact the discretionary manager or AssetMark’s Compliance department at the address on the front cover of this Brochure. FEES FOR TERMINATED STRATEGIST OR NO STRATEGIST ACCOUNTS • Institutional share class – Institutional share class funds have lower expenses because there are no 12b-1 fee charges. However, institutional share classes can include administrative fees, shareholder servicing, and/or sub-transfer agent fees paid to the Custodian. NTF funds generally pay Custodians, including AssetMark Trust, AssetMark’s affiliated custodian, a range of servicing fees from the 12b-1 fees and administrative service fees, which typically include shareholder servicing and sub-transfer agent fees, collected by the mutual funds. See below Administrative Service Fees Received by Affiliate. AssetMark will use retail share mutual funds and institutional share mutual funds. There are no separate transaction fees charged for mutual fund investments on the Platform. The Client may be invested in an Account that no longer receives advisory services because the Strategy in which the Account was invested has been terminated from the AssetMark Platform, and the Client has not selected another Strategy for their assets. These Accounts are referred to as “No Strategist” or “Terminated Strategist” Accounts. Neither AssetMark nor any Discretionary Manager will manage or shall be responsible for giving any advice with regard to these assets, but the Account typically remains invested in the investments last selected for the Strategy at a Platform Fee that is a reduction from that payable when the Strategy was active on the AssetMark Platform. The Account will continue to receive administrative and custodial services. Any Financial Advisor Fee previously payable shall be payable on No Strategist or Terminated Strategist Accounts unless AssetMark receives instructions not to charge the Financial Advisor Fee. It is up to the Financial Advisor to a Client to recommend a new Strategy to a Client for a No Strategist or Terminated Strategist Account. Platform Fee schedules for No Strategist or Terminated Strategist Accounts are available by contacting AssetMark or the Client’s Financial Advisor. Fee Billing Process AssetMark does not always use the lowest cost share class. In striving for consistency across all custodial options on the Platform, AssetMark will seek to select the lowest cost share class available across all Custodians. Due to specific custodial or mutual fund company constraints, situations will arise where a specific share class is not consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class may be the retail share class. Information about the specific fees charged by mutual funds is described in each fund’s prospectus. INDIRECT INVESTMENT EXPENSES AND MUTUAL FUND FEES PAID BY CLIENT Pursuant to the Platform Agreement, the Platform Fee is billed quarterly in advance based upon the previous quarter-end values. Fees will be deducted from account assets unless otherwise agreed upon in writing by both AssetMark and the Bank and Trust Companies. For the initial deposit to the Account and for any subsequent amounts deposited to the Account, the Platform fee shall be payable upon the deposit or market value of the account (inclusive of accruals and dividends) reaching $1,000 or more. The Platform fee will be based upon the amount of the deposit multiplied by the quarterly rate of the applicable annual rate and charged pro-rata through the end of the calendar quarter. In the event the Client takes a withdrawal from their Account, AssetMark will not refund any prepaid fees related to the amount that has been withdrawn. However, upon termination of the Account, a portion of the prepaid Advisory Fees will be refunded, calculated by multiplying the daily prepaid Account Fee during the final quarter by the number of days remaining in that quarter. Some expenses are inherent within the investments held in Client Accounts. Mutual funds pay management fees to their investment advisers, and certain funds and money market accounts have other types of fees or charges, including 12b-1, administrative, shareholder servicing, bank servicing or certain other fees, which are typically reflected in the net asset value of these mutual funds held in Client Accounts. Such expenses are borne by all investors holding such securities in their Accounts and are separate from AssetMark’s Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 9 of 32 fees or charges. As discussed above, retail share classes of mutual funds typically pay 12b-1 fees to Custodians in return for shareholder services performed by those Custodians. funds selected for Client Accounts The Platform Fee for related Accounts of any Bank Trust Client on the Platform is negotiable, as are Platform Fees paid on Bank Trust Client Accounts that are associated with a particular Bank Trust Company, subject to approval. These negotiated fees typically lower the portion of the Platform Fee that AssetMark receives. SPECIAL SERVICE FEES PAID BY CLIENT Certain mutual include Proprietary Funds from which AssetMark receives compensation as the investment adviser, as described above. AssetMark receives management and other fees for its management of the GuideMark and GuidePath Funds. Non-standard service fees incurred as a result of special requests from Bank Trust Clients, such as wiring funds or overnight mailing services, will be an expense of the Bank Trust Client’s Account and will typically be deducted by the Custodian at the time of occurrence. An authorized officer of AssetMark or the Custodian must approve exceptions. Some mutual funds charge short-term redemption fees. Currently, AssetMark seeks to avoid investing Client assets in funds that charge such fees to the extent practicable, but avoidance of these fees cannot be guaranteed. SECURITY AND SALES-BASED FEES PAID BY CLIENT MUTUAL FUND SHARE CLASS USE IN AAM STRATEGIES An Account can also incur fees referred to as “Regulatory Transaction Fees,” paid to brokerage firms to offset the fees the firms owe to self- regulatory organizations and U.S. securities exchanges to cover fees charged by the SEC for costs related to the government’s supervision and regulation of the U.S. securities markets and professionals. In addition, applicable Accounts will also be charged expenses related to custody of foreign securities and foreign taxes. The Bank Trust Company should review the agreement or schedule of fees of their Custodian. FINANCIAL ADVISORY FIRM AND FINANCIAL ADVISOR PROGRAM In the AAM Strategies, mutual fund share class is selected on a fund- by-fund basis and seeks to eliminate 12b-1 fees where possible. AssetMark will seek to use institutional classes where these share classes are available. In striving for consistency across all custodial options on the Platform, the AAM Strategies will seek to select the lowest cost share class available across all Custodians. Due to specific custodial or mutual fund company constraints, situations will arise where a specific share class is not consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class may be the retail share class. OTHER COMPENSATION DISCLOSURE Bank money market accounts and other bank services typically charge separate fees. For more information regarding bank services, refer to Cash Management Services offered by Affiliate in Item 9 below. In addition to the Platform Fee and other compensation received by AssetMark, AssetMark enters into other fee arrangements with certain Bank and Trust Companies as described below. Such arrangements will not increase the Platform Fee payable by the Bank Client. However, the Bank Client should review and understand that these arrangements can be deemed to cause a conflict of interest because they provide the Bank and Trust Companies with incentives to place and retain Bank Client assets on the AssetMark platform. Each of the mutual funds, ETFs, alternative investments and other funds or pooled investment vehicles available on the Platform bears its own operating expenses, including compensation to the fund or sub-adviser. As an investor in the mutual funds or ETFs, the Bank Client indirectly bears the operating expenses of the mutual funds or ETFs, as these expenses will affect the net asset value (or share price in the case of an ETF) of each mutual fund or ETF. These expenses are in addition to the Bank Trust Fee paid to the Bank Trust Company and the Platform Fee payable to AssetMark. The ratios of fund expenses to assets vary from fund to fund according to the actual amounts of expenses incurred and fluctuations in the fund’s daily net assets. Information on the specific expenses for each of the mutual funds is set forth in the fund’s prospectus and periodic reports. Discounted Fees for Bank and Trust Companies Bank and Trust Companies can receive discounted pricing or complimentary subscriptions from third-party service providers or from AssetMark or its affiliates for services such as business consulting, practice management, technology, financial planning tools and marketing-related tools and services because of their participation in the Platform. In certain cases, AssetMark receives a portion of the subscription fees paid by the Bank and Trust companies to such third-party service providers. Discounted pricing and complimentary subscriptions can be subsidized by AssetMark. These arrangements create a financial incentive for the Bank and Trust Companies and their representatives to recommend that Clients invest assets through the AssetMark Platform. Payment for testimonials/endorsements Bank may provide video, audio or documented statements endorsing AssetMark, and AssetMark may compensate the Bank for these. The cost of advisory and investment management services provided through the Platform can be more or less than the cost of purchasing similar services separately. For example, direct investment in a mutual fund or ETF would be less expensive than investment in the same fund through the Platform, because the Bank Trust Client would not bear any Platform Fee. All mutual funds included in mutual fund strategies on the Platform will be available for purchase at each fund’s net asset value and with no sales charge, so that no sales commissions are incurred in connection with investment in the initial Portfolio and Portfolio rebalancing. While most mutual funds available through the Platform will charge no transaction fees, mutual funds or Custodians charge redemption fees under certain circumstances. Negotiated Fees AssetMark is permitted, in its discretion, to negotiate the Platform Fee for Clients of certain Bank and Trust Companies. Certain Bank and Trust Companies with higher aggregate levels of assets on the Platform are eligible for negotiated fees, which are passed through to their Client. The Bank and Trust Company does not earn additional compensation as a result of these negotiated fees. These arrangements create an incentive for Bank and Trust Company and their representatives to invest their Client Account through the AssetMark Platform. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 10 of 32 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION SELECTION AND REVIEW OF PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS PORTFOLIO STRATEGISTS Pilot and Early Release Programs AssetMark can invite certain Bank and Trust companies to participate in pilot or early release programs designed to solicit feedback on new product or service offerings. In exchange for participation in these programs, AssetMark may provide certain incentives to the Bank and Trust companies such as fee waivers, or other incentives. The Portfolio Strategists and Investment Managers used in Model and IMA Solution Types are selected for the Platform by AssetMark in order to make available a curated range of investment options and philosophies to the Bank and Trust Companies. The selection and due diligence process is described below. Each of the Portfolio Strategists provides to AssetMark a range of investment allocations that will correspond to some or all of the six Risk/Return Profiles, ranging from most conservative to most aggressive, as discussed above under “RISK/RETURN PROFILES”. Strategist Fees In circumstances where a Bank uses a Portfolio Strategist to assist in the management of a Client’s account, AssetMark will pay a strategist fee on a selected basis to the Bank for use and monitoring of the model portfolio recommended by the Portfolio Strategist. This strategist fee creates a conflict of interest because the Financial Advisory Firm has an incentive to use the model portfolios produced by a Portfolio Strategist in order to keep receiving the fee, compared to other arrangements that might be less expensive or more appropriate for the Client. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Through the bank channel, AssetMark will be able to hold accounts that are either taxable or non-taxable. The Portfolio Strategists use technical and/or fundamental analysis techniques in formulating their investment decisions to meet their targeted objective. Although each of the Risk/Return Profiles includes asset allocations developed by several Portfolio Strategists, each of the Portfolio Strategists nevertheless has its own investment style resulting in the use of different asset classes, and mutual fund, ETF, or investment management firm options within their asset allocations. Investment Strategies can be single asset class or multiple asset classes which may include, but are not limited to the following: • U.S. Equities: Large-Cap Growth, Large-Cap Value, Mid-Cap Growth, Mid-Cap Value, Small-Cap Growth, Small-Cap Value • International Equities: Developed Markets, Emerging Markets • Fixed Income: U.S. Core, High-Yield, Global, International, Emerging Markets If the Bank Client’s Account is an Individual Retirement Account (“IRA”) or subject to ERISA, the Financial Institution must inform AssetMark in writing, and the Bank Client agrees to be bound by the terms of the “ERISA and IRA Supplement to AssetMark Investment Management Services Agreement.” Unless expressly agreed to in writing, AssetMark does not serve as a trustee or plan administrator for any ERISA plan, and does not advise such plans on issues such as funding, diversification or distribution of plan assets. • Other: REITs, Commodities, Absolute Return Strategies, Hedging Strategies and other non-standard sectors including Alternatives • Cash. The objective is to provide Banks with a variety of Investment Strategies and approaches for accomplishing their Client’s investment objectives. The Bank should review each Portfolio Strategist’s investment style prior to selecting the Portfolio Strategist and Investment Strategy for the Client Account on the Platform. A Bank Client must deposit the Account minimum into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a managed Account until the Account balance reaches the required minimum. A Bank Client’s Account will be held by the Custodian in cash or in the assets transferred in-kind until such time as the value of the deposits to the Account reaches the required minimum for investment. If accounts are at AssetMark Trust, the cash balance will be invested in the AssetMark Trust’s ICD Program. The Bank Clients should be aware that a reasonable amount of time will be needed to purchase, redeem, settle and/or transfer assets, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. The Bank will assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet their clients’ financial needs. Investment Minimums - Account Size Portfolio Strategists will provide AssetMark with instructions to rebalance (to most recent Model Portfolio allocations) or to reallocate (to new Model Portfolio allocations), either periodically or as they deem appropriate over time, depending on their specific Investment Approach and investment process. These adjustments to the asset allocations will result in transactions in the Bank Client accounts. The Bank instructs and directs the Financial Institution that the Client’s account be invested in accordance with all rebalancing and adjustment instructions provided by the Portfolio Strategists unless the Financial Institution expressly terminates the rebalancing and adjustments and/ or executes written instructions to change the Strategy in which the account is invested. The Bank Client will receive notification of all account transactions in periodic account statements provided by the account Custodian. invest the Account, unless circumstances Investment Minimums are periodically reviewed and subject to change. AssetMark can, in its discretion, waive the Investment Minimum requirement from time to time. Accounts falling below the Investment Minimum can duly impair the ability to be fully invested in your selected model. It is also important to note that certain investment solutions are subject to a Minimum Account Fee, which might be charged when an account falls below the Investment Minimum. For example, this can occur when you make significant withdrawals from your account. Accounts below the Investment Minimum can be terminated by AssetMark after notice is provided to the Financial Advisor and/or the end investor. The Portfolio Strategists provide allocations based upon the corresponding risk profile determined by the Bank, by which AssetMark indicate intends to modified allocations or investments are appropriate. These allocation recommendations are implemented by AssetMark in Bank Client Accounts when they are received from the Portfolio Strategists and will result in transactions in the impacted Accounts. Portfolio Strategists will guide AssetMark with instructions to rebalance portfolios (return Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 11 of 32 back to policy mix) and/or reallocate (change the target mix), either periodically or as they deem appropriate over time, depending on their specific Investment Approach and investment process. which creates a potential incentive for AssetMark to choose one independent Investment Management Firm over another based on how advantageous that firm’s agreement is for AssetMark. SELECTION AND DUE DILIGENCE PROCESS FOR PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS Although some of the Portfolio Strategists creating portfolios comprised of mutual funds consider all of the mutual funds available under the Platform, certain Portfolio Strategists compose their mutual fund allocations utilizing those mutual funds managed by the Portfolio Strategist or an affiliate of the Portfolio Strategist. This creates a conflict of interest for these Portfolio Strategists, as discussed above. In addition, one or more of the Portfolio Strategists will construct their allocations. The Bank Clients should review prospectuses and consult with their Bank if they have questions regarding these Funds. Each portfolio strategist and investment manager complete a detailed questionnaire (“DDQ”) about their investment process, performance and reporting and risk management, in addition to covering business organization, compliance and ethics, operational framework, and client support. The DDQ is reviewed by AssetMark Due Diligence with compliance and ethics sections also being reviewed by AssetMark‘s compliance group. An external third party is used for operational due diligence review. AssetMark ‘s due diligence process is deep and thorough and focuses on five key P’s; People, Philosophy, Process, Portfolio Construction and Performance. Consistency in the first four explains performance so we spend most of our time understanding the qualitative and quantitative aspects of a manager and strategy and use performance as the confirmation of our understanding. The team seeks the following in the five key P’s: 1. People – stable and tenured teams that have experience managing through different market environments. 2. Philosophy – a philosophy that is clearly defined and articulated well. Understanding the foundations to the philosophy and how it has adapted over time is critical. 3. Process – a consistent application of the investment process. Demonstrating how investment decisions were made in multiple market environments and tying the decisions back to the philosophy. 4. Portfolio Construction – rigor in the risk oversight in building the portfolio. A clear discipline and process that shows how risk management is considered in the investment process. AssetMark makes available to the Bank factsheets of each investment solution managed by the Portfolio Strategists and Investment Managers. This includes a brief review of each firm, including key investment management personnel, strategy process, allocation shifts and performance metrics. The Bank can select more than one Portfolio Strategist and/or Investment Strategy for the Bank Client’s Accounts, and, as noted above, the Bank is free to change Portfolio Strategists, Investment Strategy or the mutual fund or ETF components of their Portfolios from time to time, though any change by a Bank in the components of a specific asset allocation used for a Bank Client’s Account will result in a custom portfolio for that Account which would no longer be automatically rebalanced along with the Portfolio Strategist’s rebalancing of its asset allocation. The Bank Client is free to consult with the Bank at any time concerning the portfolio, and AssetMark is available to consult with the Bank and their Client concerning the administration of the Platform. It is not anticipated that Bank will have the opportunity to consult directly with the Portfolio Strategists concerning their asset allocation Strategies, although the Bank will be provided with information concerning such Strategies and any updates or revisions to such information. For more information regarding specific Portfolio Strategists’ investment processes and philosophy, or to request a copy of a Portfolio Strategist’s Form ADV Part 2A Disclosure Brochure, a Bank Client should contact their Bank or AssetMark’s Compliance department at the address on the front cover of this Brochure. 5. Performance – the proof statement and purposefully last. The team’s evaluation of the other P’s builds up their expectations of how the strategy should perform. The actual results are used to confirm expectations and to demonstrate how the manager adds value over time. AssetMark negotiates agreements with each Portfolio Strategist separately and the terms of these agreements vary from firm to firm, which creates a potential incentive for AssetMark to favor one Portfolio Strategist over another based on how advantageous that firm’s agreement is for AssetMark. For more information regarding specific Portfolio Strategist’s’ investment processes and philosophy, or to request a copy of a Portfolio Strategist’s Form ADV Part 2A Disclosures Brochure, a Bank Client should contact the Bank or AssetMark’s Compliance department at the address on the front cover of this Brochure. INVESTMENT MANAGEMENT FIRMS AssetMark uses independent investment management firms (referred to as “Investment Managers” or “Discretionary Managers”) in the certain IMAs. For new searches, all findings are reported to the Due Diligence Investment Committee prior to being reviewed by the Investment Oversight Committee (“IOC”). Once selected for the Platform, the Due Diligence team conducts quarterly reviews via conference calls or in person to discuss, among other things, performance, changes to their investment process and philosophy and any material organizational changes at the firm. For ongoing monitoring all findings are reported to the Due Diligence Investment Committee on a quarterly basis, or sooner based on the significance of the findings. In the event of significant news occurring within a quarter, the Due Diligence team is in immediate contact with the Strategist or Investment manager to fully understand the impact of the news. If a change in status is warranted, an interim investment committee meeting will be held, and relevant action taken. Any strategists on non-satisfactory status are listed in a report that is available on eWealthManager and are reviewed with the IOC on a quarterly basis. independent AssetMark charges to Portfolio Strategists and IMA Managers that have been selected to participate on the Platform a one-time set up fee and an annual maintenance fee (which is typically tiered such that the fee will increase to the extent that Client Account assets invested in Model Portfolios and/or IMA Accounts managed by Portfolio Strategists and IMA Managers exceed certain thresholds) for performing certain functions, which may include administrative, investment and marketing operational, legal and compliance, The Investment Management Firms acting as Investment Managers or Discretionary Managers in their discretionary management capacity, and acting as the Investment Management Firms in their advisory capacity, depending on the Solution Type in question, are all referred to below as Investment Management Firms in the discussion of their selection and oversight. The selection and due diligence process is described below. AssetMark negotiates agreements with each independent Investment Management Firm separately and the terms of these agreements vary from firm to firm, Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 12 of 32 • take any and all actions on the Client’s behalf that the Discretionary Manager determines to be customary or appropriate for a discretionary investment adviser to perform, including the authority to buy, sell, select, remove, replace and vote proxies for securities, including mutual fund shares and including those advised by AssetMark or an affiliate, and other investments, for the Account, and to determine the portion of assets in the Account to be allocated to each investment or asset class and to change such allocations; • select the broker-dealers or others with which transactions for the Account will be effected; and • retain and replace, or not, any person providing services to the Discretionary Manager. REASONABLE RESTRICTIONS, PLEDGING AND WITHDRAWING SECURITIES functions, in connection with adding and maintaining the Portfolio Strategist or IMA Manager on the Platform. This creates a conflict of interest for AssetMark because it provides a financial incentive for AssetMark to favor Portfolio Strategists and IMA Managers who agree to pay the fee in order to participate on the Platform. AssetMark offers a Strategist Data Program through which Portfolio Strategists pay an annual fee to access reports that provide additional detail with respect to assets invested in the Model Portfolios maintained by Portfolio Strategists. AssetMark also offers a Strategist Engagement Program that provides Portfolio Strategists the ability to engage with AssetMark in connection with the support and maintenance of their Model Portfolios on the Platform, including event sponsorships and Strategist Data Program participation, for a bundled annual fee. The Programs described above create a conflict of interest for AssetMark because they provide a financial incentive for AssetMark to favor Portfolio Strategists who pay the fees to participate in the Programs. INVESTMENT AND TAX RISKS AssetMark allows reasonable investment limitations and restrictions when notified of such by the Bank. The Banks should understand that all investments involve risk (the amount of which vary significantly), that investment performance can never be predicted or guaranteed and that the value of their Client Accounts will fluctuate due to market conditions and other factors. Bank Clients who open Accounts by transferring securities instead of opening an Account with cash, should also understand that all or a portion of their securities will be sold either at the initiation of or during the course of management of their Accounts. The Bank Client is responsible for all of the tax liabilities arising from such transactions and is encouraged to seek the advice of a qualified tax professional. AssetMark does not provide tax advice. Bank Clients have the option to place restrictions against investments in specific securities or types of securities for their Account that are reasonable in light of the advisory services being provided under the different Solution Types offered on the Platform, understanding that any restrictions placed on an Account can adversely affect performance. Requests for such restrictions are reviewed by AssetMark to ensure that they are reasonable and will not unduly impair AssetMark’s ability to pursue the Solution Type and Strategy selected by the Bank for the Client. Bank Clients can also pledge the securities in their Account or withdraw securities from their Account (transfer in-kind to another Account or Custodian), but must do so by giving instructions in writing to AssetMark and AssetMark Trust. It is important to note that restrictions cannot be effected in certain investments or due to operational capabilities such as in a mutual funds, or at the sleeve level within a Multiple Strategy Account. Side-by-side management refers to managing accounts that pay performance fees (fees based on a share of capital gains on or capital appreciation of Account assets) while at the same time managing accounts that do not pay performance fees. AssetMark does not charge performance-based fees. Performance for the asset allocation models by the Portfolio Strategists, are calculated monthly using a time weighted methodology in InvestCloud (f/k/a Tegra118 and Fiserv) APL trading and portfolio management system. Performance results are shown on a net of fees basis. Composite performance is calculated using actual Client Accounts. Generally, investment Solutions move from a model-tracking portfolio to composite performance reporting when at least one Account is under AssetMark’s Referral Model and meets the minimum investment amount for the specific strategy at AssetMark in the previous quarter. Performance for IMA Investment Solutions is not calculated or reviewed by AssetMark due to the custom nature of these strategies. Investing in securities involves risk of loss that Bank Clients should be prepared to bear. VOTING CLIENT SECURITIES For Client level performance, the InvestCloud APL system is used to calculate a time weighted rate of return. Performance results are displayed to each Client daily, via eWealthManager.com, if selected by the Financial Advisor and more formally quarterly via Clients’ Quarterly Performance Review. ASSETMARK AS PORTFOLIO STRATEGIST OR INVESTMENT MANAGER AssetMark will not vote proxies for accounts receiving services through the Bank and Trust Channel. Bank will receive their proxies and other solicitations directly from the Custodian and AssetMark will not assist with voting responsibilities. In all instances Bank shall make any and all elections with regards to participation in class actions, notices regarding bankruptcies and similar elections. AssetMark also serves as the Portfolio Strategist and Investment Manager for certain Model and IMA Solution Types. Refer to Exhibit B – AssetMark Portfolio Solutions – Solution Types for more detailed information. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS INVESTMENT DISCRETION If a Bank selects an IMA Strategy for the Bank Client, the Bank Client’s information will be shared with the IMA Manager who has discretionary authority on the Account. Bank Client information will not be shared with Portfolio Strategists who provide asset allocation Strategies and have no discretion over the Account. If an IMA Strategy is selected for the Account by the Client and/or Financial Advisor, the Discretionary Manager accepts discretionary authority to manage the assets in the Client’s Account. The Client grants the Discretionary Manager the authority to manage the assets in their Account on a fully discretionary basis. The grant of discretionary authority to the Discretionary Manager includes, but is not limited to the authority to: Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 13 of 32 REVIEW OF ACCOUNTS On August 25, 2016, the SEC announced a settlement with AssetMark in an order containing findings, which AssetMark neither admitted nor denied, that AssetMark violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)-1(a)(5) by allowing its staff, from July 2012 through October 2013, to circulate to prospective Clients who were considering an F-Squared managed account service offered by AssetMark, performance advertisements created by F-Squared relating to a different separately managed account service not offered by AssetMark and which misleadingly described that different service’s performance between 2001 and 2008, and that AssetMark violated Section 204(a) of the Advisers Act and Rule 204-2(a)(16) by failing to maintain records substantiating the performance in the advertisements created by F-Squared. There are no disciplinary items to report for the management team of AssetMark. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS AssetMark is a direct subsidiary of AssetMark Financial Holdings, Inc. The following companies are under common control with AssetMark. These affiliations can create a material conflict of interest for AssetMark or its Clients. The industry activities of these affiliated companies are described in further detail below: • Atria Investments, Inc. (d/b/a Adhesion Wealth) AssetMark does not assign client accounts directly to specific individuals for investment supervision, and hence there is not a single individual or class of individuals within the organization that can be identified as being solely responsible for implementing a full set of review criteria on any one client account. Instead, AssetMark offers a platform of Solution Types to its clients, each of which is a model portfolio to which the client’s account is linked. A variety of teams within the organization then have responsibility for reviewing the application of the appropriate investment guidelines to each account. At the model level, two groups are responsible for ensuring that the investment models to which client accounts are linked are consistent with guidelines. AssetMark Due Diligence reviews those model recommendations provided by the Portfolio Strategists. AAM creates and monitors the model recommendations offered to clients within the proprietary investment strategies available on the AssetMark platform. Other groups within the organization monitor the degree to which individual client accounts adhere to the investment models monitored by AssetMark Due Diligence or created and monitored by AAM. These groups include Trade Operations, which monitors account adherence to models provided by third-party strategists and, adherence to models created and maintained by AAM. Finally, a group known as the Adviser Services Group (ASG) deals directly with the Bank to resolve any issues that might arise in the bank client’s own review of the account. • AssetMark Brokerage, LLC • AssetMark Services, Inc. • AssetMark Trust Company ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Adhesion Wealth Adhesion Wealth is a registered investment adviser with the U.S. Securities and Exchange Commission, currently providing sub- advisory services to other registered investment advisers, either directly or through a third party sponsored program. Together with their Financial Advisor, Clients invested in High Net Worth and IMA Strategies will have direct access to Investment Managers to discuss their Account. On the other hand, Clients who have selected Model Portfolios will not have access to the Model Provider or Portfolio Strategist. ITEM 9 – ADDITIONAL INFORMATION AssetMark Brokerage, LLC AssetMark Brokerage, LLC (“AssetMark Brokerage”) is a broker-dealer registered with the SEC and is a member of FINRA. DISCIPLINARY INFORMATION AssetMark Services, Inc. AssetMark Services, Inc. provides recordkeeping and administrative services to retirement plans. AssetMark Trust Company AssetMark Trust is an Arizona chartered trust company that serves as the Custodian for certain Accounts on the AssetMark Platform. AssetMark also has indirect affiliations with companies under GTCR. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Although not affiliated when AssetMark Trust contracted with the Program Administrator for services, AssetMark Trust and the Program Administrator, as described below in the FDIC-Insured Cash Program, are now under common ownership. Some employees of AssetMark are also shared with affiliated entities. This presents potential conflicts around the sharing of client’s personal information, trading practices, and supervision. To mitigate these conflicts, the Company has policies in place to supervise and monitor the activities of these shared employees. On September 26, 2023, the SEC issued an Order Instituting Administrative Cease-and-Desist Proceedings against AssetMark. The SEC alleged that, from at least September 2016 through January 2021, AssetMark failed to fully disclose that AssetMark and affiliate AssetMark Trust together set the amount of the payment that AssetMark Trust would retain as compensation from the payment received by the banks that participated in the FDIC-Insured Cash Deposit Program (“ICD Program”) (the “ICD Program Fee”), which, in turn, determined the amount that would be distributed as interest by the banks to clients. The SEC alleged that AssetMark had failed to fully disclose the associated conflicts of interest related to its role in setting the ICD Program Fee. The SEC also alleged that AssetMark, from at least January 2016 through August 2019, did not fully disclose the associated conflicts of interest related to AssetMark’s receipt of custodial support payments from certain no-transaction fee (“NTF”) mutual funds. These failures constituted breaches of AssetMark’s fiduciary duty to advisory clients. The SEC alleged that AssetMark violated Section 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 promulgated thereunder. AssetMark consented to the Order without admitting or denying the SEC’s findings. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 14 of 32 AFFILIATE SERVICES AND CONFLICTS OF INTEREST • Administrative Service Fees (“ASF’s”), which are not an expense to the shareholders of the fund. These are an expense to the mutual fund and are paid to Fidelity per an agreement between the mutual fund company and Fidelity; • Recordkeeping fees earned on ERISA plan account holdings; and • Transaction-based fees, which may or may not be expenses of the fund. AssetMark also holds fund shares directly, without using Fidelity as sub-custodian. In such a case, the fund or fund company can pay AssetMark Trust ASF’s directly. AssetMark Trust receives ASFs from Fidelity, banks and insurance companies, or from their respective service providers. Any such income received by AssetMark Trust is in consideration for services it provides. This amount, in the aggregate, is substantial, in consideration of the services provided by AssetMark Trust to these respective service providers and varies by mutual fund. These payments are used to offset the additional annual custody fee otherwise payable by IRA Clients and Clients with Accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). AssetMark Trust currently waives any portion of this IRA & ERISA Account Fee not offset by this income. Banking Institution - AssetMark Trust AssetMark Trust, an affiliate of AssetMark, is the only available Platform Custodian for this channel. AssetMark Trust is paid for custodial and brokerage services provided to Bank Client Accounts through the Platform Fee charged their Account and, where applicable, through additional fees. Pursuant to a contract between AssetMark and AssetMark Trust, AssetMark pays AssetMark Trust for services AssetMark Trust provides its custodial Clients. Additionally, AssetMark Trust receives payments from mutual funds, mutual fund service providers and other financial institutions for certain services AssetMark Trust provides related to investments held in the Bank Client Accounts. AssetMark Trust handles transfer agency functions, shareholder servicing, sub-accounting and tax reporting functions that these financial institutions would otherwise have to perform. Such payments are made to AssetMark Trust by these financial institutions based on the amount of assets invested in the Bank Client Accounts. Any such payments to the Custodian will not reduce the Platform Fee. Some mutual funds, or their service providers, provide compensation in connection with the purchase of shares of the funds, unless prohibited by law or regulation. CASH MANAGEMENT SERVICES OFFERED BY AFFILIATE Investment Companies - GuideMark Funds and GuidePath Funds The GuidePath Funds are directly managed by AAM and invested in unaffiliated mutual funds and ETFs. AAM manages the GuidePath Funds based on research provided by current Portfolio Strategists in each of the Investment Approaches. AssetMark’s Due Diligence team has ongoing oversight over the performance of the Sub-Advisers in the GuideMark and GuidePath Funds and the Portfolio Strategists on the Platform. The Bank Clients will be offered the following cash management services: FDIC-Insured Cash and CDARS Programs; and FDIC-insured checking accounts. AssetMark Trust does not directly provide these services; they are provided to AssetMark Trust Clients through third- party providers, and AssetMark Trust is compensated by the third parties. With the exception of the Cash Allocation (discussed below), these services are optional; Clients can opt out of the services or choose not to use them. ADMINISTRATIVE SERVICE FEES RECEIVED BY AFFILIATE AssetMark selects mutual funds used in their Solution Types and, generally, the mutual funds selected are institutional share class funds. However, if institutional share class funds are not available, a fund that includes a Rule 12b-1 fee can be selected. Although most mutual funds held by AssetMark Trust client accounts do not pay a 12b-1 fee, administrative service fee or similar income is paid with regard to most funds held by Bank Client Accounts. This income and variation in payments create conflicts because AssetMark Trust is paid this income, as described below. AssetMark Trust uses sub-custodians in fulfilling its responsibilities, including National Financial Services Corp., (whose affiliated broker- dealer, Fidelity Brokerage Services, LLC, also provides brokerage and clearing services for Bank Client Accounts), see below, Custodial Relationships. Fidelity operates as a sub-custodian for AssetMark Trust, and as sub-custodian Fidelity receives certain payments from investment companies for certain administrative and recordkeeping services. AssetMark Trust receives payments from Fidelity for the recordkeeping and other administrative duties performed by AssetMark Trust as Custodian. Because Fidelity operates as a sub-custodian for AssetMark Trust, Fidelity remits approximately 92.25% of such fees collected from these investment companies to AssetMark Trust in exchange for the custodial support services AssetMark Trust provides. If an AssetMark-advised fund, e.g., a GuidePath or GuideMark Fund, is used, Fidelity pays AssetMark Trust 100% of the payments. Below are the types of fees AssetMark Trust receives: FDIC-Insured Cash Program Cash Allocation in Accounts invested in Platform Strategies: A portion (the “Cash Allocation”) of all Bank Client Accounts invested in a Platform Strategy is placed in cash or a cash alternative investment. This Cash Allocation will be placed in AssetMark Trust’s Insured Cash Deposit (“ICD”) program and deposited in one of more banks insured by the Federal Deposit Insurance Corporation (“FDIC”), unless a money market mutual fund is required or requested. AssetMark has established the target Cash Allocation at 2% in part to defray the costs of providing the Platform and to help assure cash is available to pay Financial Advisor Fees and the Platform Fee. The interest your Account earns on the 2% Cash Allocation to FDID-Insured Cash is less then what typically would be earned on a money market fund. As discussed in more detail below, because of the revenue that AssetMark and its affiliate AssetMark Trust earn from the Cash Allocation, this is a conflict of interest. The target Cash Allocation is 2%, and the Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. Accounts enrolled in AssetMark’s Tax Management Service (“TMS)” are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives. In addition to the Cash Allocation, Client Account will also hold cash pending investment or distribution and these cash amounts will be invested in the ICD Program. Additionally, Funding Accounts will be invested in the ICD Program. (A Funding Account is used to receive cash and assets transferred in kind before sale or transfer to an advised Account.). You may opt out of the ICD Program for your Cash Allocation. If you opt out of the ICD program, your Cash Allocation will be invested in one • 12b-1s, which are a cost to the shareholders of the mutual fund. If the prospectus of a mutual fund allows for 12b-1 fees to be paid for either “distribution” or “service,” it will be included in the fund’s expenses and deducted from the income the mutual fund earns. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 15 of 32 or more money market mutual funds. Cash that is not yet in a sweep vehicle (due to trading activity, residuals or new cash in a funding account) will simply be held in cash until swept to the ICD Program or money market mutual fund, when cash is moved from the funding to managed account, or typically by the following business day. the part of AssetMark Trust and AssetMark; the greater the Program Fee AssetMark Trust receives – which is determined by AssetMark Trust in consultation with AssetMark -- the lower the interest rate paid to Bank Clients. In certain interest rate environments, the Program Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Program Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. The gross interest rates paid by each Program Bank, which affects the interest rates paid in the FDIC-Insured Cash Program, do and are expected to vary from Program Bank to Program Bank; this creates a conflict for AssetMark Trust when selecting Program Banks in that it incentivizes AssetMark Trust to select the banks that pay higher interest rates. No part of the Program Fee is paid to Bank or Financial Advisors. Neither AssetMark nor AssetMark Trust share any revenue from the Program with individual AssetMark employees, Financial Advisory Firms who use our Platform, or Financial Advisors who provide advice to clients with Accounts on our Platform. This is a mitigation against the conflict of interest relating to the fees and revenue AssetMark Trust (and AssetMark, Inc. as an affiliate) earn from the Program. Administrative Accounts: If a Bank selects an Administrative Cash Account for an Account, all of the Administrative Cash Account will be placed in the ICD Program, unless the amount of the deposit qualifies for, and the Bank elects, the High Yield Cash Program, which is also part of the FDIC Insured Cash Program but one in which the interest rates credited are expected to be higher than those credited ICD Program deposits. The interest rate paid on the High Yield Cash program can be negotiable. General Securities Accounts (“GSAs”) may also hold FDIC-Insured Cash Program Funds. The Bank may also opt out of the FDIC-Insured Cash Program, in which case the bank account will be invested in one or more money market funds. Although there is no Platform Fee for Administrative Cash Accounts with deposits in the FDIC-Insured Cash Program, if the cash is deposited in the ICD Program and not the High Yield Cash Program, then those assets can be aggregated with assets in other Client Accounts with AssetMark for “householding” purposes, which aggregation should result in larger aggregate balances that can reduce the rate(s) of the Platform Fee(s) applicable to other Client Account(s). Deposits in the High Yield Cash Program, however, will not be aggregated with other AssetMark Client Account assets for fee householding purposes. You should determine if you would prefer the higher interest rate(s) offered by HYC or the lower fees available through “householding.” The Program Fees paid to AssetMark Trust can be greater or less than compensation paid to other Platform Custodians with regard to cash sweep vehicles. The interest rate Program Deposits earn with respect to the AssetMark Trust FDIC-Insured Cash Program are expected to be lower than interest rates available to depositors making deposits directly with a Program Bank or with other depository institutions. Program Banks have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Program Bank. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest and other rates available the market, including money market mutual fund rates. Fees on Advised Accounts and Conflicts of Interest: The Platform Fee is assessed on 100% of the value of Account assets invested in Platform Strategies upon initial investment and, thereafter, at the end of each calendar quarter, even though the Cash Allocation, cash pending investment or distribution portions of the Account do not receive any investment advisory or brokerage services. (They do receive administrative and custodial services.) In some low interest-rate environments, the Financial Advisor Fee plus Platform Fee can exceed the amount of interest paid on the Cash Allocation. It is anticipated that, when looked at jointly, AssetMark Trust and AssetMark will receive more compensation on the Cash Allocation and cash pending investment or distribution portions of Accounts invested in the ICD Program than on Account assets invested in the Accounts’ investment Strategy. If an Account’s cash is invested in a money market mutual fund (because, for example, the Account opted out of the FDIC-Insured Cash Program, AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Program Fees it receives from Program Banks in the FDIC-Insured Cash Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers and that has been its recent experience. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Program Fee from Program Banks than the service fee from money market mutual funds. Bank Client participation in the FDIC-Insured Cash Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust receives compensation from the Program Banks for the record keeping and administrative services it provides in connection with maintaining the FDIC-Insured Cash Program (the “Program Fee”). The interest rates paid Bank Client Accounts under the FDIC-Insured Cash Program are determined by AssetMark Trust, in consultation with AssetMark, and are based on the interest rates paid by the Program Banks, less the Program Fees paid to AssetMark Trust by the Program Banks. In determining the interest rates paid Client Accounts, AssetMark Trust and AssetMark also consider other factors, including the rates paid by competitors. The Program Fees paid to AssetMark Trust can be up to 4% on an annualized basis viewed on a rolling twelve-month basis, and across all Deposit Accounts. The amount of the Program Fee paid to AssetMark Trust and Administrative Fee paid to the third-party Program Administrator reduce the interest rate paid on Client Program Deposits. AssetMark Trust has discretion over the amount of its Program Fee, and AssetMark Trust reserves the right to modify the Program Fees it receives from Program Banks. This discretion in setting the Program Fee creates a conflict of interest on CDARS Program for Certificates of Deposits In addition to the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts), AssetMark Trust makes available to its custodial client a Certificate of Deposit Account Registry Service® (“CDARS”) Program that allows a depositor to deposit amounts in Certificates of Deposit (“CDs”) at one or more depository institution insured by the Federal Deposit Insurance Corporation (“FDIC”). Deposits in the CDARS Program are deposited through a network of individual “Destination Institutions” unaffiliated with AssetMark Trust. Subject to the satisfaction of certain conditions, these deposits are eligible for FDIC insurance up to the maximum amount permitted by the FDIC, currently $250,000 for all deposits held at each Destination Institution in the same legal capacity. AssetMark Trust is not a depository institution and does not issue or offer CDs. There is no Platform Fee is assessed on the CDs held in a GSA. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 16 of 32 Conflicts of Interest: Funds in which these Accounts invest. The fees differ between Funds and the total fees collected will vary depending upon the profile selected by the Bank and the fund allocation within each profile. If a Bank elects the GPS Fund Strategies for the financial institution client, the Financial Institution authorizes and instructs that the Account be invested pursuant to the selected profile, acknowledges that fund advisory and other fees collected by AssetMark will vary, and approves of the fee payments to AssetMark. The Client will be given prior notice if these allocations or mutual funds change resulting in fee payments and, unless the Client or the Financial Advisor gives notice to AssetMark, the Client consents to these changes. If a Financial Institution selects GPS Select for the Financial Institution Client Account, the Financial Institution authorizes and instructs that the Account be invested pursuant to the selected profile and acknowledges that AssetMark is permitted to modify Fund allocations within a range such that fund management fees earned by AssetMark can vary within a range of 0.30% of the assets in the Strategy. The Financial Institution approves fund allocations within this range and acknowledges the Financial Institution will not receive prior notice of the fund allocation changes unless such allocations would exceed the 0.30% range. For more information regarding the fees collected by AssetMark when using these Strategies, refer to the allocation tables provided in Exhibit C at the end of the Disclosure Brochure. INCENTIVE COMPENSATION Bank Client participation in the CDARS Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust receives compensation from the Destination Institutions for the placement of deposits in CDs through the CDARS Program (the “Placement Fee”). (The third-party administrator of the CDARS Program also receives a fee (“CDARS Administrative Fee”) from the Destination Institutions.) AssetMark Trust, in consultation with AssetMark, determines the amount of its Placement Fee, and the Placement Fee reduces the interest rates paid by the Destination Institutions on the CDs under the CDARS Program, as does the CDARS Administrative Fee paid to the third-party CDARS Program Administrator. In determining the Placement Fee, AssetMark Trust and AssetMark consider a number of other factors, including the rates paid on CDs in competitor programs. The Placement Fees paid AssetMark Trust can be up to 4% on an annualized basis viewed on a rolling twelve-month basis across all CDs. AssetMark Trust has discretion over the amount of its Placement Fee, and AssetMark Trust reserves the right to modify the Placement Fees it receives from Destination Institutions. This discretion in setting the Platform Fee creates a conflict of interest on the part of AssetMark Trust and AssetMark; the greater the Placement Fee AssetMark Trust receives -- which is determined by AssetMark Trust in consultation with AssetMark -- the lower the interest rate paid to Clients on CDs. In certain interest rate environments, the Placement Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Placement Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. No part of the Placement Fee is paid to Financial Advisors. Certain AssetMark associates, typically sales associates, are eligible to receive compensation pursuant to a Sales Incentive Plan (“SIP”). Payments under a SIP are based on meeting certain production goals in support of AssetMark’s long-term growth strategy and profitability but are not based on specific product offerings. Financial Institutions, not AssetMark associates, are responsible for a Financial Institution Client’s suitability and/or investment recommendations. AssetMark can also provide additional incentives for affiliate (Adhesion Wealth Services) program referrals or to promote services, e.g. tax management services. Certain AssetMark associates are also eligible to receive. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING The Bank provides investment advisory services to the bank client. The following summary describes the Code of Ethics for AssetMark, as the Platform sponsor. The Placement Fees paid to AssetMark Trust can be greater or less than compensation paid to other custodians for similar services. The interest rate CDs earn with respect to the CDARS Program offered through AssetMark Trust can be lower than interest rates available to depositors making deposits directly with, or purchasing CDs directly from, a Destination Institution or other banks or depository institutions. Destination Institutions have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Destination Institution. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest on CDs and other rates available the market, including money market mutual fund rates. In addition to CDs, AssetMark Trust custodial clients may invest cash in the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts) and/or money market mutual funds. If an Account’s cash is invested in a money market mutual fund, AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Placement Fees it receives from Destination Institutions in the CDARS Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Placement Fee from Destination Institutions than the service fee from money market mutual funds. AFFILIATE FEE INCOME AND ASSOCIATE CONFLICTS DISCLOSURE GPS Fund Strategies and GPS Select Bank Client Accounts invested in these Strategies will receive allocations, determined by AssetMark, among AssetMark ‘s Proprietary Funds. AssetMark receives fees from the Proprietary AssetMark has adopted a Code of Ethics (the “Code”) that is intended to comply with the provisions of Rule 204A-1 under the Advisers Act, which requires each registered investment adviser to adopt a code of ethics setting forth standards of conduct and requiring compliance with federal securities laws. Additionally, the Code is designed to comply with Section 204A of the Advisers Act, which requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by any person associated with such investment adviser. The Code requires that all “Supervised Persons” (including officers and certain affiliated persons and employees of AssetMark) in carrying out the operations of AssetMark, adhere to certain standards of business conduct. Specifically, the Code requires that these persons: (i) comply with all applicable laws, rules and regulations; (ii) avoid any conflict of interest with regard to AssetMark and its Clients; (iii) avoid serving their personal interests ahead of the interests of AssetMark and its Clients; (iv) avoid taking inappropriate advantage of their position with AssetMark or benefiting personally from any investment decision made; (v) avoid misusing corporate assets; (vi) conduct all of their personal securities transactions in Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 17 of 32 compliance with the Code; and (vii) maintain, as appropriate, the confidentiality of information regarding AssetMark’s operations. not charge Client Accounts transaction based fees or commissions for its execution service. In certain circumstances, better execution could be available from broker-dealers other than the broker-dealer(s) generally used by the Client’s Custodian. AssetMark, or other Discretionary Manager is permitted to trade outside the selected broker-dealer(s). For Accounts custodied at AssetMark Trust, AssetMark, or the Discretionary Manager as applicable, can combine purchase and sale transactions for a security into a single brokerage order. By combining the purchase and sale transactions into a single brokerage order, Clients that are buying a security will receive the same average price as Clients that are selling the same security and Clients selling will receive the same average price as Clients that are buying the same security, based on the single net order placed by AssetMark. This aggregation process could be considered to result in a cross transaction among affected Client Accounts. The Code contains a number of prohibitions and restrictions on personal securities transactions and trading practices that are designed to protect the interests of AssetMark and its Clients. First, the Code prohibits trading practices that have the potential to harm AssetMark and/or its Clients, including excessive trading or market timing activities in any Account that AssetMark manages, trading on the basis of material non-public information, and trading in any “Reportable Security” when they have knowledge the security is being purchased or sold, or is being considered for purchase or sale by the Accounts managed by AssetMark or any AssetMark-advised mutual funds. Second, the Code mandates the pre-clearance of certain personal securities transactions, including transactions in securities sold in initial public offerings or private placements. The Code also requires the pre-clearance of Reportable Security transactions for certain Access Persons (“Access Persons” is a segment of the Supervised Persons group that have access to AssetMark pre-trade information). Finally, the Code requires Access Persons to submit, and the Chief Compliance Officer (the “CCO”) to review initial and annual holdings, and quarterly transaction reports. AssetMark utilizes StarCompliance to provide enhanced tracking of certain employee transactions and gives AssetMark the ability to analyze those employee trades against certain parameters and transactions in its managed Accounts or any Proprietary Funds. Access Persons also utilize this system to annually certify their receipt of, and compliance with, the Code and pre-clear their Reportable Security transactions, if they are required to do so by the Code. Clients should be aware that the arrangement that AssetMark Trust has with Fidelity described above creates a financial incentive for AssetMark to utilize that broker-dealer regardless of execution quality, in order to avoid incurring the charges that accompany trading with other broker- dealers. This incentive creates an actual or potential conflict of interest to the extent that AssetMark utilizes Fidelity to execute trades for Client Accounts when higher quality execution might be available through other broker-dealers. However, in fulfilling its fiduciary obligations, AssetMark evaluates the execution quality received by Clients at their selected Custodians on a periodic basis. Any execution trends over a period of time are researched and discussed at AssetMark’s quarterly Execution Review Committee meeting. In addition, some investment solutions that have historically only been available at AssetMark Trust, are now available at other Custodians. All Supervised Persons under the Code are responsible for reporting any violations of the Code to the CCO. The Code directs the CCO to submit reports to the Board of Trustees of any AssetMark-advised mutual funds regarding compliance with the Code, and to impose sanctions on violators, as warranted. AssetMark will provide a copy of the Code to any Bank and Trust Companies or prospective Bank and Trust Companies upon request. BROKERAGE PRACTICES TRADE EXECUTION AND BROKERAGE ALLOCATION Trading is directed by and is the responsibility of AssetMark or the Discretionary Manager, if applicable. Subject to the Bank’s chosen Solution Type and Strategies for the Bank Client Account, AssetMark or the Discretionary Manager gives instructions for the purchase and sale of securities for Bank Client Accounts. AssetMark or the Discretionary Manager selects the broker-dealers or others with which transactions for Bank Client Accounts are effected. There is often an additional charge by the Platform Custodian, if AssetMark or the Discretionary Manager, as applicable, determines to trade away from the selected brokerage firm. ETFs are traded daily at market determined prices on a national exchange in a similar manner to individual equity securities. Although ETFs are priced intra-day in the same manner as equity securities, the actual timing of trade order execution varies, depending upon trade volume, systems limitations and issues beyond AssetMark’s control, and the actual fulfillment of trade orders by the broker in the market can take place at different prices and different times throughout the day. AssetMark submits ETF trades for a given day to each broker in a random order, or simultaneously where possible, to provide the most feasibly equivalent execution for all participating Clients. On days with heavy trade volumes, AssetMark can utilize “not held” and/or “limit order” instructions in an attempt to reduce market impact on the price received for the security. When a Portfolio Strategist implements a reallocation adjustment or rebalance to its ETF strategy, and/or in the case of exceptionally high volume requests, AssetMark can utilize an alternate agency broker or an “authorized participant” liquidity provider selected by AssetMark to execute orders for Clients at multiple custodians, and then “step out” those trades to those custodians on a net fee basis. AssetMark also seeks and can rely upon a Portfolio Strategist’s recommendation for stepping out to an alternative broker when executing the Portfolio Strategists reallocation. There are no separate fees charged for ETF trades that are stepped out to an alternate broker, unless in the case of a broker trading on an agency basis, in which case their flat fee will be included in the execution price. On a quarterly basis, AssetMark’s Execution Review Committee will review the step out trade activity in the Accounts. AssetMark receives Model Portfolios or trade recommendations from Strategists on a non-discretionary basis. There can be instances in which the policy of a specific Strategist or Discretionary Manager is to effect trades in the Accounts of their discretionary Clients before delivering Model Portfolios to non- discretionary Clients. AssetMark or the Discretionary Manager, if applicable, will generally direct most, if not all transactions to the Platform Custodian. Trades are bundled by Custodian in trading blocks and submitted for execution on a pre-determined randomized rotation, or through simultaneous submission to all Custodians. In addition, if the selected Custodian is AssetMark Trust, generally most, if not all transactions will be directed to Fidelity Brokerage Services, LLC, and/or National Financial Services, LLC (collectively and individually “Fidelity”) or other broker-dealers selected by AssetMark, and contracted with by AssetMark Trust, in view of their execution capabilities, and because the selected broker- dealer(s) is paid by AssetMark or AssetMark Trust and generally does Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 18 of 32 ACCOUNT LIQUIDITY RESERVE than 10 days after receipt of mailed Account Statements, trade confirmations and other notices and confirmations of information or the electronic posting of such documents. Not all Solution Types are offered at all Custodians. The AssetMark Platform provides access to the following Platform Custodian for the Bank Trust Channel: • AssetMark Trust, an Arizona trust company and affiliate of AssetMark, 3200 North Central Avenue, Seventh Floor, Phoenix, Arizona 85012. Its mailing address is P.O. Box 80007, Phoenix, Arizona 85060. To properly maintain cash flows for Client needs, a portion of all Client Accounts invested in a Strategy is maintained in a short-term investment vehicle. This liquidity reserve (or “Cash Allocation”) is generally referred to as the Custodian’s cash “sweep” vehicle. The Cash Allocation target is 2%, and an Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. (Note: Accounts enrolled in AssetMark’s Tax Management Service (“TMS)” are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives.) • On an exception basis, AssetMark can allow for the selection of a Platform Custodian not listed above. The assets of each Client Account are custodied at a Platform Custodian, and each Client must contract separately with their selected Platform Custodian for custodial services. Payment for the custodial and brokerage services provided by the Platform Custodian to the Account are included in the AssetMark Platform Fee. Refer to “Custodial Account Fees and Servicing Costs” below, for more information on what is included in the Platform Fee. The Client authorizes the Custodian to debit Platform Fees from the Account. The sweep vehicle for the Cash Allocation will differ by the Custodian and Strategy selected by the Client. At AssetMark Trust, it is usually AssetMark Trust’s Insured Cash Deposit (“ICD”) Program but depending upon the Strategy selected for the account, could be a money market mutual fund or other short-term pooled investment vehicle. Additionally, an AssetMark Trust Client can opt out of the ICD Program for the Account’s Cash Allocation, in which case the Account will be invested in one or more money market funds (see FDIC-Insured Cash Program, above). DELIVERY OF FUND REDEMPTION PROCEEDS All Client Accounts are separately maintained on the records of the Client’s selected Custodian. With regard to AssetMark Trust, Client funds and securities are typically held in omnibus accounts at various banks, broker-dealers and mutual fund companies. The holdings of these omnibus accounts reflect book-entry securities, which AssetMark Trust allocates to the individual Client Accounts on its own records. AssetMark Trust uses sub-custodians in fulfilling its responsibilities, including National Financial Services Corp., (whose affiliated broker-dealer, Fidelity Brokerage Services, LLC, also provides brokerage and clearing services for Client Accounts), and JP Morgan Chase (f/k/a Bank One). Mutual funds are included in some Client Accounts. Under certain economic or market conditions or other circumstances, mutual funds pay redemption proceeds by an in-kind distribution of securities in lieu of cash. Mutual funds, broker-dealers or transfer agents can experience delays in processing orders, or suspend redemptions or securities trading under emergency circumstances declared by the SEC, the New York Stock Exchange or other stock exchanges or regulatory agencies. RECEIPT OF EXECUTION REPORTS AssetMark does not utilize soft dollars by directing trades to broker- dealers and accumulating soft dollar credits. AssetMark receives execution reports from vendors such as Abel Noser and Fidelity, which it uses to review best execution of trades on the Platform. AssetMark does not pay directly for these reports. The Client’s asset-based Platform Fee, which includes custody, does not vary depending on whether AssetMark receives these execution reports or not. CUSTODIAL RELATIONSHIPS The Client, with the assistance of their Financial Advisor, shall select a Custodian for their Account. The Custodian selected by the Client shall send periodic account statements detailing the Client’s individual Account(s), including portfolio holdings and market prices, all transactions (such as trades, cash contributions and withdrawals, in-kind transfers of securities, interest and dividend or capital gains payments) for each individual Client Account, and fee deductions. The Custodian will also provide full year-end tax reporting for taxable accounts and fiscal year-end reporting for Accounts held for tax-qualified entities; and access to electronic or web-based inquiry system that provides detailed information on each Client’s Account, on a daily basis. Additionally, Clients can inquire about their current holdings and the value of their Accounts on a daily basis by electronic or web-based access. The Custodian can also send a Transaction Acknowledgement to the Client for all cash contributions, withdrawals and in-kind transfers as they occur. Although Clients usually waive receipt of individual transaction confirmations, a Client can elect, by written request to their Custodian, to receive a confirmation of each security transaction and such confirmations will thereafter be provided. A Client can incur termination fees from another custodian when transferring their account to ATC. ATC can elect to reimburse these termination fees to the Client. This arrangement can be deemed to cause a conflict of interest because they provide Financial Advisory Firms and Financial Advisors and their Clients with incentives to place Client assets with ATC, and ATC and AssetMark can earn more revenue. AssetMark does not provide custodial services to its Clients. AssetMark is determined to have custody of client funds in accordance with the SEC’s Custody Rule given the affiliation between AssetMark and AssetMark Trust, the qualified custodian of the Advisor’s clients’ assets. Given this determination, AssetMark will engage an independent public accountant to conduct an annual, independent surprise audit of client funds and securities. Client assets are held with banks, financial institutions or registered broker-dealers (“Platform Custodians” or “Custodians”) that are qualified Custodians under Advisers Act Rule 206(4)–2. Clients will receive custodial account statements directly from their selected Platform Custodian at least quarterly. Clients are urged to carefully review those statements. The Client agrees to review all Account Statements, trade confirmations and other notices and confirmations of information and promptly notify AssetMark of any errors within 10 days. AssetMark shall not be liable for any losses due to errors that remain unreported for more The Custodians will mail a letter of acknowledgement confirming the establishment of an Account and receipt of assets, to the Account’s address of record. Clients are strongly encouraged to review all statements, acknowledgements and correspondence sent by the Custodian. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 19 of 32 CUSTODIAL ACCOUNT FEES AND SERVICING COSTS shareholder reports, proxies and other shareholder materials for Accounts invested in a Mutual Fund Strategy or Guided Portfolios, i.e., GPS Fund Strategies or GPS Select. The Client is entitled to receive materials related to a Proprietary Funds advised by AssetMark. FINANCIAL INFORMATION In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition in this Item. AssetMark has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has never been the subject of a bankruptcy proceeding. The Platform Fee is a “wrap” fee and includes payment for advisory, administrative, custodial and brokerage services. AssetMark pays each Platform Custodian to provide custodial and brokerage services to Client Accounts. Clients do not pay transaction fees on any trades made in the Solution Types available on the Platform, unless described in the separate Custody Agreement with their selected Custodian. There are some Solution Types that do incur additional fees at the Custodian, such as fixed-income solutions or those that hold alternative or option products. Additionally, AssetMark Trust charges an annual Administrative Custody Fee of $25.00 and reserves the right to waive this fee at its discretion. ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS Not applicable to AssetMark as the Platform sponsor. Each Client will enter a custodial agreement with their selected Custodian and be provided a fee schedule or schedule of charges. Refer to the Custody Agreement or schedule of charges for specific fees applicable to the Client Account that are not included in AssetMark’s Platform Fee. For example, the Custodians can also charge termination fees and various other miscellaneous fees for wires, returned checks and other non-standard activity on an Account such as fees for alternative investments. Custody fees can also apply to Accounts in Solution Types that are either closed or no longer offered to new Clients. As well, for some legacy strategies on the AssetMark Platform no longer available to new investors, AssetMark continues to use retail share classes. All custody fee details are clearly presented in each Custodian’s fee schedule and separate custody agreement. AssetMark has negotiated with each Platform Custodian the compensation that AssetMark will pay the Custodian for providing custodial and brokerage services to Client Accounts. AssetMark provides third-party Platform Custodians with significant support services with respect to the custodial services that the Custodians must perform, including, for example, reviewing new Account paperwork and communicating with Financial Advisors to resolve incomplete custodial paperwork. These Services are taken into consideration when AssetMark and each Custodian negotiate the compensation that AssetMark will pay the Custodian for providing custodial and brokerage services to Client Accounts. The amount of the compensation that AssetMark pays differs between Custodians. Additionally, AssetMark generally receives more revenue when Clients choose AssetMark Trust as their Custodian. These differences in payments and revenue create conflicts of interest for AssetMark. AssetMark addresses these conflicts by having the same Platform Fee apply regardless of the Custodian chosen and by allowing the Client to choose their own Custodian, which can be AssetMark’s affiliated Custodian, AssetMark Trust. Although the Platform Fee is the same among Custodians, different fees for incidental expenses can apply. Pursuant to the services agreement between AssetMark and AssetMark Trust, AssetMark reallocates expenses for non-advisory services that AssetMark provides to AssetMark Trust. These services are primarily administrative in nature, all of which are provided by AssetMark for the benefit of all affiliates, including AssetMark Trust. PROSPECTUSES & OTHER INFORMATION The Client designates AssetMark, or the applicable Discretionary Manager, as their agent and attorney-in-fact to obtain certain documents related to securities purchased on a discretionary basis for their Account. If the Client selects AssetMark Trust as their Custodian, Clients waive receipt of prospectuses, shareholder reports, proxies and other shareholder documents. This waiver can be rescinded at any time by written notice to AssetMark. Clients that select a Custodian other than AssetMark Trust, i.e., PAS, or Fidelity elect to receive prospectuses, Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 20 of 32 EXHIBIT A – SOLUTION TYPES – MODEL PROVIDERS AND INDIVIDUAL MANAGED ACCOUNTS ASSETMARK PLATFORM MODEL PORTFOLIOS INDIVIDUALLY MANAGED ACCOUNTS PROPRIETARY 3RD PARTY PROPRIETARY 3RD PARTY GPS Fund Strategies Acadian 4 AssetMark Custom HNW City National Rochdale (HNW) GPS Select1 AlphaSimplex CIBC (HNW) Guided Income Solutions2 Clark PUMA (HNW) Algorithmic Investment Models (former Beaumont) Market Blend - Global William Blair (HNW) Market Blend - US AllianceBernstein4, 5 Parametric - Custom MarketDimensions BlackRock4, 5 Fixed-Income OBS DFA/EFS Portfolios Brown Advisory 4, 5 Parametric Savos Fixed Income - Laddered Bonds WealthBuilder Capital Group (American Funds) 4 Capital Group AssetMark Asset Builder Dorsey Wright Clark AssetMark Personal Values DoubleLine3 Nuveen AssetMark Income Builder Federated-Hermes 4 I Savos Preservation Fiera Capital 4 Savos GMS/PMP1 First Trust Savos USRC Franklin Templeton 4 Savos Personal Portfolios1 Hartford (Wellington) 4 GuidePath Managed Futures3 JP Morgan 4 Julex6 S N O T U L O S T N E M T S E V N I Kensington Logan 4 Morningstar4 New Frontier Nuveen5 Neuberger Berman3, 4 PIMCO Principal (Principal Edge) 4 State Street Stone Ridge 3 VanEck WestEnd William Blair 4 FINANCIAL ADVISOR CUSTOM ACCOUNTS¹ Multi-Strategy Account (MSA) Custom GPS Select Custom Savos GMS and PMP OTHER SERVICES AND NON-MANAGED ACCOUNTS Administrative Accounts General Securities Account ICD and High Yield Cash INVESTMENT VEHICLES closed-end mutual funds; open-end mutual funds; ETFs, alternatives, stocks, fixed income, bonds, options, preferred stocks; treasury bonds, bills and notes, bank notes. ¹ Financial advisor can customize this Model Portfolio to more closely reflect the Client’s specific needs or preferences 2 Goal or target-based Solution 3 Individual Mutual Fund or Model Provider offers at least one Individual Mutual Fund solution 4 Offers at least one equity model; used in SMA Program 5 Offers at least one ESG model 6 Closed to new business Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client  Page 21 of 32 EXHIBIT B – ASSETMARK ASSET MANAGEMENT – SOLUTION TYPES Strategies are available with or without an exposure to alternative investment mutual funds. With the assistance of the Bank, the Bank Client’s selected GPS Fund Strategy will take into account the Bank Client’s investment objective, if the Bank Client is in an accumulation or distribution phase, if the Bank Client seeks to have exposure to alternative investments or not, or seeks to use GPS Fund Strategies as a focused strategy in order to complement other Solution Types selected for the Bank Client Portfolio. AssetMark Asset Management (“AAM”) serves as the Portfolio Strategist and Investment Manager for the proprietary Models and IMA Solution Types described below. AAM can exercise its discretion by making investment decisions that are tailored to one specific proprietary solution and not applicable to all proprietary solutions on the Platform. Investment Objective: Accumulation vs. Distribution. MODEL PORTFOLIOS Guided Portfolios • GPS Fund Strategies Accumulation Objective. An accumulation objective typically refers to investors who are still working and seeking to build their wealth base. A blended mix of Investment Strategies with an emphasis on growth of capital is used. • GPS Select Mutual Fund Solution Types • Market Blend (GuideMark Funds) • OBS/DFA • AssetMark Asset Builder Distribution Objective. A distribution objective typically refers to investors who are in or near retirement and seeking to take withdrawals from their asset base over time. A blended mix of Investment Strategies with an emphasis toward providing income with a secondary objective of growth of capital is used. • AssetMark Personal Values • AssetMark Income Builder Exchange-Traded Fund (“ETF”) Solution Types • MarketBlend Focused GPS Fund Strategies. Focused GPS Fund Strategies provide a means for Clients to access pre-set strategies based primarily on the Client’s risk profile and their desire for focused exposure to one or more Investment Strategies used to complement other Solution Types selected for the Client Portfolio. Mutual Fund/ETF Blend Solution Types • WealthBuilder • MarketDimensions Core Markets Focused. Strategies seek to provide exposure to growth of capital markets and are generally allocated to Core solutions blending a mix of equities and bonds. Savos Solution Types • IMA Accounts, (Equity Balanced, Fixed-Income, and Custom High-Net Worth) Tactical Focused. Strategy seeks to provide flexible exposure to the equity market dependent on risk environment and for defensive equity exposure. • Savos Preservation Strategy • Savos GMS Accounts Tactical-Low Volatility Focused. Strategies seek to provide flexible exposure to the equity market alongside flexible bond exposures in a blended mix. • Savos PMP Accounts • Savos US Risk Controlled Strategy, and • Savos Personal Portfolios Low Volatility Focused. Strategy seeks to provide a low correlation to equities with low volatility experience similar to bonds for risk management purposes. I. GUIDED PORTFOLIOS GPS Fund Strategies Multi-Asset Income Focused. Seeks to provide a blend of income and growth, and depending on the profile. A core position in the GuidePath Multi-Asset Income Fund is held with complementary exposure to GuidePath Growth Allocation, Tactical Allocation and Absolute Return. GPS Select For GPS Fund Strategies, AssetMark will provide investment allocations across Investment Strategies based on investment objectives, market outlook, risk profile and other preferences. As of the date of this Brochure, the GPS Fund Strategies primarily utilize NTF mutual funds advised by AssetMark, the GuidePath Funds. AssetMark advised mutual funds, including the GuidePath Funds, are collectively known as “Proprietary Funds. For GPS Select, AssetMark will provide investment allocations across Investment Approaches based on investment objectives, market outlook, risk profile and other preferences. Additionally, AssetMark will select the mix of Portfolio Strategists and Investment Managers, including AAM Solutions and Proprietary Funds. AAM starts with a baseline allocation across Investment Strategies; however, these allocations will tilt over time based on their view of the risk environment. AssetMark is compensated by the Proprietary Funds for its advisory services provided to the Proprietary Funds. The Platform Fee for the GPS Fund Strategies is lower than that charged for strategies with third party funds. The Platform Fee for the GPS Fund Strategies does not include a charge for advisory services but pays for custodial, trading, administrative and other services. GPS Select will invest in Strategies which include investments in both mutual funds and ETFs. Mutual fund share class is selected on a fund by fund basis and seeks to utilize institutional share classes. Some mutual funds have both institutional share classes, which do not charge fund shareholders 12b-1fees but which typically do charge fund shareholders for shareholder servicing or sub-transfer agent fees, and retail share classes, which charge fund shareholders AAM starts with a baseline allocation across Investment Strategies; however, these allocations will tilt over time based on their view of the risk environment. This allocation mix is met with the use of GuidePath Funds and, as needed, GuideMark Funds. GPS Fund Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 22 of 32 AssetMark manages GPS Select using limited discretionary authority. While AssetMark will exercise limited discretion on the Portfolio asset allocation within portfolio investment sleeves, AssetMark relies upon the third-party Strategists to conduct individual security selection. As discussed above AssetMark will seek to utilize the lowest cost mutual fund share class for Accounts in the GPS Select Solutions, however, because of limitations on the securities available at the Platform Custodians, there will be circumstances where AssetMark is not able to obtain the lowest cost mutual fund share class available, and will have exercised “discretion” in selecting an alternative share class. Refer to Exhibit C at the back of this Disclosure Brochure for more information. MUTUAL FUND SOLUTION TYPES Market Blend Mutual Fund Strategies 12b-1 fees as well as shareholder servicing fees or sub-transfer agent fees. AssetMark will seek to use institutional classes where these share classes are available. AssetMark has determined that for most Clients, transaction fee mutual funds and share classes would be more expensive than non-transaction fee mutual funds and share classes. The Platform Fee for these solutions is used to pay for the administration and servicing of the Accounts that AssetMark performs. In striving for consistency across all custodial options on the Platform in GPS Select, AssetMark will seek to select the lowest cost share class available across Custodians and that aligns the stated program Account minimum and allocation weighting of funds held with the fund’s prospectus requirements. Due to specific custodial or mutual fund company constraints, the institutional share class is not always consistently available. In those cases, AssetMark will seek to invest the Bank Clients in the lowest cost share class that is commonly available. The institutional share class is typically lower, however, in some cases, the lowest share class can be the retail share class. See Servicing Fees Received by Custodians, Including AssetMark Trust Company and Share Class Use in Item 4, Service, Fees and Compensation. Market Blend Strategies use Proprietary Funds, and in Market Blend Strategies, AssetMark provides the following strategic asset allocation Strategies. The Bank can select from the following Market Blend Mutual Fund Strategies for the Bank Client Account: With the assistance of the Financial Advisor, Clients can select from the following GPS Select products: • Global GuideMark Market Blend • US GuideMark Market Blend • Select Wealth Preservation. Strategy seeks to preserve capital while keeping up with inflation and is allocated with a blended mix to selected Strategist portfolios across Investment Strategies. This Strategy is designed for wealth preservation and protection from inflation. • Select Accumulation. Strategies seek growth of capital and are allocated with a blended mix to selected Strategist portfolios Investment Strategies. • Select Distribution. Strategies seek a blend of income and growth of capital and are allocated with a blended mix to selected Strategist portfolios Investment Strategies. Strategist selection will be focused toward Strategists managing to a multi-asset income mandate or where income is a large component of the Strategy. This Strategy is also designed to provide an enhanced level of income and to control portfolio volatility. These Strategies will provide a strategic asset allocation across seven to ten core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the portfolio. The Global model will take global exposures while the US model will take domestic exposures. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. The investment vehicles used to implement the Strategy are the proprietary GuideMark Funds that provide exposure to each of the asset classes. AAM manages the Market Blend Strategies and the underlying Proprietary Funds, but the Bank chooses whether to invest, or remain invested, in the Market Blend Strategies for the Bank Client Account. AAM does not advise the Bank whether to invest, or to remain invested, in the Market Blend Strategies. Focused GPS Select are based primarily on the Client’s risk profile and desire for focused exposure to one or more Investment Strategies used to complement other Solution Types selected for the Client Portfolio. • Select Low Volatility. Strategy seeks to provide a low correlation to equities with low volatility experience and is allocated with a blended mix to selected Strategist portfolios mainly emphasizing bonds. This focused investment Strategy targets low volatility with a low level of return. It is important to note that Bank Client Accounts invested in Market Blend Mutual Fund Strategies will receive allocations, determined by AAM, among the GuideMark Funds. AssetMark will receive advisory fees from the mutual funds in which these Accounts invest. The mutual fund advisory fees differ between funds and the total fund advisory fees collected by AssetMark will vary depending upon the profile selected by the Bank and the fund allocation within each profile. If a Bank selects a Market Blend Mutual Fund Solution, the Bank authorizes and instructs that the Account be invested pursuant to the selected profile, acknowledges that the fund advisory fees collected by AssetMark will vary, and approve of the fund advisory fee payments to AssetMark, within the ranges provided In Exhibit C. The Bank will be given notice if these ranges or funds change and it results in a higher average weighted fee earned. Unless the Bank gives notice to AAM, the Bank consents to these changes. See Exhibit C for more information. • Select Tactical. Strategies seek to provide flexible exposure to the equity market alongside flexible bond exposures and are allocated with a blended mix to selected Strategist portfolios across mainly defensive equity and bond Investment Strategies. This focused investment Strategy seeks to limit participation in extreme market downturns while generally participating in normal markets. Higher risk profiles will hold higher exposure to Tactical Strategies while lower risk profiles will hold higher exposures to Diversifying Strategies. AssetMark Asset Builder • Select Multi-Asset Income. Strategies seek to provide a blend of income and growth, and are allocated with a blended mix to selected Strategist portfolios across Investment Strategies. This focused investment Strategy seeks to provide an enhanced level of income across changing markets. AAM provides strategic asset allocation services utilizing mutual funds. Bank Client Account asset allocations are dependent on the stated risk parameters and investment objectives of the Bank Client Account. Assets are managed on a discretionary basis. Bank Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 23 of 32 reallocated to the revised allocations. On at least an annual basis the asset class exposures are reviewed for reallocation of the Strategy. The investment vehicles used to implement the Strategy are ETFs that are representative of the cap-weighted indices for each of the asset classes and lower cost. MUTUAL FUND AND ETF BLEND SOLUTION TYPES can transfer existing investments to fund the Account; however, all transferred assets will be liquidated and invested to the appropriate asset allocation without regard to any taxable gains or losses that can result. Periodic Account reviews will include Account rebalancing. Rebalancing can be performed without consideration for any realized taxable gains or losses that result. Bank can place reasonable restrictions on Accounts. MarketDimensions Strategies AssetMark Income Builder Income Builder is an asset allocation strategy designed to provide a higher level of current yield in comparison to traditionally asset allocated portfolios with a similar risk profile. Income Builder will allocate the portfolio across a variety of fixed income and equity investments: traditional fixed income, high yield fixed income, income and growth and traditional equities. While Income Builder is designed to provide a higher current yield, a higher yield is not guaranteed. For the MarketDimensions Strategies, AAM will seek to create strategic global portfolios through a combination of multiple asset classes including equities and fixed income. In seeking to maximize total return, these Strategies allocate to a diversified portfolio of domestic and international equity securities, domestic and international fixed income securities, and cash equivalent money market securities indirectly using Dimensional Fund Advisors mutual funds and ETFs (DFA Funds). AssetMark Socially and Faith Based Screened Portfolios (Values Based Portfolios) The Bank can select from the following MarketDimensions Strategies for their Client Accounts. • Standard. The Global Standard Strategy will represent asset classes selected from the broad universe of DFA Funds. • Tax-Sensitive. The Tax-Sensitive Strategy will represent asset classes seeking to use tax-advantaged DFA Funds where possible. The Strategy will be reallocated typically one to two times per year. AAM will monitor the Strategies’ exposures to the asset classes on an ongoing basis for excessive drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. At a Client’s request, AAM will offer portfolios managed for various social or faith based considerations (“Personal Values Portfolios”). Such portfolios can be offered under the Asset Builder and the AssetMark Custom High Net Worth strategies. Personal Values Portfolio allocations are typically constructed from mutual funds, but can also include Separately Managed Accounts, individual securities, closed-end funds and exchange traded funds. Mutual funds utilized in Personal Values Portfolios are selected from a more limited menu of mutual funds than “traditional” allocations. As a result, and though not expected, risk characteristics and performance returns of Personal Value Portfolios could vary significantly from our traditional Portfolios. Personal Values Portfolios can also be limited to certain investment types and securities and therefore, may not be fully diversified. You may wish to discuss these limitations with your Financial Advisor. Minimum Account sizes for applicable service levels apply and are subject to negotiation. Beginning or after June 2025, AssetMark will no longer manage these strategies. Dimensional Fund Advisors will be assuming direct oversight and management of these strategies. ETF SOLUTION TYPES OBS Strategies Market Blend ETF Strategies Bank can select from the following Market Blend ETF Strategies for their Client Accounts: AAM will seek to create strategic global portfolios through a combination of multiple asset classes including equities and fixed income. In seeking to maximize total return, these Strategies allocate to a diversified portfolio of domestic and international equity Securities, domestic and international fixed income Securities, and cash equivalent money market securities indirectly DFA Funds. These strategies will bias towards the factors favored by Dimensional Fund Advisors. The Bank can select from the following OBS Strategies for their Client Accounts. • AssetMark DFA/EFS. The Flagship Strategy will represent asset classes selected from the broad universe of DFA Funds. • AssetMark DFA/EFS. Enhanced • Global Market Blend Strategies. These Strategies will provide a global strategic asset allocation across core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the Portfolio. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. On at least an annual basis the asset class exposures are reviewed for reallocation of the Strategy. The investment vehicles used to implement the Strategy are ETFs that are representative of the cap-weighted indices for each of the asset classes and lower cost. International. The Enhanced International Strategy will represent asset classes selected from the broad universe of DFA Funds and will tilt exposures more towards international markets. The Strategies will be reviewed at least annually for reallocation. AAM will monitor the strategies’ exposures to the asset classes on a quarterly basis for excessive drift against volatility-based targets and will rebalance the Strategies if targets are breached. • US Market Blend Strategies. These Strategies will provide a domestic strategic asset allocation across core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the Portfolio. Asset class exposures are reviewed on an ongoing basis for drift against volatility based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or Beginning or after June 2025, AssetMark will no longer manage these strategies. Dimensional Fund Advisors will be assuming direct oversight and management of these strategies. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 24 of 32 WealthBuilder Strategies Additionally, AAM is permitted to use one or more Proprietary Funds within the Strategy. The Strategy for each Proprietary Fund is described in more detail in the Proprietary Funds’ prospectus. All Proprietary Funds utilized are registered investment companies for which AssetMark serves as investment adviser. Savos GMS, PMP, US Risk Controlled and Savos Personal Portfolios AAM manages UMAs and is also referred to as Discretionary Manager providing discretionary investment management services. AAM selects securities directly for the Bank Client Accounts. IMA Accounts are permitted to hold investments selected by AAM, and these investments can include, but are not limited to, some or all of the following types of securities: ETFs; equities, closed-end mutual funds; open-end mutual funds; preferred stocks; Treasury bonds, bills and notes; and bank notes. The asset allocation decisions, and security selection decisions will be made solely by AAM at its discretion. For WealthBuilder Strategies, AAM will provide strategic investment allocations across Investment Strategies based on investment objectives, market outlook, risk profile and other preferences to provide seeking to grow their capital. AAM combines a Core Market globally focused Core portfolio of ETFs with complementary third- party mutual funds that represent other Investment Strategies. The Strategy will also be comprised of a 2% allocation to cash. For more information regarding the cash allocation, refer to the ICD Program section under Other Financial Industry Activities and Affiliations and Affiliate Conflicts of Interest. The goal of the portfolio is to manage risk efficiently through diversification of Strategy. The Core Market portfolio will provide a strategic asset allocation across seven to ten core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the portfolio. The portfolio is globally diversified with asset class exposures reviewed on a quarterly basis for drift against volatility-based targets. Where the drift exceeds pre-set criteria, the Account will be rebalanced. The mutual funds complement the Core Market portfolio and are selected based upon their representation of the approach. Each Fund undergoes deep due diligence before being used within the Strategy, and institutional shares are used. On an annual basis, the portfolio’s exposures are reviewed for reallocation of the Strategy. SAVOS SOLUTION TYPES For IMA Accounts, AAM employs comprehensive analysis, including specific mathematical, technical and/or fundamental tools and risk- control criteria in the management of Bank Client Accounts. The focus of AAM as Discretionary Manager is to add value to each Client’s Account through: (i) the strategic and tactical determination and implementation of asset allocation levels; (ii) the selection of securities with investment characteristics which AAM believes are appealing; and (iii) the formation of portfolios with risk management options to match the portfolio to the Bank Client’s chosen level of risk tolerance. • Savos Preservation Strategy • Savos GMS Accounts • Savos PMP Accounts • Savos US Risk Controlled Strategy For GMS and PMP accounts, a risk management strategy is implemented through the use of fixed income strategies. Portfolio allocations for these risk management strategies will vary based on individual Client objectives within target allocations established and monitored by AAM. • Custom Accounts - Savos Personal Portfolios - Savos Fixed Income Strategies • AssetMark Custom High Net Worth GMS & PMP Accounts Banks who select the GMS or PMP Account as their Client’s Solution Type must deposit at least $25,000 into their Client Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $25,000. A Bank Client’s Account will be held by the Platform Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $25,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. Savos Preservation Strategy For the - Savos Preservation Strategy, AAM provides discretionary investment management services to the Account, and the Financial Institution grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and such other authorities appropriate for a discretionary manager of an investment account. In the Savos Preservation Strategy, the Bank need not make further selections to specify the Strategy for the Account. The Savos Preservation Strategy considered to be Risk/Return Profile 1 as a bond Investment Strategy. In a GMS or PMP Account, the Bank authorizes AAM to provide discretionary investment management services to the Account. The Bank grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and the other authorities appropriate for a discretionary manager of an investment account. AAM is permitted to invest the Account in individual securities, pooled investment vehicles, such as mutual funds or ETFs or in other securities or investments. The primary investment objective of the Savos Preservation Strategy is to generate a positive real (after-inflation) return over each 12 month period. A secondary objective is to limit the strategy’s sensitivity to changes in interest rates. Intra-year volatility and performance will vary and are independent of the Strategy’s primary investment objective. There is no guarantee that the Strategy’s primary and secondary investment objective will be met in all market conditions. The Account will be invested primarily in mutual funds and ETFs. Additionally, AAM is permitted to use one or more Proprietary Funds within the Strategy. The Strategy for each Proprietary Fund is described in more detail in the prospectus for the fund. All Proprietary Funds are registered investment companies for which AssetMark serves as investment adviser. This Strategy is permitted to invest in, among other things, “opportunistic” or “specialized” asset categories, which can include real estate, commodities, precious metals, energy and other less traditional asset classes, with no geographic restrictions. AAM will adjust the holdings in a GMS or PMP Account on an ongoing basis. In some instances, AAM will sell or readjust GMS or PMP Account holdings to take advantage of certain opportunities to reduce taxes for the Client. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client  Page 25 of 32 The US Risk Controlled Strategy is a defensive U.S. equity solution (Tactical Limit Loss) and is offered in a single risk profile. Profile six (6), Maximum Growth. Custom and Advisor - Custom Accounts Additionally, Bank should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets during the annual adjustment period, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. Such transactions can take three or more business days. The GMS or PMP Account is a Core Investment Strategy allocating across equities and fixed income. The type of fixed income used will vary depending on the risk profile selected. There are two main investment mandates that a client can choose between: The Client, with the assistance of the Financial Advisor, can request that AAM deviate from standard allocations for the selected GMS or PMP Strategy. Such an Account is considered a Custom GMS or PMP Strategy. The Custom GMS and PMP Strategy can be customized (1) based on a tax-managed transition plan, (2) due to a request to reduce net capital gains on an ongoing basis, or (3) due to a request for other customization. • High Dividend – The account will primarily be allocated to U.S. stocks and tilted towards dividend paying securities which can include significant allocations to real estate and high dividend paying stocks. • Global – The account will be allocated to U.S. and international securities (including emerging markets). The Bank selects a Risk/Return Profile for the GMS or PMP Account. Only Profiles numbered two (2) through six (6) that is Moderate, Moderate Growth, Growth and Maximum Growth are available. US Risk Controlled Strategy If the Bank requests a tax-managed transition, AAM will take commercially reasonable efforts to limit the immediate realization of net gains related to securities transferred in-kind. Bank can also ask that certain securities not be purchased for their Custom account. Banks can request the implementation of socially responsible screens, of Global Industry Classification Standard (“GICS”) codes or social themes, or the exclusion of specific securities by CUSIP. Requests for restrictions are reviewed by AssetMark to ensure that they are reasonable and will not unduly impair AssetMark’s ability to pursue the Strategy selected by the Bank. Banks can also request a Custom Account consistent with a proposal or product sheet provided by AAM for the Account. Contact your AssetMark consultant for more information. Banks who select the US Risk Controlled Strategy as their Solution Type must deposit at least $25,000 into their account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $25,000. Discretionary authority includes the authority, without first consulting with the Bank to buy, sell, remove and replace securities and to determine the allocations to each investment, select broker-dealers, vote proxies, and take any and all other actions on the Bank’s behalf that AAM determines is customary or appropriate for a discretionary investment adviser to perform. A Bank Client’s Account will be held by Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $25,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. Additionally, the Bank, can choose to participate in a program, in consultation with AAM, can request further customization for their Bank Client’s Account (“Advisor – Custom Accounts” or “ACA”). The Bank will be solely responsible for determining the additional customization and the suitability for their Client. AAM, in its discretion, will determine the implementation of the ACA. The Bank will be solely responsible for determining the additional customization. The Bank can request that AAM recommend to the Bank asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the custom models developed by the Bank may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for the GMS or PMP Accounts described below. The GMS or PMP Platform Fee schedules will be charged to the Bank Client Account, unless otherwise negotiated between the Bank and AAM. Savos Personal Portfolios In the US Risk Controlled Strategy, the Bank authorizes AAM to provide discretionary investment management services to the Account. The Bank grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and other discretionary authorities. AAM retains the right to allocate across asset classes, which will include such recommended securities, in its own discretion. AAM invests the Account in individual securities and ETFs. Banks who select the Savos Personal Portfolios must deposit at least $150,000 into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $150,000. A Bank Client’s Account will be held by Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $150,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. The US Risk Controlled Strategy adjusts equity exposure, seeking to limit losses in extreme market declines while participating in equity market returns most of the time. AAM will adjust the holdings in the US Risk Controlled Strategy based on a proprietary indicator. AAM will sell or readjust holdings where appropriate based on the indicator. During periods of heightened market volatility, AAM will have the ability to adjust the holdings to a non-equity alternative. During periods of low market volatility, AAM will have the ability to adjust the holdings to use a leveraged investment to obtain additional market exposure. In Savos Personal Portfolios, the Bank authorizes AAM to provide discretionary investment management services to the Account. The Bank grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and other discretionary authorities. AAM retains the right to allocate across asset classes, which will include such recommended securities, in its own discretion. AAM invests the Account in individual securities, mutual funds and ETFs. Additionally, Clients should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets during the adjustment period, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. Such transactions can take three or more business days. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 26 of 32 AssetMark Custom High Net Worth Savos Personal Portfolios is a Core Investment Strategy Invested in a mix of traditional asset classes, mainly equities and fixed income, and a tactical Strategy. Savos Personal Portfolios seeks to provide total return through the combination of multiple asset classes predominantly in equity and fixed income. The tactical sleeve adjusts equity exposure, seeking to limit losses in extreme market declines while participating in equity market returns most of the time. The fixed income holdings will include a combination of ETFs and/or mutual funds selected to maximize the yield of the fixed income sleeve while managing to pre-defined risk limits. The Tax-Sensitive Strategies will offer an optional, personalized tax-managed transition in the Account and will also offer tax-loss harvesting to Bank Clients. There are two main investment mandates a client can choose between: • Growth and Growth Tax-Sensitive - The Strategy focuses on growth whereby equity exposure is taken across U.S. and international equity market securities (including emerging markets), targeting stocks selected to maximize exposure to equity style factors such as value, momentum, and quality. The AssetMark Custom High Net Worth service is available through AAM. The minimum Account size for this Account is $500,000. AAM uses a number of the Strategies and advisory services in providing discretionary investment management services to the Custom High Net Worth Account. AAM can invest the Account in direct securities, pooled investment vehicles, such as open-end mutual funds, closed end investment companies, including ETFs, or in other securities or investments. AAM retains the right to allocate across asset classes, in its own discretion. Portions of the Account will also be managed by third-party model providers that AAM selects, retains and replaces in its discretion. For the fixed income portion of the Custom High Net Worth Account, AAM will use pooled vehicles or have a third-party Discretionary Manager manage with discretion that portion of the Client’s Account. AAM will remove, add or replace the third-party Discretionary Manager in its discretion. The Bank grants AAM the authority to buy and sell securities for the Account and to vote proxies for securities held by the Account. When a third-party Discretionary Manager is used, the Client grants that third-party Discretionary Manager the authority to buy and sell securities and investments and to vote proxies for securities held in that portion of the Account it manages. • Dividend and Dividend Tax-Sensitive - The Strategy focuses on growth and income whereby equity exposure targets stocks that exhibit positive exposure to equity style factors including dividend yield. The Savos Personal Portfolios follow the Core Markets Investment Approach. Profiles numbered three (3) through six (6), are available for the Savos Personal Portfolios, and can be customized based on a tax-managed transition plan. Savos Personal Portfolios - Custom The Bank Clients invested in the AssetMark Custom High Net Worth service have the option to place restrictions against investments in specific securities or types of securities for their Account that are reasonable in light of the advisory services being provided. Requests for such restrictions are reviewed by AAM to ensure that they are reasonable and will not unduly impair AAM’s ability to pursue the Account’s investment objective. As may be limited by the Custodian’s policies and procedures, Clients can also pledge the securities in their Account or withdraw securities from their Account (transfer in-kind to another Account or Custodian), but must do so by giving instructions in writing to the Custodian. Savos Fixed Income Strategies A Savos Personal Portfolio - Custom Account can be customized within a specific range across equity, fixed-income and tactical allocations. The Bank can select from various Savos Strategies. In doing so, and by selecting within the range of pre-determined allocations, a Savos Personal Portfolios - Custom Account will be established. Each equity, fixed-income and tactical allocation is referred to as a “sleeve” allocation. For Savos Fixed Income Accounts, AAM acts as Investment Manager for Bank Client Accounts. The available Mandates for the Savos Fixed Income Accounts are as follows: • Laddered Bond Mandates. These Strategies invest the Account in either U.S. Treasury, U.S. Agency or U.S. Treasury Inflation Protected bonds, with an intermediate or short duration, typically on a buy and hold basis. AAM will make available the specific range of pre-determined allocations, which range will be updated from time to time. The number of sleeves selected can vary from a minimum of one to a maximum of nine sleeve selections, to comprise the entire Savos Personal Portfolios - Custom Account. There is an investment minimum of $20,000 in the equity and tactical sleeve, and $10,000 for the fixed- income sleeve. The Custom Savos Personal Portfolio Strategy can be customized based on a tax-managed transition plan. • Municipal, Duration-based and the High Income Mandates. These standard Strategies invest the Account in closed-end funds, ETFs or mutual funds to obtain relevant exposure specific to desired asset categories. The Bank will be solely responsible for determining the Risk Return profile, additional customization and the suitability for the Bank Client Account. AAM, in its discretion, will determine the implementation of the AAM Personal Portfolio - Custom. AAM does not provide any individualized investment advice to Savos Personal Portfolios - Custom. The asset allocation classification of the custom models developed by the Bank may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure. Profiles numbered one (1) through six (6), are available for the Savos Personal Portfolios Custom Account. • Advisor - Custom Accounts. The Bank can choose to participate in a program in which The Bank, in consultation with AAM, can request further customization for their Account (“Advisor – Custom Accounts” or “ACA”). The Bank will be solely responsible for determining the additional customization and the suitability for the Bank Client. AAM, in its discretion, will determine the implementation of the ACA. The Bank can request that AAM recommend to the Bank asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the custom models developed by the Bank may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for the Fixed Income strategies described above, and the AAM Fixed Income Platform Fee schedule will be charged to the Bank Client Account, unless otherwise negotiated between the Financial Advisory Firm and AAM. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 27 of 32 SAVOS DYNAMIC HEDGING FEATURE The Dynamic Hedging feature is offered within certain Solution Types managed by AAM The primary investment objective of the Dynamic Hedging feature is to mitigate losses resulting from a severe and sustained decline in the broad-based equity markets. AAM will implement the Dynamic Hedging feature by investing in any number of hedging, fixed income or other protective investment vehicles. Investment Objective The goal of the Dynamic Hedging feature is to participate in the growth of equity markets while also providing risk management protection during periods of sustained and severe equity market decline. The Dynamic Hedging feature seeks to allow investors to stay invested for the long term by partially offsetting extreme declines in the equity markets while also seeking to provide positive total returns in rising markets. Risks No Guarantee; Expressed or Implied The phrase “risk management protection” or simply “protection” should in no way be regarded as a guarantee against losses or even the mitigation of losses. Similarly, the word “participation” should in no way imply positive gains during periods of rising equity markets. The primary goal of the Dynamic Hedging feature is to provide some degree of mitigation of losses during sustained and severe declines in the broad-based equity markets, (and participation in gains during rising markets), but this is not a guarantee. AAM may or may not be successful in achieving the investment objective in any individual calendar year. The Dynamic Hedging feature should not be expected to mitigate losses occurring over short periods of time, nor should the Dynamic Hedging feature be expected to mitigate losses occurring from market declines that are relatively small or minor. Limiting Circumstances for Participation in Upside Equity Market Movements Another goal of Dynamic Hedging is to allow growth in the equity portion of a Bank Client’s Account to increase the value of the overall Account. This is the “participation” portion of Savos’ “participation and protection” objective. Banks who elect Dynamic Hedging should know that the “cost” of the protection is likely to reduce returns when equity markets are increasing in value. This drag would generally result because (i) the hedging vehicles used by AAM to implement the Dynamic Hedging feature moves inversely to equity markets, and (ii) the cost of the hedging vehicles used in the Dynamic Hedging feature are more likely to increase in declining equity market conditions. As a result, the level of participation and protection of a Bank Client’s Account will vary depending upon market environment and the specific path of market returns. Dynamic Hedging can fall while the overall equity market is rising in certain time intervals, and will fall more than the overall equity markets in certain intervals. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 28 of 32 EXHIBIT C – PROPRIETARY MUTUAL FUND SOLUTIONS - CONFLICTS OF INTEREST DISCLOSURES MUTUAL FUNDS FEES RETAINED BY ASSETMARK The Accounts of Bank and Trust Companies who select a GPS Fund Strategy will be invested in mutual funds advised by AssetMark. This creates a conflict because AssetMark receives Management Fees and Administrative Service Fees from these mutual funds, the Management Fees retained by AssetMark can differ and AssetMark will determine the allocations of Account value among these funds. AssetMark addresses this conflict by providing additional information below regarding the maximum fees AssetMark can retain. The maximum net Management Fee retained by AssetMark from a fund in GPS Fund Strategies is 0.40% of average daily net assets, and the maximum Administrative Service Fee paid AssetMark is 0.25%. Therefore, the maximum fee that AssetMark can retain from a mutual fund in a GPS Funds Strategies account is 0.65% of average daily net assets. AssetMark is also compensated by the Platform Fee charged for the GPS Fund Strategies, which is less than that charged for strategies with third party funds and ranges from 0.25% to 0.10% (depending upon Account assets, with the first $250,000 of Account value always being charged the highest 0.25% fee). The Platform Fee for the GPS Fund Strategies does not include a charge for advisory (or management) services but pays for custodial, trading, administrative and other services. In selecting a GPS Fund Strategy, the Client agrees to the receipt by AssetMark of the maximum 0.65% Management Fee plus Administrative Fee (paid by the fund) plus the applicable Platform Fee (charged at the Account level) and that this fee is reasonable compensation to AssetMark. AssetMark’s management of a GPS Fund Strategy can result in internal fund fees to AssetMark lower than the 0.65% authorized by the Client. Listed below are the mutual funds advised by AssetMark in which AssetMark can invest GPS Fund Strategy accounts and the maximum fee that AssetMark can retain from each fund as a percentage of average daily net assets of the mutual funds. If a fund has a sub-adviser, the minimum that AssetMark can pay the sub-adviser is deducted in the amount shown as retained by AssetMark. AssetMark can waive part or all of its management fee, and AssetMark can also recoup previously waived fees and assumed expenses, but these possibilities are not considered in the below-reported maximum retained fees. Some funds invest in shares of other funds; the fees paid these underlying funds are not included in the below-reported fees. The Bank should refer to the funds’ prospectuses and other shareholder materials for information, including fees, regarding the funds. Additional mutual funds can be added to those that receive allocations. If an added fund results in a fee greater than 0.65% being paid to AssetMark, the Bank will be given notice. MUTUAL FUNDS MAXIMUM FEES RETAINED BY ASSETMARK GuidePath Growth Allocation Fund 0.50% GuidePath Conservative Allocation Fund 0.50% GuidePath Tactical Allocation Fund 0.60% GuidePath Absolute Return Fund 0.60% GuidePath Managed Futures Strategy Fund 0.60% GuidePath Flexible Income Allocation Fund 0.50% GuidePath Multi-Asset Income Allocation Fund 0.60% GuideMark Large Cap Core 0.60% GuideMark World ex-US Service 0.60% Since the amount that AssetMark is paid by each mutual fund varies, changes by AssetMark to the allocations of mutual funds in Client Accounts can change what AssetMark receives in fees from the funds. GPS Fund Strategies include strategies with “Accumulation of Wealth,” “Distribution of Wealth” and “Focused” investment objectives. AssetMark anticipates making periodic changes to allocations among mutual funds in the Accumulation of Wealth and Distribution of Wealth investment objectives but does not anticipate any material allocation changes for Accounts invested in the Focused investment objectives. Listed below, for each Profile in each Strategy offered in the Accumulation of Wealth and Distribution of Wealth investment objectives is the maximum retained fee and the range of retained fees that AssetMark can receive assuming the possible asset allocations that AssetMark anticipates for that Profile and objective. For the strategies in the Focused investment objectives, only the maximum possible retained fee is listed because AssetMark anticipates that a change, if any, in the allocations will not materially affect the maximum fee. If an allocation change or the addition of a new mutual fund results in a maximum retained fee for a Strategy greater than that listed below, the Bank will be given notice. The Maximum Net Revenue for the GuidePath Absolute Return Fund reflects a fee waiver currently in place for the Fund. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 29 of 32 GPS FUND STRATEGIES MAX NET REVENUE RANGE OF NET REVENUE GPS ACCUMULATION OF WEALTH 1 0.59% 0.54% - 0.59% 2 0.59% 0.54% - 0.59% 3 0.58% 0.53% - 0.58% 4 0.57% 0.52% - 0.57% 5 0.58% 0.53% - 0.58% GPS DISTRIBUTION OF WEALTH 2 0.61% 0.56% - 0.61% 3 0.64% 0.59% - 0.64% 4 0.64% 0.59% - 0.64% GPS FUND STRATEGIES MAX NET REVENUE GPS FUND STRATEGIES MAX NET REVENUE GPS FOCUSED CORE MARKETS GPS ACCUMULATION - NO ALTERNATIVE EXPOSURE 1 0.50% 1 0.54% 2 0.49% 2 0.54% 3 0.49% 3 0.53% 4 0.49% 4 0.52% 5 0.49% 5 0.53% GPS FOCUSED LOW VOLATILITY GPS DISTRIBUTION, NO ALTERNATIVE EXPOSURE 1 0.54% 2 0.57% 3 0.60% GPS FOCUSED TACTICAL 4 0.60% 5 0.59% GPS FOCUSED TACTICAL GPS FOCUSED MULTI-ASSET INCOME 2 0.55% 2 0.55% 3 0.56% 3 0.59% 4 0.58% 4 0.56% Mutual funds advised by AAM are available only through the AssetMark Platform and are dependent on the continued vitality of the AssetMark Platform for their commercial viability. GPS SELECT Part of Platform Fee is credited to Account AAM serves as investment manager for GPS Select and will allocate account value across investment Strategies, and among Strategists and investment managers within those investment Strategies. Included within these investment options are strategies managed by AAM and the investment options include allocations to mutual funds advised by AAM. AssetMark pays fees to various strategists and investment managers that it allocates account value to but does not pay such fees to third parties when it allocates account value to Strategies it manages. Further, AssetMark receives compensation from mutual funds they advise. For GPS Select, the Platform Fee is 0.95%. In selecting GPS Select, the Client agrees to the receipt by AssetMark of this 0.95% fee and that this fee is reasonable compensation to AssetMark. However, an amount of 0.30% is credited back to the Account, resulting in a net Platform Fee of 0.65% for assets invested in GPS Select. The purpose of the 0.30% credit is to ensure that, regardless of the allocation decisions made by AAM, the Bank will receive a Platform Fee credit that is at least as much as any additional compensation AssetMark might retain due to the allocations that AssetMark is permitted to make pursuant to the GPS Select investment guidelines. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client  Page 30 of 32 MARKET BLEND MUTUAL FUND STRATEGIES Mutual Fund Fees retained by AssetMark The Accounts of Bank who select a GuideMark Market Blend Mutual Fund Strategy will be invested in Proprietary Funds advised by AssetMark. AssetMark will receive Management Fees and Administrative Service Fees from these funds, the Management Fees retained by AssetMark can differ and AssetMark will determine the allocations of Account value among these funds. AssetMark addresses this conflict by providing additional information below regarding the maximum fees AssetMark can retain. The maximum net Management Fee retained by AssetMark from a fund in a GuideMark Market Blend Mutual Fund Strategy is 0.45% of average daily net assets, and the maximum Administrative Service Fee paid to AssetMark is 0.25%. Therefore, the maximum fee that AssetMark can receive from a mutual fund in a GuideMark Market Blend Mutual Fund Strategy is 0.70% of average daily net assets. AssetMark is also compensated by the Platform Fee charged for the GPS Fund Strategies, which is less than that charged for strategies with third party funds and ranges from 0.25% to 0.10% (depending upon Account assets, with the first $250,000 of Account value always being charged the highest 0.25% fee). The Platform Fee for the GPS Fund Strategies does not include a charge for advisory (or management) services but pays for custodial, trading, administrative and other services. In selecting a GuideMark Market Blend Mutual Fund Strategy, the Client agrees to the receipt by AssetMark of the maximum 0.70% Management Fee plus Administrative Fee (paid by the fund) plus the applicable Platform Fee (charged at the account level) and that this fee is reasonable compensation to AssetMark. AAM’s management of a GuideMark Market Blend Mutual Fund Strategy can result in internal fund fees to AssetMark lower than the 0.70% authorized by the Bank. Listed below are the Proprietary Funds in which AssetMark is permitted to invest GuideMark Market Blend Mutual Fund accounts and the maximum fee that AssetMark can retain from each fund as a percentage of average daily net assets of the mutual funds. If a fund has a sub-adviser, the minimum that AssetMark can pay the sub-adviser is deducted in the amount shown as retained by AssetMark. AssetMark can waive part or all of its management fee, and AssetMark can also recoup previously waived fees and assumed expenses, but these possibilities are not considered in the below-reported maximum retained fees. The Bank should refer to the funds’ prospectuses and other shareholder materials for information, including fees, regarding the Funds. Mutual funds can be added to those that receive allocations. If an added fund results in a fee greater than 0.70% being paid to AssetMark, the Bank will be given notice. MUTUAL FUNDS MAXIMUM FEES RETAINED BY ASSETMARK GuideMark Large Cap Core 0.60% GuideMark Small/Mid Cap Core 0.70% GuideMark Core Fixed Income 0.60% GuideMark Emerging Markets 0.61% GuideMark World ex-US Service 0.60% Since the amount that AssetMark is paid by each Proprietary Fund, changes by AssetMark to the allocations of Proprietary Funds in Client Accounts can change what AssetMark receives in fees from the funds. Listed below, for each Profile in each Strategy offered in Market Blend Mutual Fund Strategies, is the maximum retained fee that AssetMark can receive, assuming the possible asset allocations that AssetMark anticipates for that Profile and objective. If an allocation change or the addition of a new Proprietary Fund results in a maximum retained fee for a Strategy greater than that listed below, the Bank will be given notice. MARKET BLEND STRATEGIES MAX NET REVENUE GLOBAL GUIDEMARK MARKET BLEND 2 0.59% 3 0.60% 5 0.60% 6 0.61% US GUIDEMARK MARKET BLEND 2 0.60% 3 0.61% 5 0.61% 6 0.62% Additionally, AssetMark Trust will be paid Shareholder Service Fees. Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client Page 31 of 32 i t s e h g h s F M M 1 $ % 0 9 . 0 % 5 9 . 0 % 9 9 . 0 % 9 9 . 0 % 4 0 1. % 0 1 1. % 0 1 1. l a n o i t a N y t i C e l a d h c o R e h t : ) y l n o i l a u d i v i d n I % 5 2 . 0 % 5 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 0 0 0 , 0 1 $ 8 . s e r u s o l c s i d t n a t r o p m i . d e t s s e v e c e r i l l e d o M r o f r o m o t s u C % 5 0 . 0 M 1 $ - K 0 0 5 $ % 5 7 . 0 % 5 8 . 0 % 0 9 . 0 % 4 9 . 0 % 9 9 . 0 % 5 0 1. % 5 0 1. m o t s u C s a s e e f i i m u m n m r o s i v d A e h t t n e m e g a n a m e g a p t x e n e e s e e f m o t s u C C B I C 3 s o i l o f t r o P M 1 $ % 0 8 . 0 % 0 9 . 0 % 5 9 . 0 % 5 9 . 0 % 0 0 1. % 0 0 1. % 0 0 1. 4 p e e w S l a i d o t s u C s F M y t r a P - d r i h T l a u d i v i d n I / s t c c A e v i t a r t s i n i m d A 3 s e i t i r u c e S l a r e n e G % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 % 0 0 . 0 0 0 0 , 0 1 $ d e c u d e r e e F l r e d n u i e s a e l P r i i l 8 s t n u o c c A d e g a n a M y l l a u d i v i d n I r a i l l l e v e c e r a B m a m u m n m o d i l l i i m o t s u C c i r t e m a r a P 3 . t r o P m o t s u C a t n e m e p p u S W K 0 5 7 $ - K 0 5 2 $ % 0 5 . 0 % 0 6 . 0 % 0 6 . 0 % 0 6 . 0 % 5 6 . 0 % 5 6 . 0 % 5 6 . 0 l a n o s r e P s o i l o f t r o P % 5 7 . 0 % 5 7 . 0 % 5 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 6 . 0 0 0 0 , 0 5 1 $ t s r fi l a u n n a r e d n u e l b a l i a v a ( s o i l t n o p k a e r b e h T . : s e c i 0 0 1 $ k s i R S U d e l l o r t n o C % 0 9 . 0 % 5 7 . 0 % 0 7 . 0 % 5 6 . 0 % 5 6 . 0 % 5 6 . 0 % 5 5 . 0 0 0 0 , 5 2 $ l h c a e S P G m o t s u C t c e e S % 0 1 . 0 % 0 2 . 0 % 0 3 . 0 % 0 4 . 0 S P G m o t s u C t c e l e S % 5 6 . 0 % 5 6 . 0 % 0 6 . 0 % 5 5 . 0 % 5 4 . 0 % 0 4 . 0 % 5 3 . 0 0 0 0 , 0 5 2 $ d e r e i t t n u o c c a 0 0 0 , 0 1 $ a d n a % 9 2 . 0 - r e v o P M P / S M G % 0 0 1. % 0 8 . 0 % 5 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 7 . 0 % 0 6 . 0 0 0 0 , 5 2 $ % 5 2 a d n a % 0 1 . . 0 e r a e v o b a 0 o f t r o P d e g a n a M : s t e s s a t c e l e S S P G % 5 6 . 0 % 5 6 . 0 % 0 6 . 0 % 5 5 . 0 % 5 4 . 0 % 0 4 . 0 % 5 3 . 0 K 0 0 1 $ - K 0 5 $ : e e f r o s i t a l l s o v a S n o i t a v r e s e r P % 5 7 . 0 % 0 5 . 0 % 0 5 . 0 % 5 4 . 0 % 5 4 . 0 % 0 4 . 0 % 0 3 . 0 0 0 0 , 5 2 $ s e e f e h T d n a e e f v d A e e F t a F v r e S t n e m e g a n a M x a T F R T I F k r a l C % 5 5 . 0 % 5 5 . 0 % 0 5 . 0 % 5 4 . 0 % 5 3 . 0 % 0 3 . 0 % 5 2 . 0 0 0 0 , 0 5 2 $ P M P d n u F S P G s e i g e t a r t S % 5 2 . 0 % 5 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 0 0 0 , 0 1 $ i e e F l d e l l o r t n o C k s i R S U s o v a S d e x i F e v i t c A 3 e m o c n I % 0 2 . 0 % 0 3 . 0 % 0 3 . 0 % 5 2 . 0 % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 K 0 5 2 $ - K 5 2 $ 3 e m o c n I d e x i F e v i t c A s o v a S , i , t h g i r W s r o s i v d A d n E t s e W l , 8 e m o c n I d e x i F d e r e d d a L y e s r o D S M G s o v a S , x e l u J t n o m u a e B a t n e m e p p u S s o i l o f t r o P d e d i u G e m o c n I d e d i u G s n o i t u l o S % 0 % 0 % 0 % 0 % 0 % 0 % 0 0 0 0 , 0 5 $ — s m u m n M l a t i p a C k r a l C 2 F M F M l e e F % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 % 5 1 . 0 % 5 1 . 0 % 5 1 . 0 % 5 1 . 0 0 0 0 , 5 2 $ y r a t e i r p o r P 5 3 e m o c n I d e x i F n e e v u N % 5 3 % 0 3 % 8 2 % 5 2 % 0 2 % 0 1 r e g a n a M , i n u M e t a i d e m r e t n , F T E y t r a P - d r i h T a n o i t u t i t s n I % 0 1 . 0 % 5 1 . 0 % 0 2 . 0 % 5 2 . 0 % 0 5 . 0 % 0 6 . 0 , F T E y t r a P - d r i h T l a n o i t u t i t s n I % 0 5 . 0 . 0 . 0 . 0 . 0 . 0 . 0 0 0 0 , 5 2 $ l I d e r e d d a L , , p u o r G l l a t i . s t n e i l , ) e e r F - x a T d n a x a T s t n u o c c A d e g a n a M y l l a u d i v i d n I y t r a P - d r i h T 3 e m o c n I d e x i F % 7 2 . 0 % 7 2 . 0 % 7 2 . 0 % 2 2 . 0 % 2 2 . 0 % 2 2 . 0 % 2 2 . 0 K 0 5 2 $ - K 5 2 1 $ a t n e m e p p u S p a C ( c F T E y r a t e i r p o r P F M % 5 0 . 0 % 5 1 . 0 % 5 4 . 0 F T E y r a t e i r p o r P 5 F M % 0 4 . 0 % 5 3 . 0 % 0 3 . 0 % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 0 0 0 , 5 2 $ i , e m o c n I y r o s v d a n a g r o M P J s A M S % 0 7 . 0 % 0 7 . 0 % 7 6 . 0 % 4 6 . 0 % 0 6 . 0 % 5 5 . 0 % 0 5 . 0 K 0 0 1 $ - K 0 5 $ s A M S % 5 0 . 0 % 0 1 . 0 h t i d e x i F , t n e m t s e v n I ) s A M S ( G S E 6 1 k r a M e d i u G % 5 2 . 0 % 5 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 0 0 0 , 0 1 $ , 2 r e d l i , s t l A c i t s i n u t r o p p O w e s u , I n w o r B , F T E ( l r e g r e b u e N , A M d e t a r e d e F c i t a m e h T k c E n a V k c E n a V i n a g o L 2 s e u l a V , k c o R k c a l B r o s v d a , p u o r G l e e F e e F ( k c o R k c a l B n o t e p m e T n i l k n a r F l l i t e e r t S e t a t S u B t e s s A k r a M t e s s A l a t i p a C t h g i r , a r e i F W i s r o s i v d A d n E t s e W l l i i , s e v i t a n r e t l A t s u r T t s r i F , e n i L e l b u o D a c n a n fi i i l , ) n o i t a c o l l , n i e t s n r e B e c n a i l l a t n e m e p p u S A , y r o s i v d A , s e m r e H , n a g r o M P J , d r o f t r a H , e g d E l a p i c n i r P , n a m r e B l a p i c n i r P , n a i d a c A l a n o s r e P k r a M t e s s A K 0 5 2 $ < K 0 0 5 $ - K 0 5 2 $ M 1 $ - K 0 0 5 $ M 2 $ - M 1 $ M 3 $ - M 2 $ M 5 $ - M 3 $ + M 5 $ m u m n M s e i g e t a r t S K 0 5 2 $ < a t n e m e p p u S s t n u o c c A d e g a n a M y l e t a r a p e S , x e l p m S a h p A , ) I F R r a t s g n i n r o M , e l b i x e l F l a b o l G A , s e m e h T p o T t s u r T t s r i F , n o i t p u r s i D r e i t n o r F w e N y e s r o D , x e l u J t n o m u a e B K 0 0 5 $ - K 0 5 2 $ M 1 $ - K 0 0 5 $ M 2 $ - M 1 $ M 3 $ - M 2 $ M 5 $ - M 3 $ + M 5 $ m u m n M 4 2 0 2 R E B M E C E D F O S A r o F & s e e F Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client  Page 32 of 32 . l O C M I P 9 s d n u F e n o t S l , . c n d e c n a h n E I f o e t a i l , e t i r i i l i f f a a u d v d n e n i L e l b u o D r e l l i h S , E P A C r e g r e b u e N n a m r e B W t u P S D N E R T d e g a n a M , s e r u t u F d e fi i s r e v i D e g d i R s e v i t a n r e t l A I a u t u M n a , , k r a M t e s s A I f o d n a A R N F p u o r G F T E k r a l C , e m o c n I , e m o c n I e v e e s h c a e o t n o i t a c o e v i l l i i i 3 e m o c n l a t i p a C e t a i d e m r e t n I , i n u M l a t i p a C e l b a x a T e e r F - x a T d e x i F , n e e v u N e v i t c A s o v a S d e x i F s o v a S s r e d d a L i t c A d e x F I r e b m e m n o s v d a , e r u s o l c s i D e h t o t C L L 5 , 3 e m o c n y r a t e I r e f e r d e x , t n e m e g a n a M i . s d n u f i l d n o B s o v a S s r e d d a L i r p o r P d e r e d d a L F . s e c n a t s n i — s t n u o c c A d e g a n a M y l e m o s l l n i , s n o i t u o s 3 e m o c n 8 e m o c n I I l i l t e s s A k r a M t e s s A , M T e g a r e k o r B k r a M t e s s A y b a u d v i d n i c i r t e m a r a P y t r a P - d r i h T d e r e d d a L d e x i F I d e x i F a u t u m y r a t e i r p o r p i l . s e s s a c e r a h s i l i i t n e m t s e v n e e F m r o f t a P e h t i d e t u b i r t s d m a i l l i , e g d E a r e i F i W n i l k n a r F , p u o r G e r a i . e d a r t l e r u s o , n i e t s n r e B e c n a i l l ) s A M S , n a i d a c A A , k c o R k c a l B , y r o s i v d A n w o r B l a t i p a C d e t a r e d e F , s e m r e H , l a t i p a C , n o t e l p m e T , d r o f t r a H , n a g r o M P J , n a g o L , r a t s g n i n r o M r e g r e b u e N , n a m r e B , l a p i c n i r P l a p i c n i r P , k c E n a V r i a l B y l e t a r a p e S d e g a n a M s t n u o c c A ( . s e n a p m o c i l c s i s ’ k r a M t e s s A e s u t a h t r e p 0 2 $ y d e t a . s r o s v d a l l i s u o i r a v e h t . n o s s m m o C e g n a h c x E d n a i i i s e v a w k r a M t e s s A i l m a i l l i d / o f n i / r o f i l i f f a n u a t e r d n a e r a h s A g n d u c n a c p y t W i n a t r e c s e g e t a r t s , , h t r o W o t d n a e r a n o s d n u F ® h t a P e d u G d n a m o c . s e i t i r u c e S y l l a u d i v i d n l k r a M t e s s A h g i H m o t s u C t e N l a t i p a C k r a l C d e z i l a n o s r e P A M U r i a l B m o t s u C I d e g a n a M 8 s t n u o c c A . l e b a . s e e f l i i l a v a e t a r a p e s l , y r u s a e r T % 0 0 1 S U e h t n i i l i e s e h T r o f s e r u s o c s d e r a h t i s o ® k r a M e d u G i l e m o c n I e r a . n r u t e R i i i s t s i g e t a r t s l l ) . s t n u o c c A y g e t a r t S e p i t l u M d n a t s e r e t n n a g r o M P J A k r a l C s u l p ( d e x i F l a t o T s o v a S d n a A M U ) s e i g e t a r t s s e i g e t a r t S e h t e l b a t e l b a l i a v a S P G m o t s u C t c e l e S S P G m o t s u C t c e l e S d e d u G o f t r o P i . t n u o c c a i f o s d n u F ) e e F n o i t c a s n a r T o N s t s g e t a r t s s e s n e p x e d n a , s e e f . s e g e t a r t s d n a e h t w d e r e t s g e r , s d n u F s t c o t ( F T N i l d e x i F , i d n u F - T i l f n o c , d r a d n a t S r e s v d a e b a c . d e v r e s e r d n E t s e W s e d o m S B O k r a M t e s s A O C M I P , , t h g i r i l y t r a p - d r i h t w e N t n e m t s e v n i i W , t n o m u a e B k r a m t e s s a w w w o t o g e s a e l , x e l p m S a h p l A c i t s i n u t r o p p O - i t l u M A T , p p a i 2 F M d n a l a b o l G p , I s t h g i r n a c i r e m A n o , k c E n a V , s m u m n m e b l l n o t g n i s n e K l t n a t r o p m , n r u t e R e t u l o s b A f o d e s i r p m o c , ) s t l A / A y e s r o D i , w , ) n o i t a c o l l y t n e m t s e v n 6 2 0 2 / 1 1 P X E G S E n e e v u N i i | y a m r o f . c n I i n a G S E A T , I F R k r a M t e s s A y b C l i r a m , x e l u J , ) I s . s t n e d e v a w s i k r a M t e s s A l i i i l l a n o i t u t i t s n 4 2 0 2 y r a t e i r p o r p s ’ m , s e e f F, T E y t r a P - d r i h T I / G S E , F T E , e v i s s a P / e v i t c A i c , s d n u F n a c i r e m A A M ( k c o R k c a l B , s t l A r e g a n a M R T I F k r a l C t s u r T t s r i F , e n i L e l b u o D w o L t s u r T t s r i F , s e v i t a n r e t l A t s r i F , e m o c n I d e x i F n o i t a r u D t s r i F , e r o C k s i R c i g e t a r t S t s u r T t s u r T t s r i F , s e m e h T p o T t s u r T r e f f u B y t i u q E S U d e r e d d a L t s e V , n o t e l p m e T n i l k n a r F , l e d o M F T E ( n a g r o M P J , e l b i x e l F l a b o l G A M r a t s g n i n r o M , e m o c n I d e g a n a M ( A e m o c n I , r e i t n o r F , t e e r t S e t a t S s r o s i v d A k c o R k c a B g n d u c n i . c n . c n 1 1 e e f I I , . s d n u f l i r p e r a | l l i , t n e m u c o d s i d e t c e e s r i f e h t . s d n u F ® k r a M e d u G e h t y a w a . t i b h x E o t e b a t n u o c c A d e g a n a M y i . r o s i v d a l a i c n a n fi r u o y t c a t n o c e s a e l p s h T i h t l i l l ( o t t e k r a M d n u f , a v a . k r a M t e s s A y b d e r e f f o e s o h t l e d a r t y r o s v d a i i r e f e R i 0 5 3 $ s e d u c n o t , k r a M t e s s A i , k r a M t e s s A , k r a M t e s s A 4 2 0 2 © 1 9 9 2 1 7 8 6 f o n o e r a : i a e h t n o d e s a b d e t h g e w d n a d e t c e e s t s g e t a r t s h c a e r o f e u d e h c s e e f y g e t a r t s - e g n s e v o b a e h t n o d e s a b e r a t n u o c c a A S M n a r o f d e g r a h c s e e f e h T e m o c n I l a n o s r e P h t i k r a M t e s s A a u d v d n r e s v d a s o i l o f t r o P I : ) i k r a M t e s s A l k r a M t e s s A r e f e r 5 F M F, T E y r a t e F T E i l g n d u c n i s r e v i s d n u F i A S M ( l w e s u s e g e t a r t s e s e h t n h t i s e p y t , 2 r e d l i u B t e s s A k r a M t e s s A i r p o r P d n e l B M S r e d l i u B h t l a e W k r a M t e s s A , r e d l i u B s n o i s n e m D t e k r a M , s o i l o f t r o P , s o i l o f t r o P S F E / A F D S B O k r a M t e s s A , 2 s e u l a V t e k r a m y e n o m = e m o c n - l , s e e f i I t n e m t s e v n t n u o c c a t u o b a n o i t a m r o f n i i : s n o i t u o S d n u F a u t u M l l t n e r r u c l i e h t a u t u m ® k r a M e d u G s n a t n o c . c n r o s v d a d e x F I , y p o c a e v i e c e r o T s n o i t u o s i l i i r o p e e w s i i i 5 4 4 2 0 2 5 4 9 A C l e e F m r o f t a P m u m n M w d e s u s d n u F i a u d v d n I l l l ® k r a M e d i u G y g e t a r t s l i e t e l p m o c t s o m e h t i i d n a m o t s u C k r a M t e s s A y r a t e i r p o r P d e s a b - n o i t c a s n a r T a d o t s u C r e h t O , k r a M t e s s A t e e r t S t n a r G 5 5 6 1 r o o F h t 0 1 , d r o c n o C 5 4 3 5 - 4 6 6 - 0 0 8 a u n n A a u t u M s h T , 7 d n e l B t e k r a M s d n u F ® k r a M e d i u G , 7 d n e l B t e k r a M s e i g e t a r t S 6 , 1 k r a M e d u G , 7 r e i t n o r F w e N l a b o l G ® k r a M e d i u G S U l a u d i v i d n I , s d n u F ® h t a P e d i u G Y R O G E T A C Y B S M R I F T N E M T S E V N . 8 . 9 t n u o c c A y g e t a r t S e p i t l u M a u t u M y r a t e i r p o r P I r o F . e r u h c o r B a c n a n fi r o F . 1 . 2 . 3 . 4 . 5 . 6 r o F . 7 Bank and Trust Company Platform Disclosure BrochureThis must remain with the Client 

EFFECTIVE MARCH 26, 2025 Efficient Edge RetireReady Disclosure Brochure Form ADV – Appendix 1 For Efficient Edge Advisory Services SEC File Number − 801 56323 IA Firm CRD Number - 109018 ITEM 1 – COVER PAGE This AssetMark Disclosure Brochure provides information about the qualifications and business practices of AssetMark, Inc. (“AssetMark”). If you have any questions about the contents of this Brochure, please contact AssetMark using the above information. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. AssetMark is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. AssetMark, Inc. Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 800-664-5345 assetmark.com Additional information about AssetMark also is available on the SEC’s website at www.adviserinfo.sec.gov. R305_AssetMarkADVRetReady_2025_03  AssetMark Efficient Edge RetireReady Disclosure Brochure Page ii ITEM 2 – MATERIAL CHANGES This section provides a summary of material changes that were made to this brochure since the last update. It includes changes to AssetMark’s Platform and is intended to help Clients determine if they want to review this brochure in its entirety, or contact their Financial Advisor with questions about the changes. AssetMark may make interim updates to this brochure throughout the year. However, you will receive notice of any material changes, which must also be filed with the SEC. To request a copy of the most recent disclosure brochure, write to: AssetMark, Inc. Attention: Adviser Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 800-664-5345 assetmark.com advisorcompliance@assetmark.com There have been no material changes since the last Form ADV Part 2A update in September 2024. This must remain with the Client  Page 1 of 7 ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I ITEM 2 – MATERIAL CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II ITEM 3 – TABLE OF CONTENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ITEM 4 – SERVICES, FEES AND COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 9 – ADDITIONAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 AssetMark Efficient Edge RetireReady Disclosure BrochureThis must remain with the Client Page 2 of 7 ITEM 4 – SERVICES, FEES AND COMPENSATION You should consult with your registered representative and/or your financial adviser on your decision regarding which Asset Allocation Model to select. Your registered representative can assist you in determining which Model will be best suited to your financial needs, investment time horizon and willingness to accept risk. AssetMark does not bear this responsibility. OVERVIEW OF ASSETMARK’S EFFICIENT EDGE ADVISORY SERVICE AssetMark, Inc. (“AssetMark”) is an investment adviser registered with the U.S. Securities and Exchange Commission providing various investment advisory services since 1999. AssetMark Asset Management (AAM) is responsible for AssetMark ‘s proprietary investment strategies. AssetMark is wholly owned subsidiary of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc. is an independent, U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. ASSETMARK’S EFFICIENT EDGE ADVISORY SERVICE INTRODUCTION Asset allocation is an investment strategy for distributing assets among asset classes (and, where applicable, amongst sub-asset classes) to help attain an investment objective. One of the theories supporting an asset allocation strategy is that diversification among asset and sub- asset classes can help reduce volatility over the long term. This disclosure brochure contains information about AssetMark’s investment strategies and the conditions and procedures applicable to the Efficient Edge advisory service, some of which are subject to change. AssetMark’s Efficient Edge service offers three Asset Allocation Models (“Models”), each based on different investor profiles and investment objectives. For these Models, AssetMark analyzes the set of mutual fund portfolios currently made available for use in the Models (the “Available Portfolios”). The Efficient Edge Advisory Service (“Efficient Edge”) is offered by AssetMark exclusively to owners of variable annuity insurance contracts (“Variable Contracts”) issued by Genworth Life and Annuity Insurance Company (“GLAIC”) and Genworth Life Insurance Company of New York (“GLICNY”) (collectively, the “Insurance Companies,” each an “Insurance Company”). Efficient Edge is a service through which owners of Variable Contracts may have the value in their Variable Contract subaccounts allocated pursuant to the investment objective, or “Model,” they select. There is no separate, additional charge to Variable Contract owners for the Efficient Edge service. The set of Available Portfolios is a list of open-end registered mutual funds that have been selected by the Insurance Companies for use by the Efficient Edge service in the development of the Models. The Insurance Companies reserve the right to adjust the list of Available Portfolios from time to time. While AssetMark does not participate in the determination of the list of Available Portfolios, AssetMark does, as part of its Efficient Edge service, perform an investment analysis of each fund on the list of Available Portfolios, to determine which funds, from the available universe of funds, will receive allocations within each Model. THE EFFICIENT EDGE ASSET ALLOCATION MODELS The Investor Profiles and Investment Objectives of each Asset Allocation Model are described below. There is no guarantee that these objectives will be met. You should review this information carefully before selecting an Asset Allocation Model that is most appropriate for you. AssetMark serves as the investment adviser solely for the purposes providing asset allocation and fund selection recommendations on the Asset Allocation Models and for making periodic updates to the Asset Allocation models. When Asset Allocation Models are updated, the Insurance Companies will provide written notice of the updates to the Models at least 30 days in advance of the effective date of the updates. If you wish to accept the changes to your selected Model, you will not need to take any action. If you do not wish to accept the changes to your selected Model, you will be given alternative options as described in your Variable Contract. ASSET ALLOCATION MODELS S E L I 40/60 MODEL MODERATELY CONSERVATIVE 60/40 MODEL MODERATE 70/30 MODEL MODERATELY AGGRESSIVE Investor is willing to accept a moderate to high level of risk, has a long term (15 to 20 years) investment time horizon and is looking for a growth oriented investment. F O R P R O T S E V N I Investor is willing to accept a low to moderate level of risk, has a moderately short term (less than ten years) investment time horizon and is looking for an investment to keep pace with inflation. Investor is willing to accept a moderate level of risk, has a moderately long term (10 to 20 years) investment time horizon and is looking for an investment with the opportunity for long term moderate growth. I allocation mix is 40% equities and 60% fixed income. Growth of capital with a low to moderate level of current income. Target allocation mix is 60% equities and 40% fixed income. Growth of capital but without the price swings of an all equity portfolio. Target allocation mix is 70% equities and 30% fixed income. T N E M T S E V N S Growth and current income. Target E V T C E J B O I AssetMark Efficient Edge RetireReady Disclosure BrochureThis must remain with the Client  Page 3 of 7 CHOOSING AN ASSET ALLOCATION MODEL Each Efficient Edge Advisory Service Model offers a specific fixed allocation between the broad asset classes of equity and fixed income, appropriate for the level of risk, investment time horizon and investment objective specified above for each of the three Asset Allocation Models. These are listed under “The Efficient Edge Asset Allocation Models” shown above. If you are an Efficient Edge client, you must select one, and only one, Asset Allocation Model. All of the contract value in your Variable Contract and all purchase payments will be allocated in accordance with the Model you choose. In addition, you will not be able to invest or allocate any of your contract value in your Variable Contract or any of your purchase payments to the Insurance Company’s Guarantee Account (as defined in your Variable Contract). If you are a Variable Contract owner who has not elected one of the optional living benefit riders available under your Variable Contract, you may choose any one of the three available Asset Allocation Models. To provide further diversification benefits beyond the broad asset class allocations, AssetMark conducts an optimization analysis to determine the appropriate allocations to sub-asset classes for each Asset Allocation Model. While generally AssetMark exercises its own broad discretion in allocating to sub-asset classes, AssetMark may be required by the Insurance Companies to limit certain levels of sub- asset class allocations in order to achieve a level of risk consistent with certain of the optional living benefit riders offered under the Insurance Companies’ Variable Contracts. If you are a Variable Contract owner who has elected one of the optional living benefit riders available under your Variable Contract, there are certain limits, restrictions or conditions on the particular Models that are available to you. Please carefully review your Variable Contract and its current prospectus for more information. Please note that other specified investment options may be available with certain optional riders. Such investment options, however, are not a part of the Efficient Edge Advisory Service. After the asset class and sub-asset class exposures have been identified for each Model, a determination is made as to how the Available Portfolios can be used to implement the asset and sub-asset class allocations. As previously mentioned, the Available Portfolios considered by AssetMark are all those currently available for contributions of new purchase payments by all Variable Contract owners. You must determine which Asset Allocation Model is best for you given your financial situation and investment objectives. The Insurance Companies and AssetMark will not make this decision for you. Part of the process used by AssetMark in determining the allocation to Portfolios in the Models is an evaluation of the asset and/or sub-asset class(es) exposures given by each Portfolio in order to combine Portfolios to arrive at the desired asset and sub-asset class allocation levels. Your registered representative can help you determine which Model is best suited for your financial needs, investment time horizon and willingness to accept investment risk and they can assist you in completing the proper forms. You should periodically review with your registered representative your financial situation and investment objectives to determine if you should change Models or discontinue the Efficient Edge service. AssetMark considers various factors in determining allocations to each Portfolio for each Asset Allocation Model, which may include historical style analysis and asset performance and multiple regression analyses, as well as qualitative assessments of a Portfolio’s portfolio manager and expected future market and economic conditions. Portfolios are not required to report their individual securities holdings directly to AssetMark; therefore, this analysis may include a review of the historic security holdings of the Portfolios, as described in public documents. When consulting with your registered representative, you may use an investor profile questionnaire, available from the Insurance Company, which is designed to help you and your registered representative assess your financial needs, investment time horizon and willingness to accept investment risk. However, even if you use the investment profile questionnaire, it is still your decision as to which Model to select. Neither the Insurance Company nor AssetMark is responsible for this decision. Based on AssetMark’s analyses, Available Portfolios are evaluated based on their potential to optimize returns for each Model, given a particular level of risk tolerance. This evaluation could, in some cases, result in an allocation to a Portfolio in a Model based on its specific asset class, or sub-asset class, exposure or other specific optimization factors, even when another Available Portfolio has exhibited better historical investment performance. MANAGEMENT OF THE ASSET ALLOCATION MODELS BY ASSETMARK AssetMark’s management of the Asset Allocation Models involves a multi-step process designed to optimize the allocations across the list of Available Portfolios, for a given level of risk tolerance, in an effort to maximize expected returns and limit the effects of expected market volatility. In addition, in allocating to Portfolios for a Model, AssetMark can receive (but is not obligated to follow) recommendations from GLAIC and/or GLICNY. One exception is that the Insurance Companies have placed restrictions on the level of risk taken and/or asset class exposure for the Models, based in part on their availability in investment strategies required by Variable Contract optional living benefit riders). These recommendations are based on various factors, including whether the investment adviser or distributor of a Portfolio pays GLAIC and/or GLICNY fees for certain administrative and other services provided to the Portfolio and whether Capital Brokerage Corporation, an affiliate of the Insurance Companies and the principal underwriter of the Variable Contracts, receives 12b-1 fees from the Portfolio. Asset allocation strategies reflect the theory that diversification among asset and sub-asset classes can help reduce volatility and potentially enhance returns over the long term. An asset class is a category of investments having similar characteristics, such as stocks and other equity investments, and bonds and other fixed income investments. There are also further divisions within asset classes, often referred to as “sub-asset classes,” such as divisions according to the size of the issuer (e.g., large cap, mid cap or small cap), the type of issuer (e.g., government, municipal or corporate), or the location of the issuer (e.g., domestic or foreign). Additionally, AssetMark can develop more than one version of each Model, by allocating to some Portfolios in one version and allocating to other Portfolios in another version of the same Model, but you may be offered only one version of each Model because of the Portfolios AssetMark Efficient Edge RetireReady Disclosure BrochureThis must remain with the Client Page 4 of 7 available in your Variable Contract. The Portfolios available for allocation in versions of a Model may differ because of the distribution or marketing of the Variable Contracts or other factors. Additionally, sub- asset class allocations may differ slightly between versions of the same Model. AssetMark is also subject to competing interests that have the potential to influence its decision making with regard to the Efficient Edge Asset Advisory Service. For example, GLAIC and GLICNY may believe that certain Portfolios could benefit from additional assets or could be harmed by redemptions. contract value and purchase payments in accordance with an appropriate level of risk. If you want to make changes to your allocations, you must do so pursuant to the terms of your Variable Contract. You may however, continue to receive written materials about any changes proposed to be made to the Models by AssetMark, and you may notify the Insurance Company in writing to and request allocation of your variable subaccounts in accordance with such materials and consistent with the terms of your Variable Contract. If you would later like to sign up again for the Efficient Edge Asset Allocation services you may do so by contacting your Insurance Company subject to the terms of your Variable Contract. Please use the contact information provided by the Insurance Company. If you are a prospective or new Efficient Edge client selecting a Model within the 30 day period prior to implementation of a change, you will be given information regarding composition of both the current Asset Allocation Model you have chosen as well as the proposed changes to your Model. MONTHLY AND AUTOMATIC REBALANCING OF ASSET ALLOCATIONS The Portfolios underlying the subaccounts invest, depending upon their investment objective and the decisions by their investment managers, in securities issued by Genworth Financial, Inc. AssetMark will not have any role in determining whether a Portfolio should purchase or sell Genworth securities. AssetMark may allocate portions of the Asset Allocation Models to Portfolios which have held, hold or may hold Genworth securities. AssetMark’s decision to allocate a percentage of a Model to such a Portfolio will be based on the merits of investing in such a Portfolio and a determination that such an investment is appropriate for the Model. CHANGES TO ASSET ALLOCATION MODELS On the monthly anniversary of your Variable Contract, the Insurance Company will rebalance your Variable Contract subaccounts and return their allocations to the percentages specified by your current Model. This monthly rebalancing addresses increases and decreases of contract value in each subaccount due to subaccount performance. The first monthly rebalancing will occur at the first monthly anniversary following the Contract Date. AssetMark will periodically, generally annually, evaluate the Asset Allocation Models to assess whether the percentage allocations to each Portfolio should be changed to better optimize the potential return for the level of risk tolerance intended for each Model. AssetMark anticipates that such changes will be made annually, unless more frequent changes are determined by AssetMark to be necessary or appropriate. On any Valuation Day (as that term is defined in your Variable Contract) after any transaction involving a withdrawal, receipt of a purchase payment or a transfer of contract value, the Insurance Company will rebalance your Variable Contract subaccounts and return their allocations to the percentages specified by your current Model. This automatic rebalancing addresses increases and decreases in each subaccount due to subaccount transfers, withdrawals (including if taken from specific subaccounts you designated) and purchase payments (including if allocated to specific subaccounts you designated). If AssetMark determines that the allocations in your Model should be changed, your Insurance Company will send you written notice of the changes at least 30 days before they are to be implemented. Please carefully review these notices. If you want the Model changes implemented, you do not need to take any action. Your Insurance Company will allocate the contract value in your Variable Contract, and any subsequent purchase payments, in accordance with the updated Model received from AssetMark. POSSIBLE RESTRICTIONS AND CHARGES FOR TRANSFERS If you reject the Asset Allocation Model change, you have created a self-directed portfolio. You have terminated your advisory relationship with AssetMark, and AssetMark is no longer providing investment advice or allocations for your Variable Contract subaccounts. Your contract value and purchase payments will not be allocated according to the updated Model. The Insurance Companies may have certain rules and procedures related to the manner, number, and permissibility of, and possible charges or fees for transfers among the subaccounts in your Variable Contract. AssetMark’s Efficient Edge Advisory Service has been designed so that transfers among subaccounts caused 1) by AssetMark’s update of the Models and 2) by the monthly rebalancing of the value in your subaccounts will be permitted by the Insurance Companies without charge. However, restrictions and charges may still be imposed by the Insurance Companies. Please review your Variable Contract prospectus for more information. The Efficient Edge service has not been designed to allow excessive withdrawals and transfers by the Variable Contract owner, in addition to the transfers prompted by AssetMark and the monthly rebalancing, and still ensure that subaccount reallocations do not conflict with the possible restrictions on frequent transfers or are exempt from possible transfer fees applicable to the subaccounts of the Variable Contracts. Please review your Variable Contract prospectus for more information. AssetMark and AssetMark’s advisory personnel do not have access to your Variable Contract and its subaccounts. Any changes to your subaccount allocations must be made by your Insurance Company. If you do not want to accept the changes to your selected Model, you may transfer the contract value allocated to the Model from the Model to another available investment option in your Variable Contract or, if you have elected certain of optional living benefit riders under your Variable Contract, you can notify the Insurance Company in writing that you have elected to reject the change. If you have elected one of the optional living benefit riders available under your Variable Contract, there may be certain limits, restrictions or conditions on the investment you can make and the benefits you receive under such rider may be adversely affected. Your options will be explained to you in your Variable Contract and its prospectus. Please read your Variable Contract and its prospectus for more information. If you have purchased an optional living benefit rider to your Variable Contract that requires your contract value and purchase payments to be invested in an “Investment Strategy,” you should consider how to invest your AssetMark Efficient Edge RetireReady Disclosure BrochureThis must remain with the Client Page 5 of 7 INVESTMENT RISKS Investment Supervisory Services - Referral Model AssetMark receives client referrals through representatives of broker dealer firms and investment advisory firms (these firms are referred to as “Financial Advisory Firms”). AssetMark manages each client Account according to the client’s selected Investment Solution under the terms of the AssetMark Investment Management Services Agreement. AssetMark provides investment supervisory services to clients as described in AssetMark’s “Referral Disclosure Brochure.” AssetMark offers the following advisory services or Investment Solutions under the Referral Model platform: Although the Asset Allocation Models are designed to optimize returns given the various levels of risks, there is no assurance that a Model will not lose money or not experience volatility. Investment performance of contract value could be better or worse by participating in an Asset Allocation Model than if the owner had not participated. A Model may perform better or worse than any single Portfolio, subaccount or asset class or other combination of Portfolios, subaccounts or asset classes. Model performance is dependent upon the performance of the component Portfolios. Contract value will fluctuate, and when redeemed, may be worth more or less than the original cost. Mutual Fund Accounts ETF Accounts Privately Managed Accounts (“PMA”), including: • Individually Managed (“IMA”) Accounts, An Asset Allocation Model may not perform as intended. Although the Models are intended to optimize returns given various levels of risk tolerance, Portfolio, market and asset class performance may differ in the future from the historical performance and assumptions upon which the Models are based, which could cause the Models to be ineffective or less effective in reducing volatility. • Manager Select Accounts (“MSA”), • Savos Preservation Strategy, • Savos Fixed Income Accounts, and Unified Managed Accounts, including: • Privately Managed Portfolios (“PMP”) Accounts, Periodic updating of the Asset Allocation Models can cause the underlying Portfolios to incur transactional expenses to raise cash for money flowing out of the Portfolios or to buy securities with money flowing into the Portfolios. These expenses can adversely affect performance of the related Portfolios and the Models. • GMS Strategies (“GMS”) Accounts, and • Active Return Opportunities (“ARO”) Accounts Investment Supervisory Services - Mutual Funds In addition to providing the foregoing investment supervisory services, AssetMark is also the investment adviser for: 1) GuideMark Funds (no-load sub-advised mutual funds) 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund). Each Portfolio has one or more investment advisers and/or sub- advisers. The Portfolios are managed through a variety of investment strategies and invest in various types of securities depending on their investment strategy, including but not limited to, U.S. and non-U.S. equity and fixed income securities. Each Portfolio’s prospectus includes more complete information, including a discussion of the Portfolio’s investment techniques and the risks associated with its investments. No assurance can be given that a Portfolio will achieve its investment objective. Owners should read each Portfolio prospectus carefully before investing. Other Services - Advisor Model Platform COMPENSATION AssetMark receives compensation from the Insurance Companies for providing the Efficient Edge Advisory Service. There are no additional fees paid by Variable Contract owners who are AssetMark Efficient Edge clients for the Efficient Edge service. In addition to the investment supervisory services offered clients directly by AssetMark upon referral by Financial Advisory Firms, the Platform Investment Solutions are offered by Financial Advisory Firms serving as the individual investment advisor for their clients with accounts invested through the Platform. For these Financial Advisory Firms and their clients, AssetMark serves as the Platform sponsor and provides the Financial Advisory Firms with administrative and consulting services. These services are described in more detail in the Platform Disclosure Brochure. However, Variable Contract owners do pay charges and fees in connection with their ownership of the Variable Contracts and these fees may increase in connection with use of the Efficient Edge Advisory Service. For example, transfer fees may apply on re- allocations of value among subaccounts of the Variable Contract. AssetMark can offer other advisory services on an exception basis. Additionally, the Insurance Companies may receive fees for certain administrative and other services provided to the Portfolio, and CBC and the Insurance Companies may receive 12b-1 fees from Portfolios, including those advised by third parties. As of 12/31/2024, the Efficient Edge Advisory Service had assets totaling $543.7 million. OVERVIEW OF ASSETMARK’S OTHER ADVISORY SERVICES AssetMark provides a variety of investment advisory services to clients as described below. This brochure discusses only AssetMark’s Efficient Edge Advisory service in detail. AssetMark faces a number of conflicts of interest between its duty to serve its Efficient Edge clients and the advisory services it provides to other individual clients, other insurance contract owners and its mutual fund shareholders. For example, AssetMark faces a conflict as to the timing of its advisory recommendations for other clients as those recommendations relates to recommendations for Efficient Edge clients, as well as conflicts arising regarding the availability of information as to what type of advisory recommendations – potentially containing useful information – are being performed for other clients. Additionally, AssetMark faces conflicts over its ability to take certain trades to market for other clients while in possession of information about the intended advice to be provided to Efficient Edge clients. AssetMark also provides services to its other mutual fund clients in the selection, review and AssetMark Efficient Edge RetireReady Disclosure BrochureThis must remain with the Client Page 6 of 7 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS termination of third-party investment management firms to serve as sub-advisers to its funds, a service provided for Efficient Edge clients through the evaluation of third-party fund managers. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS The Efficient Edge Advisory Service is offered to owners of select variable contracts issued by the Insurance Companies. Owners of a Variable Annuity Contract who have opted for the Efficient Edge Advisory Service will not generally have access to the AssetMark investment management staff that constructs the Asset Allocation Models. Clients will also not generally have access to the investment management staff at the mutual fund companies that manage the Portfolios in the list of Available Portfolios. Clients of the Efficient Edge Advisory Service should consult with their registered representative for information about the ongoing activities of their Asset Allocation Model. HOW TO BECOME AN EFFICIENT EDGE ADVISORY SERVICE CLIENT ITEM 9 – ADDITIONAL INFORMATION DISCIPLINARY INFORMATION This disciplinary information is with regard to AssetMark’s other advisory services, as described above. The services described in the AssetMark’ s disciplinary information were not available through the Efficient Edge Advisory Service. You must own a Variable Contract issued by GLAIC or GLICNY for which AssetMark’s Efficient Edge Advisory Service is offered. You may sign up for the service with forms provided by the Insurance Company which issue your Variable Contract. You do not need to sign a separate agreement with AssetMark; however, AssetMark will only follow written instructions from you received by your Insurance Company in a form acceptable to the Insurance Company. The terms of your agreement with AssetMark are contained in this Disclosure Brochure. There is no minimum account value required for the AssetMark Efficient Edge service, although there may be minimum Variable Contract values imposed by the Insurance Companies. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION AssetMark Asset Management (“AAM”) requires that employees providing investment advice are required to have financial or analytical experience or to have qualified for registration as an Investment Advisory Representative as required by applicable state securities regulations, either by having passed the Uniform Investment Adviser Law Examination (Series 65) or by possessing other qualifying designations such as the Chartered Financial Analyst (CFA) designation. In addition to the foregoing, members of AAM are generally required to have a college education or equivalent experience, analytical or portfolio management experience, and/or to have obtained the CFA designation. On September 26, 2023, the SEC issued an Order Instituting Administrative Cease-and-Desist Proceedings against AssetMark. The SEC alleged that, from at least September 2016 through January 2021, AssetMark failed to fully disclose that AssetMark and affiliate AssetMark Trust Company together set the amount of the payment that AssetMark Trust would retain as compensation from the payment received by the banks that participated in the FDIC-Insured Cash Deposit Program (“ICD Program”) (the “ICD Program Fee”), which, in turn, determined the amount that would be distributed as interest by the banks to clients. The SEC alleged that AssetMark had failed to fully disclose the associated conflicts of interest related to its role in setting the ICD Program Fee. The SEC also alleged that AssetMark, from at least January 2016 through August 2019, did not fully disclose the associated conflicts of interest related to AssetMark’s receipt of custodial support pay-ments funded through payments from certain no-transaction fee (“NTF”) mutual funds. The SEC alleged that these failures constituted breaches of AssetMark’s fiduciary duty to advisory clients. The SEC alleged that As-setMark violated Section 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 promulgated thereunder. AssetMark consented to the Order without admitting or denying the SEC’s findings. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The Insurance Companies are responsible for providing information to clients and/or to their registered representatives concerning all aspects of the Efficient Edge Advisory Service, including such items as investment performance, allocation changes, market updates and changes to the list of Available Portfolios. On August 25, 2016, the SEC announced a settlement with AssetMark in an order contained findings, which AssetMark neither admitted nor denied, that AssetMark violated Section 206(4) of the Advisers Act and Rule 206(4)-1(a)(5) by allowing its staff, from July 2012 through October 2013, to circulate to prospective clients who were considering an F-Squared managed account service offered by AssetMark, performance advertisements created by F-Squared relating to a different separately managed account service not offered by AssetMark and that misleadingly described that different service’s performance between 2001 and 2008, and that AssetMark violated Section 204(a) of the Advisers Act and Rule 204-2(a)(16) by failing to maintain records substantiating the performance in the advertisements created by F-Squared. There are no disciplinary items to report for the management of AssetMark. AssetMark Efficient Edge RetireReady Disclosure BrochureThis must remain with the Client Page 7 of 7 FINANCIAL INDUSTRY AFFILIATES ASSETMARK’S CODE OF ETHICS FOR PERSONAL SECURITIES TRANSACTIONS AssetMark was previously named Genworth Financial Wealth Management, Inc. and was renamed AssetMark, Inc. following its separation from Genworth Financial, Inc. AssetMark is also the investment adviser for the GuideMark Funds, and the GuidePath Funds. AssetMark Brokerage, LLC is a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”) and acts as the distributor for the GuideMark Funds, and the GuidePath Funds. AFFILIATED COMPANIES The following are AssetMark affiliated companies under common control. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its clients. These companies are not relevant to AssetMark’s provision of the Efficient Edge Advisory Service. • Atria Investments, Inc. (d/b/a Adhesion Wealth) • AssetMark Trust Company (AssetMark Trust) • AssetMark Services, Inc. • AssetMark Brokerage, LLC (AssetMark Brokerage) NON-AFFILIATED COMPANIES Insurance Companies AssetMark has adopted a Code of Ethics (the “Code”) that is intended to comply with the provisions of Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”), which requires each registered investment adviser to adopt a code of ethics setting forth standards of conduct and requiring compliance with federal securities laws. Additionally, the Code is designed to comply with Section 204A of the Advisers Act, which requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by any person associated with such investment adviser. The Code requires that all “Supervised Persons” (including officers and certain affiliated persons and employees of AssetMark) in carrying out the operations of AssetMark, adhere to certain standards of business conduct. Specifically, the Code requires that these persons: (i) comply with all applicable laws, rules and regulations, (ii) avoid any conflict of interest with regard to AssetMark and its Clients, (iii) avoid serving their personal interests ahead of the interests of AssetMark and its Clients, (iv) avoid taking inappropriate advantage of their position with AssetMark or benefiting personally from any investment decision made, (v) avoid misusing corporate assets, (vi) conduct all of their personal securities transactions in compliance with the Code, and (vii) maintain, as appropriate, the confidentiality of information regarding AssetMark’s operations. The Efficient Edge Advisory Service is offered by AssetMark exclusively to owners of Variable Contracts issued by Genworth Life and Annuity Insurance Company and Genworth Life Insurance Company of New York. Broker-Dealers Capital Brokerage Corporation (“CBC”) is a broker-dealer registered with the U.S. Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority (“FINRA”). CBC serves as the principal underwriter of the Variable Contracts. CLIENT REFERRALS The Insurance Companies make the Efficient Edge Advisory Service available to owners of select Variable Contracts they offer. AssetMark does not pay the Insurance Companies a specific fee for these referrals. PRIVACY POLICY The Code contains a number of prohibitions and restrictions on personal securities transactions and trading practices that are designed to protect the interests of AssetMark and its Clients. First, the Code prohibits trading practices that have the potential to harm AssetMark and/or its Clients, including excessive trading or market timing activities in any account that AssetMark manages, trading on the basis of material non-public information, and trading in any “Reportable Security” when they have knowledge the security is being purchased or sold, or is being considered for purchase or sale by the Accounts managed by AssetMark or any AssetMark-advised mutual funds. Second, the Code mandates the pre-clearance of certain personal securities transactions, including transactions in securities sold in initial public offerings or private placements. The Code also requires the pre-clearance of Reportable Security transactions for certain Access Persons (Access Persons is a segment of the Supervised Persons group that have access to AssetMark information). Finally, the Code requires Access Persons to submit, and the Chief Compliance Officer (the “CCO”) to review, initial and annual holdings, and quarterly transaction reports. The Privacy Policy supplied to you by your Insurance Company will govern the Efficient Edge Advisory Service. QUARTERLY REPORTS Efficient Edge Variable Contract owners will receive quarterly account statements from their Insurance Company which include information about the subaccounts in their Model. AssetMark utilizes StarCompliance to provide enhanced tracking of certain employee transactions and gives AssetMark the ability to analyze those employee trades against certain parameters and transactions in its managed Accounts or any AssetMark-advised funds. Access Persons also utilize this system to annually certify their receipt of, and compliance with, the Code and pre-clear their Reportable Security transactions, if they are required to do so by the Code. ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS Not Applicable All Supervised Persons under the Code are responsible for reporting any violations of the Code to the CCO. The Code directs the CCO to submit reports to the Board of Trustees of any AssetMark-advised mutual funds regarding compliance with the Code, and to impose sanctions on violators, as warranted. AssetMark will provide a copy of the Code to any Client or prospective Client upon request. AssetMark Efficient Edge RetireReady Disclosure BrochureThis must remain with the Client

EFFECTIVE MARCH 26, 2025 Platform Disclosure Brochure Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure SEC File Number − 801 56323 IA Firm CRD Number - 109018 ITEM 1 – COVER PAGE This Disclosure Brochure provides information about the qualifications and business practices of AssetMark, Inc. (“AssetMark”). If you have any questions about the contents of this Brochure, please contact AssetMark using the information shown on the left. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. AssetMark is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. AssetMark, Inc. Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 800-664-5345 Additional information about AssetMark is also available on the SEC’s website at www.adviserinfo.sec.gov. R274_PlatDsclBro_2025_03  AssetMark Platform Disclosure Brochure Page ii ITEM 2 – MATERIAL CHANGES This section provides a summary of material changes that were made to this brochure since the last update. It includes changes to AssetMark’s Platform and is intended to help Clients determine if they want to review this brochure in its entirety or contact their Financial Advisor with questions about the changes. AssetMark can make interim updates to this brochure throughout the year. However, you will receive notice of any material changes, which must also be filed with the SEC. Information about AssetMark is available on the SEC’s website at www.adviserinfo.sec.gov or at www.assetmark.com. You can also request a copy by contacting us at: AssetMark, Inc. Attention: Adviser Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 800-664-5345 advisorcompliance@assetmark.com There have been no material changes since the last Form ADV Part 2A Appendix 1 update in September 2024. The following updates were made, in addition to clarifying edits in the disclosure brochure: • Item 4 – Services, Fees and Compensation - Additional disclosures about investments in funds managed by AssetMark or AssetMark affiliates. - Additional information about refund of prepaid Account fees for withdrawals. • Item 5 – Account Requirements and Types of Clients - Investment Minimums – Account Size • Item 6 – Portfolio Manager Selection and Evaluation - Updates to Shareholder Materials, Proxy Voting and Class Actions • Item 9 – Additional Information - Updates to FDIC-Insured Cash Programs Additional information under Custodial Relationships • Exhibit B – AssetMark Asset Management – Solution Types - Upcoming management change for MarketDimensions and OBS Strategies This must remain with the Client  Page 1 of 38 ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i ITEM 2 – MATERIAL CHANGES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii ITEM 3 – TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ITEM 4 – SERVICE, FEES AND COMPENSATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • WRAP FEE PROGRAM – THE FINANCIAL ADVISOR FIRM AND THE CLIENT SERVICES AGREEMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • ASSETMARK, INC. AND ITS OWNERSHIP STRUCTURE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • DESCRIPTION OF PLATFORM SERVICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 • OTHER SERVICES AND NON-MANAGED ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 • INVESTMENT VEHICLES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 • ASSETS UNDER MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 • FEES AND COMPENSATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 • SELECTION AND REVIEW OF PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS . . . . . . . . . . . . . . . . . . . . . . . . 14 • ASSETMARK AS PORTFOLIO STRATEGIST OR INVESTMENT MANAGER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 • REVIEW OF ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 ITEM 9 – ADDITIONAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 • DISCIPLINARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 • OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 • CUSTODIAL RELATIONSHIPS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 EXHIBIT A – SOLUTION TYPES – MODEL PROVIDERS AND INDIVIDUAL MANAGED ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 EXHIBIT B – ASSETMARK ASSET MANAGEMENT SOLUTION TYPES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 EXHIBIT C – PROPRIETARY MUTUAL FUND SOLUTIONS - CONFLICTS OF INTEREST DISCLOSURES . . . . . . . . . . . . . . . . . . . . . . . . . 34 FEES AND INVESTMENT MINIMUMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 AssetMark Platform Disclosure BrochureThis must remain with the Client Page 2 of 38 ITEM 4 – SERVICE, FEES AND COMPENSATION WRAP FEE PROGRAM – THE FINANCIAL ADVISORY FIRM AND THE CLIENT SERVICES AGREEMENT AssetMark is responsible for the selection and management of subadvisors for each of the GuideMark Funds. However, the Client and the Financial Advisor, and not AssetMark, are responsible for selecting the Solution Type that uses Proprietary Funds. AssetMark, Inc. (“AssetMark”) is the sponsor of the AssetMark Platform (“Platform”) through which it offers its advisory and Platform services to Clients (the “Client”). Representatives of third-party investment adviser firms (these firms are referred to in this brochure as “Financial Advisory Firms” and their representatives are referred to as the “Financial Advisors”) consult with Clients to assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet the Client’s financial needs. AssetMark is not registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor, based on its determination that it will rely on certain exemptions from registration provided by the Commodity Exchange Act (“CEA”) and the rules thereunder. The CFTC has not passed upon the availability of these exemptions to AssetMark. AssetMark currently acts as a registered “commodity pool operator” (“CPO”) with respect to the GuidePath Managed Futures Strategy Fund and its wholly owned controlled foreign corporation, the GuidePath Managed Futures Strategy Cayman Fund. AssetMark is registered as a CPO under the CEA and the rules of the CFTC. AAM acts as the Portfolio Strategist (described below) providing Model Portfolios (described below) for a number of Solutions. It is also among the Discretionary Managers (described below) offered on the Platform. With respect to those Strategies in which AssetMark acts as a Discretionary Manager, its obligations are accordingly those of a Discretionary Manager and include the selection of securities for the Account (consistent with the Strategy (described below) selected by the Financial Advisor and Client) and trade execution. A list of Portfolio Strategists/Model Providers and Investment/Discretionary Managers are provided in Exhibit A. Individual Solutions are available either through third-party Investment Management Firms (described below) or as proprietary Strategies managed by AAM. Strategists are also permitted to use AssetMark proprietary investment options or funds as part of a Strategy. DESCRIPTION OF PLATFORM SERVICES In order to participate in the Platform, the Client and the Financial Advisory Firm will enter into a Client Services Agreement (“CSA”) or other advisory agreement that outlines the services to be performed by the Financial Advisory Firm, the authority of the Financial Advisory Firm, the compensation payable by the Client, and other important provisions governing participation in the Platform. The Financial Advisory Firm evaluates the Client’s investment needs and objectives, consults with the Client concerning the Client’s participation in the Platform and is responsible for determining the suitability of various Solution Types (“Solution Types”) for the Client’s investment objectives and financial condition. The Financial Advisory Firm, through its Financial Advisor, not AssetMark, recommends the Strategy to the Client and monitors whether to recommend that the Client remain in the selected Strategy. Each of the Solution Types may be implemented with a number of options, including a range of Risk/Return Profiles (the “Risk/Return Profiles”) and Investment Approaches (the “Investment Approaches”), each described below, so that the Client can customize a strategy by which each of the Client’s accounts under the Platform will be managed or maintained. The specific Solution Type and the components of the strategy selected for the Client’s Account are referred to as the Client’s investment “Strategy.” A Client will establish one or more investment accounts (each an “Account”) through the Platform, and the Client’s Accounts are collectively referred to as the Client’s “Portfolio.” ASSETMARK, INC. & ITS OWNERSHIP STRUCTURE Financial Advisory Firms enter into an agreement with AssetMark to access the Platform for their Clients. As part of the Platform services, AssetMark provides account administration, custody, brokerage and advisory services; the Platform is therefore considered a “wrap program.” AssetMark has developed internet-based software which provides the Financial Advisory Firm with the ability to directly monitor its Clients’ Accounts, download information concerning changes in the Platform, and access current information relating to the Platform. AssetMark is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since 1999 providing various investment advisory and consulting services to other advisors and investment Clients. AssetMark and AssetMark Trust Company (“AssetMark Trust”) are wholly owned subsidiaries of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc. is an independent, U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. AssetMark Wealth Solutions includes AssetMark’s Asset Management (AAM), Due Diligence, Investment Consulting, and other portfolio, wealth, and practice solutions. AAM is responsible for AssetMark’s proprietary investment strategies. If the Financial Advisor selects for the Client a Solution Type (or “Solutions,” described below) managed by AAM, AssetMark is responsible for the management of that Solution Type for the Client’s Account (described below). AssetMark also serves as the investment adviser for the GuideMark Funds and GuidePath Funds (each a “Fund” and collectively the “Proprietary Funds”) available in certain Solution Types on the Platform: 1) GuideMark Funds (no-load sub-advised mutual funds) To establish a Client’s Account on the Platform, the Financial Advisory Firm and Client will enter into an advisory agreement. A Client will typically complete a questionnaire, or otherwise provide information to the Financial Advisory Firm, to enable the Client and the Financial Advisory Firm to identify the Client’s risk tolerance and rate of return objectives. The Client typically will provide the Financial Advisory Firm with information concerning the Client’s investment experience, anticipated need for liquidity, potential timing of the need for retirement funds, and other investment needs and parameters. This information will assist the Client and the Financial Advisory Firm in selecting which of the Risk/Return Profiles (described below) is most closely aligned with the Client’s investment goals. The Financial Advisory Firm remains responsible for monitoring the Solution Types and Risk/Return Profiles and recommending any changes to the Client throughout the duration of the Client’s Account on the Platform, including any custom accounts at third-party Discretionary Managers. AssetMark’s responsibility is to implement the Solution Type and Risk/Return Profile chosen by the Client and the Financial Advisory Firm. AssetMark does not advise the Client about potential changes to the Client’s Solution Type or Risk/Return Profile. 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund) AssetMark Platform Disclosure BrochureThis must remain with the Client Page 3 of 38 RISK RETURN PROFILES over a diversified benchmark through active management – Enhanced Return Focus), income (ie equity dividends) or defense (limiting losses during market downfalls through reducing equity exposure – Limit Loss Focus – holding lower beta securities or using hedging strategies) One of the fundamental elements of the Platform is establishing the Client’s appropriate Risk/Return Profile. These Profiles range from most conservative (lowest estimated risk and lowest potential return) to most aggressive (highest estimated risk and highest potential return). Strategies on the Platform can only have a single risk profile or may have multiple risk profiles. The investment objectives for each of the six Risk/Return Profiles are listed below: 3. Bond: Strategies that are mainly invested in fixed income and are typically a single risk profile (Bond and Bond Alternatives). Some Bond Strategies may include some low volatility alternative or equity exposure. These Strategies can help manage risk through diversification benefits and may focus on either a total return, income or defensive (typically lower duration) investment mandate • Profile 1 – Conservative: The profile is designed for an investor who wants to focus on preservation of capital as a primary goal and wishes to minimize downside risk. 4. Alternative: Strategies that are mainly invested in non-correlated liquid alternative strategies to provide diversification benefits to help manage risk. Alternative Strategies are typically a single risk profile and can invest in traditional alternative strategies, niche strategies or trend following strategies (managed futures – Equity Alternatives). • Profile 2 – Moderate Conservative: The profile is designed for an investor who seeks to preserve capital but wishes to assume moderate downside risk in order to earn a return sufficient to preserve purchasing power. SOLUTION TYPES • Profile 3 – Moderate: The profile is designed for an investor who seeks to balance risk of loss to capital with capital appreciation. Investment Strategies are available through three general “Solution Types” (or “Solutions”) on the Platform. • Profile 4 – Moderate Growth: The profile is designed for an investor who seeks enhanced capital appreciation and is willing to accept greater risk of downside loss and volatility of returns. • Profile 5 – Growth: The profile is designed for an investor who seeks significant capital appreciation and is willing to accept a correspondingly greater risk of loss and volatility of returns. • Profile 6 – Maximum Growth: The profile is designed for an investor who seeks the highest level of capital appreciation and is willing to accept the correspondingly greater risk of loss and volatility of returns. • Model Portfolios – Client Accounts are allocated among securities and other investment vehicles on a non-discretionary basis pursuant to Model Portfolios provided by “Portfolio Strategists” (also referred to as “Model Providers”). Model Portfolios include mutual fund and ETF investment strategies and Separately Managed Accounts (“SMA”). SMA Model Portfolios are allocated among securities and other investment vehicles in accordance with the model and are typically selected for a specific asset class. AssetMark will serve as the Overlay Manager (described below) with regard to SMA accounts. Generally, the percentage allocation to equity securities targeted for each Risk/Return Profile increases for each Profile from Profile 1, Conservative, which would represent the lowest target allocation of equity securities, through Profile 6, Maximum Growth, which would represent the highest target allocation of equity securities. INVESTMENT STRATEGIES • Individually Managed Accounts (“IMA”) – The Client Account is managed and individual Client Account trades are implemented on a discretionary basis by a “Discretionary Manager” (also referred to as an “Investment Manager”). For some IMAs, AssetMark serves as the Discretionary Manager; for others, a third-party manager serves as Discretionary Manager and AssetMark has no role in trading for the IMA. Another element of establishing the Client’s investment objective is to identify the appropriate mix of Investment Strategies to manage risk efficiently and meet the Client’s return objectives. Each Portfolio Strategist, Investment Manager and/or Solution Type is classified by AssetMark based on their Investment Strategy. The Client, with the assistance of their Financial Advisor, can select Solution Types for their Portfolio that represent a blend of different Investment Strategies. There are four main types of investment strategies which can be used in a client portfolio: 1. Core: A mix of predominantly equities and fixed income across US or global markets and has multiple risk profiles. Other asset classes, including real assets and alternatives may be included to help manage risk. Strategies may focus on a total return or income mandates. Some Core Strategies may offer a tax aware option whereby tax-exempt fixed income investments are held within portfolios and in some cases tax-managed equity investments can also be held. For some Core Strategies, holding periods and turnover levels will be considered; however, AssetMark cannot guarantee that the portfolios will behave in a tax-sensitive manner over any given time period. • Individual Mutual Fund (“IMF”) – Client accounts are allocated to a single mutual fund and is intended to complement other Solution Types available on the AssetMark Platform, as part of the Client’s overall Portfolio. The IMF’s used in this advisory service can be Proprietary or third-party funds. Each IMF is not available at all Platform Custodians. Clients should be aware that the Platform Fees charged by AssetMark for this service can be higher or lower than those charged by others in the industry or directly from the third-party mutual fund provider, and that it can be possible to obtain the same or similar services from other investment advisers at lower or higher rates. AssetMark may waive the Platform Fee in its discretion. A Prospectus for any individual mutual fund made available under this Solution Type can be obtained upon request from AssetMark or the Client’s Financial Advisor. Clients should review fund prospectuses and consult with their Financial Advisor if they have questions regarding these IMF Solution Types. The mutual funds shares selected for use can be institutional or retail shares, and can include administrative service fees, sub-transfer agency fees and/or 12b-1 fees, that are fees borne by Clients. See Servicing Fees Received by Custodians, including AssetMark Trust and Share Class Use for a discussion of 12b-1 fees, administrative service fees and sub-transfer agency fees and the Fees & Investment Minimums table at the back of this Disclosure Brochure for the Platform Fees charged IMFs. 2. Equity: Strategies that are mainly invested in equities and are typically a single risk profile. Equity Strategies may focus on one of three investment mandates; total return (enhancing return AssetMark Platform Disclosure BrochureThis must remain with the Client Page 4 of 38 The client’s Investment Strategy can be customized to each clients account and implemented with a number of features and alternatives, such as: • a range of Risk/Return Profiles; • selection of one or more Investment Strategies and Mandates; • a group of available Portfolio Strategists or Investment Managers; investments for the Account, vote proxies for securities held by the Account, to select the broker-dealers or others with which transactions for the Accounts will be effected, and such other actions that are customary or appropriate for an Investment Manager to perform. The Investment Manager is responsible for selecting the securities for Client investment, including the share class if the investment is in mutual funds. Custody fees, if charged, are asset based. Usually, transaction fees are not charged to IMA accounts. and Step Out or Trade Away Trades for IMAs • various IMA’s, so that the Client, as advised by the Financial Advisor, can create a Strategy by which each of the Client’s Accounts under the Platform will be managed or maintained. Some Solution Types are available through third-party Investment Management Firms unaffiliated with AssetMark. Other Solution Types are proprietary Strategies available through AAM, or Individual Mutual Funds as described above. AssetMark makes available fact sheets and other information to assist the Financial Advisor and Client in making an informed decision. More detailed information about the proprietary solutions are provided in Exhibit B – AssetMark Asset Management – Solution Types. Overlay Manager The Investment Manager has the authority to “step-out” or “trade away” a trade and use a brokerage firm other than that usually used with the Client’s selected Custodian, and such trading will result in additional fee(s) from the Platform Custodian, unless such fees are waived (refer to Item 9 under “Brokerage Practices”). If a Discretionary Manager of an IMA determines to “step out” or “trade away” a trade, the Custodians are permitted to assess a fee of $20.00 per trade. This transaction fee would be in addition to any commission or trading costs. If an Account is invested in fixed income investments, e.g., a Parametric bond ladder IMA, the Client should expect this $20.00 fee on each security transaction. Commission charges, dealer spreads, markups/ downs, and foreign currency conversion rates associated with these transactions may not be visible to you in your program documents. For SMA Investment Solutions, the Client, with the assistance of their Financial Advisor, shall select a model provided by a Portfolio Strategist and AssetMark will serve as the “Overlay Manager” (or Investment Manager or Discretionary Manager) for Client Accounts. The Overlay Manager shall provide limited discretionary investment management services to the Account as discussed further below. The Client grants the Overlay Manager the authority to buy and sell securities and investments for the Account, to vote proxies and to effect corporate actions. AssetMark has contracted with Portfolio Strategists to provide recommendations for exposures to specific asset classes or securities. For Clients selecting an IMA, their Account will be managed by an Investment Manager consistent with the Strategy selected by the Client. The Investment Manager shall provide discretionary investment management services to the Account, and the Client grants the Investment Manager the discretionary authorities discussed above. AssetMark can replace the Investment Manager at its discretion. Certain Custom IMAs are available in the Core Markets Investment Approach and the six Risk/Return Profiles, as described above under Risk/Return Profiles. In certain IMA Solutions, Clients will receive from the Investment Manager, and will be required to acknowledge receipt of, additional disclosures regarding specific investments, such as alternative investments, the use of the IMA managers mutual funds, or the use of options and/or certain fixed-income solutions. Use of Mutual Funds Managed by IMA Manager The SMA Model Portfolios have been constructed by Portfolio Strategists engaged by AssetMark using individual securities recommendations. The Overlay Manager will have limited discretionary authority to execute transactions in each Account necessary to (i) track any reallocations, rebalance or other adjustments to the SMA asset allocations constructed by the Portfolio Strategists, (ii) implement changes recommended by the Portfolio Strategists; (iii) effect sale transactions of specified securities as directed by the Client and purchases of replacement securities; and (iv) implement trades to support advisor-directed tax- loss harvesting requests for clients and (v) implement any individual securities restrictions imposed on the Account by the Client. As Overlay Manager, AssetMark intends to invest the Account consistent with the models provided by the Portfolio Strategist, unless circumstances indicate that modified allocations or investments are appropriate. The Client, with assistance of their Financial Advisor, can specify the initial Portfolio Strategist for the Account and will be given notice of any change to that Portfolio Strategist. Individually Managed Accounts (“IMA”) An IMA can be established as: • Equity/Balanced; • Fixed Income; and • Custom High Net Worth IMA Managers can include in the IMA Client accounts they manage mutual funds that they or an affiliate manage. In these situations, the IMA Manager typically receives fees from AssetMark for their management of the Client’s Account, and they or an affiliate typically receive investment adviser or other fees from the funds they or the affiliate manage. This is a conflict because it can create an incentive for the IMA Manager to select their own or affiliated funds. These fees can exceed what the IMA Manager would receive for using third- party mutual funds. Clients should discuss this conflict with their Financial Advisor. Clients will also receive the IMA Manager’s Form ADV Disclosure Brochure which will disclose all conflicts of interests. The IMA Manager also provides additional disclosures regarding their rebate process in order to avoid collecting two fees on the same assets. In some instances, the IMA Manager will receive fees from AssetMark and rebate the portion of fees received from the funds they or the affiliate manages. In other cases, the IMA Manager will receive their fees from the funds they or the affiliate manages, and rebate the portion of the fees received from AssetMark. To the extent that an IMA Manager invests Account assets in a fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. The Investment Manager will provide discretionary investment management services to the Account and the Client grants the Investment Manager the authority to buy and sell securities and AssetMark Platform Disclosure BrochureThis must remain with the Client Page 5 of 38 Custom GPS Select Use of Options Options strategies will be used for certain IMA Solutions. GPS Select, as described in Exhibit B – AssetMark Asset Management – Solution Types, can be customized within a specific range from the baseline to various Investment Strategies. The Client, with the advice of their Financial Advisor, not AssetMark, can select from various Investment Approaches from Portfolio Strategists and Investment Managers, including AAM, and Proprietary Funds. In doing so, and by selecting within the range of pre-determined allocations, a Custom GPS Select account will be established. Each Portfolio Strategist, Investment Manager or mutual fund selection is referred to as a “sleeve” allocation. If a mutual fund Solution Type is selected, the share class used will be consistent with the underlying single strategy solution. The Financial Advisor is responsible for advising the Client on an ongoing basis whether or not to maintain or change the Investment Strategy, the Portfolio Strategist and the Investment Manager for the duration of the account. AssetMark does not advise the Client about the Investment Strategy, the Portfolio Strategist or the Investment Manager appropriate for that Client’s Account. Clients should consider their financial resources, investment objectives and tolerance for risk and should be aware that options trading can be highly speculative and could result in financial losses even though margin borrowing will not be used for the types of options traded by these Client Accounts. Clients will be obligated to deliver the underlying security within the prescribed time for a call option that is exercised. Each of AssetMark and the Investment Manager is authorized to act as the Client’s agent to complete the Client’s obligations with respect to any options in the Client Account. The Client agrees to assume the financial risks of options transactions. All options transactions are subject to the rules, regulations, customs and practices of The Options Clearing Corporation (OCC) and the securities exchange, association or clearing organization through which the transactions are executed. Expiring options that are valuable (meaning, in the money) are exercised automatically pursuant to the exercise by exception procedure of the OCC. Additional Information about the risks, characteristics and features of options is available at: https://www.theocc.com/company- information/documents-and-archives/options-disclosure-document . Custom High Net Worth AssetMark will make available the specific range of pre-determined allocations, which range will be updated from time to time. The number of sleeves selected can vary from a minimum of three to a maximum of eight sleeve selections, to comprise the entire Custom GPS Select account. The standard minimum account by sleeve varies and AssetMark’s revenue will increase or decrease based on the sleeve allocation agreed upon between the Client and Financial Advisor. Savos Custom GMS, PMP, Advisor – Custom, or Personal Portfolios (Refer to Exhibit B – AssetMark Asset Management – Solution Types for more detailed information regarding the selection of AAM strategies to be used within these custom accounts.) • Custom GMS and Privately Managed Portfolios (“PMP”): The Client, with the assistance of the Financial Advisor, can request that AAM deviate from standard allocations for the selected GMS or PMP Strategy. Such an Account is considered a Custom GMS or PMP Strategy. For Custom High Net Worth (“HNW”) accounts, the Client, with the assistance of the Client’s Financial Advisor, selects an Investment Manager to manage the individual Client Account and to provide discretionary investment management services to the Account. The Client grants the Investment Manager the authority to buy and sell securities and investments for the Account, to re-balance and re- allocate assets within the Account, to vote proxies for securities held by the Account and such other discretionary authorities as determined between the Client, their Financial Advisor and the Investment Manager. As such, the Client’s personalized investment objective can go beyond the standard investment objectives listed for each of the six Risk/ Return Profiles as described earlier in this section, and as developed by the Investment Manager for the Client. The Investment Manager, in its discretion, will maintain investment decision records with regards to the Client’s HNW Account. If a Client’s investment objective and/ or Risk/Return Profile changes, the Financial Advisor is responsible for notifying AssetMark of the change. FINANCIAL ADVISOR – CUSTOM ACCOUNTS Multiple Strategy Accounts • Advisor – Custom Accounts: The Client can choose to participate in a program in which their Financial Advisor, in consultation with AAM, can request further customization for their Client’s Account (“Advisor – Custom Accounts” or “ACA”). The Financial Advisory Firm will be solely responsible for determining the additional customization and the suitability for the Client. AAM, in its discretion, will determine the implementation of the ACA. The Financial Advisory Firm can request that AAM recommends to the Financial Advisory Firm asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the ACA developed by the Financial Advisory Firm may not be consistent with the Investment Strategies or Risk/Return Profiles described in this Disclosure Brochure for the GMS or PMP Accounts described in Exhibit B – AssetMark Asset Management – Solution Types. The GMS or PMP Platform Fee schedules will be charged to the Client Account, unless otherwise negotiated between the Financial Advisory Firm and AssetMark. Certain Model Solutions discussed above are also available as sleeve- level options within a Multiple Strategy Account. In a Multiple Strategy Account, an Account can be customized with no set allocation limits. The Client, with the assistance of their Financial Advisor, can select from various Portfolio Strategists and Investment Managers, including AAM, and AssetMark-advised mutual funds (“Proprietary Funds”). In selecting and determining the allocations in each sleeve, a Multiple Strategy Account will be established. The number of sleeves selected can vary from a minimum of two to a maximum of eight selections, to comprise the Multiple Strategy Account and will be evaluated on a quarterly basis for rebalancing across the sleeves. The standard minimum account by sleeve will vary. The fees charged for the Multiple Strategy Account will be based on the single-strategy fee schedule for each Strategist selection and based on the allocation to each sleeve. • Savos Personal Portfolios – Custom: A Savos Personal Portfolios - Custom Account can be customized within a specific range across equity, fixed-income and tactical allocations. The Client, with the assistance of their Financial Advisor, can select from various Savos strategies. In doing so, and by selecting within the range of pre-determined allocations, a Savos Personal Portfolios - Custom Account will be established. Each equity, fixed-income and tactical allocation is referred to as a “sleeve” allocation. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 6 of 38 Advisor As Strategist Program and Advisor Managed Portfolios Program or for otherwise enforcing any rights with respect to Alternative Investments held in Client Accounts. AssetMark is under no obligation to take any action should there be a default, bankruptcy, or other impairment associated with Alternative Investments. Before you invest in an Alternative Investment, your Financial Advisor will review the Alternative Investment and determine that the Alternative Investment is appropriate and suitable for you. You will be provided disclosures through the iCapital Platform that will explain the risks in the Alternative Investment, including, for example, lack of liquidity. Alternative Investments are speculative and involve a substantial degree of risk, including the risk of complete loss. There can be no assurance that Alternative Investments will achieve its investment objective. A Financial Advisory Firm may participate in the Advisor as Strategist or Advisor Managed Portfolios program (“AAS” or “AMP” program). In these programs, a Discretionary Client Services Agreement or advisory agreement is executed by the Client; the Client grants the Financial Advisory Firm discretionary authority to invest and reinvest Account assets and the Advisor manages the “Custom Account” for their client. The Financial Advisory Firm will be solely responsible for determining account assets and giving instructions for trades and rebalances. AssetMark does not provide any investment advice to Custom Accounts, does not have or exercise any discretionary authority with regard to Custom Accounts and does not supervise the Custom Accounts or the Financial Advisory Firm in its management of Custom Accounts. To the extent that a Financial Advisory Firm invests Account assets in a fund or strategy managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees. There is generally no public or secondary market for non-publicly traded, alternative investments, and the values reported on Account Statements received from the Custodian may not represent market values. It is unlikely that you would be able to sell your interests in the Alternatives Investments or realize the amounts shown on Client Account Statements. It is likely that the actual “resale” value of Alternative Investments may be substantially lower than what is on Account Statements. Values displayed on Account Statements are for convenience purposes only, may be out-of-date, and should not be relied upon as any indication of market value. The asset allocation classification of the Custom Accounts and any models used by the Financial Advisory Firm may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for Platform Accounts. The Platform Fee schedules will be charged to the Client Account, unless otherwise negotiated between the Financial Advisory Firm and AssetMark. The Client will receive additional information regarding the Financial Advisory Firm’s management of the Custom Account through the Financial Advisory Firm’s disclosure brochure. Alternative Investments Solutions Although AssetMark may rely on the values provided by the issuers or sponsors of non-publicly traded, alternative investment securities, AssetMark does not verify or confirm such valuations and makes no representations that the values are reasonable, accurate, or reflect actual holdings. In the event third-party data sources provide valuation of your Alternative Investment, Client Account Statements may display the value provided by a third party or a value derived from the third-party data. Client Account statements may also report the value of Alternative Investments as “N/A” or “Not Available.” Alternative Investments are hedge funds, private equity funds, private placements and other securities that do not trade on securities exchanges or over-the-counter markets. iCapital Network, Inc. (“iCapital”) offers a platform that provides advisors and their qualified investors access to Alternative Investments. AssetMark has contracted with iCapital to provide your Financial Advisor with access to Alternative Investments. Your Financial Advisory Firm will need to contract with iCapital or an iCapital affiliate to gain access to the iCapital Platform. Your Financial Advisor will not have access to the full iCapital Platform through the Assetmark Platform but only those funds that have been approved by AssetMark’s Alternative Product Acceptance Committee. There is a 0.25% flat Platform Fee for Alternative Investments. There is also a custody fee of $100/year for each position payable to Fidelity Brokerage Services, the only Platform Custodian currently available to custody Alternative Investments. By maintaining an account at Fidelity for Alternative Investments, the Client commits to maintaining sufficient cash in the Account holding the Alternative Investments to pay the custody fees. iCapital has agreed to compensate AssetMark for AssetMark’s administrative services in supporting access to iCapital’s Platform at the rate of 20% of the management and/or technological fees earned by iCapital. AssetMark services include the selection of funds to be made available to Financial Advisory Firms and their clients. Because iCapital’s compensation can differ between funds, the compensation paid AssetMark is expected to differ between funds, and this creates conflicts of interest for AssetMark. AssetMark addresses these conflicts through disclosures and criteria for fund selection. INVESTMENT CONSULTING AssetMark does not facilitate transfers, sales, withdrawals, or any other activity related to Alternative Investments. AssetMark, will not act in any capacity in any purchase or sale of Alternative Investments in Client Accounts. AssetMark does not assume responsibility for the Alternative Investments, including, but not limited to, the contents in documentation related to the Alternative Investments, the appropriateness or suitability of the Alternative Investments, restrictions on ownership, rights of transfer, financial statements, or the adequacy of disclosure or compliance with applicable laws, rules, and regulations. Any review performed by AssetMark will solely be for its benefit in determining its ability to provide access and services to select Alternative Investments. A Financial Advisory Firm or Financial Advisor can request that AssetMark consult on the creation of practice-based models that include Platform Solutions to meet specific goals and/or objectives sought by the Financial Advisory Firm or Financial Advisor. These models can include proprietary and/or third-party Solutions. The Financial Advisory Firm and Financial Advisor will continue to be responsible for determining the final combination of Solutions used in their practice-based models and the suitability of these Solutions for their Client(s). AssetMark does not provide individualized investment advice to Clients or to the Financial Advisor for individual client accounts. There is typically no fee for this service, but the Financial Advisor is expected to make an asset commitment to the Platform, AssetMark has no responsibility or duty to investigate, evaluate, or report any information that AssetMark may possess or may become aware of regarding any Alternative Investments. In the event that funds are wired or transferred to an issuer or sponsor of Alternative Investments, AssetMark will not have any responsibility or liability if the issuer or sponsor involved does not provide the required receipt or confirmation of the Alternative Investment in a manner that would allow the security to be held in Client Accounts. AssetMark shall have no responsibility for monitoring non-publicly traded, alternative investments to assure compliance with its terms or disclosures, for taking any actions to collect on any amount owed to Client Accounts, AssetMark Platform Disclosure BrochureThis must remain with the Client Page 7 of 38 Cash Accounts which creates a conflict of interest for the Financial Advisor. The inclusion of a proprietary Solution creates a conflict of interest for AssetMark if selected by the Financial Advisory Firm and Financial Advisor because AssetMark receives fees for the management of proprietary Solutions. TAX MANAGEMENT SERVICES Certain custodians will offer cash management services, which are described in more detail in their custodial agreements and/or disclosures. For more information about Cash Management Services at AssetMark Trust, refer to Item 9. Additionally, AssetMark Trust clients will receive a separate disclosure entitled AssetMark Trust Company Disclosures Regarding Services, that describes its Cash Management Services. SERVICES NO LONGER OFFERED AssetMark also continues to manage other advisory services which are no longer offered to new Clients. Clients with these services can contact AssetMark for more information. INVESTMENT VEHICLES The Solution Types can be comprised of: (i) closed-end mutual funds; (ii) open-end mutual funds; (iii) ETFs; (iv) individual securities (stocks, bonds, preferred stocks, treasury bills and notes, bank notes) and (v) alternatives. The Client Accounts managed by Investment or Discretionary Managers can also include options and alternative investments, as advised by the Financial Advisor and the Investment Manager. The Portfolio Strategists select and monitor the performance of the mutual funds, ETFs, and securities within their asset allocations and will periodically adjust and/or rebalance the asset allocations in accordance with their investment strategies. Each Investment Solution will maintain a 2% target cash allocation for the payment of fees, to cover withdrawals and other fees applicable to the Account. However, Portfolio Strategists and IMA Managers can determine to allocate a higher percentage to cash. AssetMark will reallocate the Account to the cash target when the Account passes certain thresholds (under 1.5% or over 2.5% for most Investment Solutions). Tax Management Services (TMS) is designed to improve the after-tax return for the client’s account. The application of TMS can cause the account to stray from the Strategy and Risk/Return Profile selected for the Account. Clients can submit account restrictions, such as GICS sub-industry restrictions for individual stocks, not mutual funds or ETFs. The application of TMS will cause the account to deviate from its selected investment strategy and may also affect the risk profile and overall performance of the account. Municipal securities held in TMS accounts can be replaced with non-municipal or non-state specific securities as portfolio holdings, resulting in interest income that may be subject to federal, state, and/or local income taxes. If you select TMS with a high tax sensitivity, you should expect the account to deviate from the selected strategy to a higher degree than if a lower tax sensitivity is selected. If additional customizations or restrictions are added to your TMS account, they may impact the account’s tax and investment results and the effectiveness of TMS. AssetMark does not provide tax planning, accounting, or legal advice or services. The Tax Management Services fee is ten basis points (0.10%) with a $100 minimum annual fee per account, except for Savos Personal Portfolios with TMS and AssetMark Direct Indexing. TMS fees can be negotiable. Accounts enrolled in TMS can trade at different times than other accounts on the AssetMark Platform invested in than same strategy and can hold higher cash allocations due to minimum trade size, rounding and other factors. TMS accounts will not be automatically rebalanced if the cash allocation exceeds a 2% threshold. The cash allocations will be invested in the cash “sweep” vehicle at the client’s selected custodian, which for AssetMark Trust is usually its Insured Cash Deposit (“ICD”) Program. OTHER SERVICES AND NON-MANAGED ACCOUNTS From time to time, AssetMark will add to or delete certain investment vehicles from the Platform: Administrative and General Securities Accounts a) Mutual Funds and ETFs model portfolios available through the Platform; b) Investment Managers available for the IMA Accounts; c) Portfolio Strategists available on the Platform; and d) other Investment Management Firms providing asset allocations and asset selections for Solution Types. The Financial Advisor reviews the Portfolio Strategists’, Investment Managers’ and Investment Management Firms’ and the Strategies’ performance on behalf of the Client and makes or recommends investment decisions based on such analysis. AssetMark does not recommend specific Portfolio Strategists, Investment Managers or Investment Management Firms to Clients. MUTUAL FUND MODEL PORTFOLIOS Although options vary depending upon the Custodian selected by the Client, the Client can usually establish an Account at their selected Custodian to hold “non-managed” assets (an “Administrative/Non- Managed Account”), and such Account can include a Cash Account or a General Securities Account. An Administrative/Non-Managed Account is provided as an administrative convenience for the Client. Assets in an Administrative/Non-Managed Account are not managed or advised by AssetMark, and AssetMark is not responsible for their investment or management. The Client will be solely responsible for directing the investments in the Administrative/Non-Managed Account. Non-Managed assets are subject to the terms of the Client’s agreement with their selected Custodian. In addition to reporting by the Client’s Custodian, the assets of an Administrative/Non-Managed Account will be included in periodic AssetMark reports that the Financial Advisor can provide to the Client. If Clients select AssetMark Trust as their Platform Custodian, they will be offered a FDIC-Insured Cash Program and, Certificates of Deposit for their Administrative account. This option, other cash management services from AssetMark Trust and the conflicts of interest involved in AssetMark affiliate AssetMark Trust offering these services are discussed in Item 9 of this Brochure. For Clients selecting a Mutual Fund Account, their Account will be invested in institutional mutual funds retail NTF funds and/or mutual funds that generally do charge a sales load but where the sales charge has been waived. Third-party mutual funds and AssetMark Proprietary Funds are used. (Refer to Servicing Fees Received by custodians, Including AssetMark Trust and Share Class Use below). The Account will be invested consistent with allocations provided by a Portfolio Strategist for the Risk/Return Profile selected by the Client based on the advice of the Financial Advisor. Certain Portfolio Strategists compose their mutual fund allocations utilizing only those mutual AssetMark Platform Disclosure BrochureThis must remain with the Client Page 8 of 38 funds, have management fees paid to the manager of the ETF. There are no separate share classes for ETFs. ETF Solutions invest in third- party ETFs, which are not advised by AssetMark. funds managed by the Portfolio Strategist, Investment Manager or an affiliate of the Portfolio Strategist or Investment Manager. One or more of the Portfolio Strategists will construct their allocations exclusively using Proprietary Funds managed by AssetMark, including the GuideMark and GuidePath Funds. To the extent that a Portfolio Strategist makes an allocation to a mutual fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. AssetMark does not advise the Client about the Portfolio Strategist or the Risk/Return Profile appropriate for that Client’s Account. Multiple Investment Strategies are available as a model portfolio. Information regarding the Solutions and the Portfolio Strategists available for each of the Investment Strategies is available from the Client’s Financial Advisor. If a Mutual Fund account is chosen, it can also include non-mutual fund investments. For example, non-mutual fund investments could include cash alternatives and/or ETFs held by the Account, in addition to, depending upon the Custodian chosen, a standard allocation to cash. A Client, with the assistance of their Financial Advisor, can also select from ETF Solution Types, and their Account will be invested in ETFs consistent with allocations provided by a Portfolio Strategist for the Risk/Return Profile selected by the Client. A Portfolio Strategist can compose their ETF asset allocations utilizing ETFs managed by the Portfolio Strategist or an affiliate, by unaffiliated investment managers, or a combination of both. To the extent that a Portfolio Strategist makes an allocation to a mutual fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. ETFs are traded daily at market determined prices on a national exchange in a similar manner to other individual equity securities. ETF Solution Types also invest in exchange-traded notes (“ETNs”), which are senior, unsecured debt securities issued by an underwriting bank. AssetMark is responsible for trading the ETF Solution Types based on the recommendations of Portfolio Strategists. The ETF trading practices are discussed further in Item 9 under “Brokerage Practices” in the Trade Execution and Brokerage Allocation section. Multiple Investment Strategies are available as an ETF Model Portfolio. Information regarding the Solution and Portfolio Strategies available for each of the Investment Strategies is available from the Client’s Financial Advisor. Portfolio Strategists select from mutual funds that are AssetMark Proprietary Funds, third-party funds, NTF funds, load-waived, or retail mutual fund share classes that are available on each Custodian’s platform. There are no per-trade transaction fees charged to the Client in the mutual fund Solution Types on the AssetMark Platform. See Servicing Fees Received by Custodians, Including AssetMark Trust Company and Share Class Use under Fees and Compensation for more information on indirect fees the Client pays through their investment in mutual funds. A Client Account is also permitted to include some non-ETF investments or an allocation to proprietary mutual funds managed by the Portfolio Strategist. In addition, the Client retains all indicia of beneficial ownership, including, without limitation, all voting power and other rights as a security holder in each of the funds held for the Client. Use of Portfolio Strategist and IMA Manager Proprietary Mutual Funds and AssetMark and AssetMark Affiliate Proprietary Funds ASSETS UNDER MANAGEMENT As of December 31, 2024, the Advisor Model Platform had $68.4 billion in assets under administration on the AssetMark Platform. This includes investments in proprietary mutual funds and Proprietary Solution Types, in which AAM is the discretionary manager. On December 2, 2024, AssetMark announced the close of its acquisition of Morningstar Wealth’s Turnkey Asset Management Platform (TAMP) assets. The assets under management also includes the acquired Morningstar accounts. Morningstar will continue to provide account services to the acquired accounts through mid-year 2025. FEES AND COMPENSATION The fees applicable to each Account on the Platform can include: 1. Financial Advisor Fee 2. Platform Fee, which includes any Strategist or Manager Portfolio Strategists and IMA Managers are permitted to use their funds that they or an affiliate advises in the Model Portfolios or IMA accounts they manage. In these situations, the Portfolio Strategist and the IMA Manager typically receive fees from AssetMark for the Model Portfolio or the management of the Client’s IMA Account, and they typically receive investment adviser or other fees from the funds they or an affiliate advise. These fees can exceed what the Portfolio Strategist or IMA Manager would receive for using third-party mutual funds. This is a conflict for the Portfolio Strategist or IMA Manager because it can create a financial incentive for the Portfolio Strategist or IMA Manager to select their own proprietary or affiliated funds. Clients should discuss this conflict with their Financial Advisor. Clients will also receive the IMA Manager’s Form ADV Disclosure Brochure in which the IMA Manager is required to disclose all conflicts of interests. To the extent that an IMA Manager invests Account assets in, or a Portfolio Strategist makes an allocation to, a fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will earn fees from the fund. Supplemental Fee, as applicable, and most custody fees. in various The Fees applicable to the Account will be set forth in the Client Billing Authorization the Client receives each time an Account is established. The Financial Advisor Fee and the Platform Fee when combined are referred to as the Advisory Fee. Other fees for special services are also charged. The Client should consider all applicable fees. AAM uses Proprietary Funds investment solutions. Information about the Proprietary Funds, including fees and expenses, are described in more detail in the Proprietary Funds’ prospectus. To the extent that AssetMark makes an allocation or invests Account assets in a fund managed by an AssetMark affiliate, AssetMark will rebate the portion of fees received by the AssetMark affiliate from the fund. ETF MODEL PORTFOLIOS An ETF is an investment fund traded on stock exchanges and holds assets such as stocks, commodities, or bonds, and can be traded over the course of the trading day. Each investor owns shares, which represent a portion of the holdings of the fund, and ETFs, like mutual Clients should be aware that the fees charged by AssetMark can be higher or lower than those charged by others in the industry and that it can be possible to obtain the same or similar services from other investment advisers and other platform providers at lower or higher rates. A Client can obtain some or all of the types of services available through AssetMark on an “unbundled” basis either through other AssetMark Platform Disclosure BrochureThis must remain with the Client Page 9 of 38 preparation of quarterly performance review (to complement account statements provided by Custodians); and maintenance and access to electronic or web-based inquiry system that provides detailed information on each Client Account on a daily basis. firms or through single or multiple strategy account selections on the Platform and, depending on the circumstances, the aggregate of any separately paid fees, or bundled fees can be lower or higher than the fees described below in Section C and in the Fees & Investment Minimums schedule at the end of this Disclosure Brochure. The annual rate of the ongoing Platform Fee is based on the amount and type of assets. Each fee schedule is tiered so that, subject to certain exceptions, the first dollar under management receives the highest fee and only those assets over the breakpoints receive the reduced fees. Under certain circumstances, assets held in one Investment Solution Account are considered when determining assets under management for breakpoint purposes relating to another Investment Solution Account held for the benefit of the same or a related person. Some of AssetMark’s Platform Fees are negotiable, and exceptions to the Fees & Investment Minimums schedule are subject to approval. As a standard practice, AssetMark grants exceptions to its fee schedule for accounts of employees and employees of broker-dealer, investment advisory or other firms with whom AssetMark maintains an active agreement, any of which can be offered discounted fees. It is important that the Client understands all the fees applicable to their Account and that all fees are subject to negotiation. The Platform Fee schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimums table located at the end of this Disclosure Brochure. The Fees & Investment Minimums table will be updated from time to time, to include the addition of new products and services, to remove any terminated strategies, or to make updates. Information regarding the Fees & Investment Minimums will also be posted at www.assetmark.com/info/disclosure, and you should consult this site for the most up-to-date information about the Fees & Investment Minimums. Generally, you will also receive notification in advance if there is a fee increase. That notification may direct you to your Financial Advisor or to the web address listed above for specific information on the change. CUSTODIAL AND BROKERAGE SERVICES FINANCIAL ADVISOR FEE The Financial Advisor Fee is paid to the Financial Advisory Firm with which the Client’s Financial Advisor is associated and compensates for the advisory and other services provided the Client by the Financial Advisory Firm. These services include obtaining information regarding the Client’s financial situation and investment objectives, conducting an analysis to make a determination of the suitability of the Solutions to be provided by AssetMark for the Client, providing the Client with AssetMark disclosure documents, assisting the Client with Account paperwork and being reasonably available for ongoing consultations with the Client regarding the Client’s investment objectives. The Financial Advisor and Client select an annual rate for the Financial Advisor Fee, which is paid to the Financial Advisory Firm, by choosing a flat rate, or a custom tiered rate of up to 1.95% (195 basis points), or a rate as negotiated and agreed between the Client and the Financial Advisor. PLATFORM FEE The Platform Fee charged Client Accounts includes compensation for custodial and brokerage services. Pursuant to agreements that AssetMark has negotiated with AssetMark Trust (AssetMark’s affiliated Custodian) and the third-party Custodians on AssetMark’s Platform, AssetMark pays the Custodian for the custodial and brokerage services provided to Client Accounts. (The Custodians also have other income sources.) The Client does not pay transaction fees on trades made in most of the Solution Types available on the Platform. Separate transaction fees will be charged in Fixed Income IMA Solutions and in some equity IMA Solutions. Additionally, AssetMark generally receives more revenue when Clients choose AssetMark Trust as their Custodian. These differences in payments and revenue create conflicts of interest for AssetMark. AssetMark addresses these conflicts by having the same Platform Fee apply regardless of the Custodian chosen and by allowing the Client to choose their own Custodian, which can be AssetMark’s affiliated Custodian, AssetMark Trust. Although the Platform Fee is the same among Custodians, different fees for incidental expenses can apply. The Platform Fee includes: (i) payment for advisory services (including the Strategist’s or Manager’s Supplemental Fee, if applicable) and administrative services; and The selected Custodian’s full fee schedule will be presented to the Client together with the separate custodial agreement to be executed between the Client and their selected Custodian. Please refer to the Custody Agreement (described below) for specific fees attributable to the Client Account. More information about Custodians are also discussed below in Item 9, Additional Information – Custodial Relationships. SUPERVISORY FEE (ii) payment for custodial and brokerage services (although additional fees are payable for certain third-party mutual funds, Actively Managed Fixed Income Strategies, Funding Accounts (an account used to receive cash and assets transferred in kind before sale or transfer to an advised Account), acquired Global Financial Private Capital (“GFPC”) Strategies, and Accounts custodied at Charles Schwab & Co. (“Schwab”). The Platform Fee provides compensation to AssetMark for maintaining the Platform and for arranging for advisory, administrative, custodial and brokerage services to the Account. The advisory services include the Model Portfolios provided by the Portfolio Strategists and the account management services provided by the Discretionary Managers. The Platform Fee will be higher for certain Financial Advisory Firms due to the amounts payable to Financial Advisory Firms with supervisory responsibility over the Financial Advisors. This supervisory fee, of up to 0.20% annually, is deducted from Client Account assets, and paid to certain Financial Advisory Firms, for supervision of the Account. The receipt of a supervisory fee creates an incentive for Financial Advisory Firms to use the AssetMark program versus other programs. You can ask your Financial Advisor if a supervisory fee applies to your Account. Information on participating Financial Advisory Firms is available from AssetMark upon request. The administrative services include but are not limited to: arranging for custodial services to be provided by various Platform Custodians pursuant to separate agreement between Client and Custodian; AssetMark Platform Disclosure BrochureThis must remain with the Client Page 10 of 38 MANAGEMENT/STRATEGIST FEE In the Advisor as Strategist or Advisor Managed Portfolio program (“AAS” or “AMP” program), your FA may act as a model provider or discretionary manager to your Account and be paid part of the Platform Fee. In certain instances, when your FA Firm acts as the adviser to your account, they may charge a management fee or similar fee, up to a maximum of 0.20%, that will be deducted from your Account. If such is the case, your FA Firm will disclose this to you. MINIMUM ACCOUNT PLATFORM FEE been terminated from the AssetMark Platform, and the Client has not selected another Strategy for their assets. These Accounts are referred to as “No Strategist” or “Terminated Strategist” Accounts. Neither AssetMark nor any Discretionary Manager will manage or shall be responsible for giving any advice with regard to these assets, but the Account typically remains invested in the investments last selected for the Strategy at a Platform Fee that is a reduction from that payable when the Strategy was active on the AssetMark Platform. The Account will continue to receive administrative and custodial services. Any Financial Advisor Fee previously payable shall be payable on No Strategist or Terminated Strategist Accounts unless AssetMark receives instructions not to charge the Financial Advisor Fee. It is up to the Financial Advisor to a Client to recommend a new Strategy to a Client for a No Strategist or Terminated Strategist Account. Platform Fee schedules for No Strategist or Terminated Strategist Accounts are available by contacting AssetMark or the Client’s Financial Advisor. FINANCIAL PLANNING AND CONSULTING FEES Certain ETF and mutual fund investment solutions are charged an annual Minimum Platform Fee of $350, or a quarterly prorated amount based on the number of days in that quarter. If the quarter end value of an Account multiplied by the fee rate is less than the calculated quarterly minimum fee, then the account will be charged the prorated quarterly minimum fee based on the number of days in the quarter. The Minimum Platform Fee is typically charged to accounts that no longer maintain the Investment Minimums in certain strategies. The Minimum Platform Fee, if charged, could represent a higher percentage fee than the stated Platform Fee for the strategy. Clients should consult with their Financial Advisor to understand the impact of fees when Investment Minimums are not met. Financial Advisory Firms that provide financial planning and consulting services are permitted to charge their Financial Planning and Consulting Fees through the Client’s Account on the Platform. Client authorization is required to establish or modify the Financial Planning and Consulting Fee, and to elect from which Account the fee will be charged, or establish for payment via Automated Clearing House, or ACH. The Fee can be a one-time fee or a recurring fee. If a Client elects to charge this Fee to an Individual Retirement Account (“IRA”) or other qualified account, the Client is responsible for any adverse tax consequences that can arise from fee payments from an IRA. Fee Billing Process The Platform Fee Schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimums schedule located at the end of this Disclosure Brochure. The Fees & Investment Minimums table will be updated from time to time, to include the addition of new products and services, to remove any terminated strategies, or to make updates. Information regarding the Fees & Investment Minimums will also be posted at www.assetmark.com/info/disclosure, and you should consult this site for the most up-to-date information about the Fees & Investment Minimums. STRATEGIST’S OR MANAGER’S SUPPLEMENTAL FEE For an Account invested in a third-party Investment Solution, a supplemental Strategist or Investment Manager Fee can be payable to the Strategist or Discretionary Manager. The Investment Manager Fee provides compensation for services provided by the Discretionary Manager that are customary for a Discretionary Manager to provide, including but not limited to, selecting, buying, selling and replacing securities for the Account and selecting the broker-dealers with which transactions for the Account will be effected. Advisory Fees (or “Account Fees”) are payable quarterly, in advance. The quarterly Advisory Fee is calculated by multiplying the market value of all Account assets inclusive of accrued interest and dividends as of the end of the previous calendar quarter by the “quarterly rate.” The quarterly rate is number of calendar days in the quarter, divided by 365 (or 366, as applicable) days in the year, multiplied by the applicable annual Advisory Fee rate provided for in the Fees & Investment Minimum table. For the initial deposit to the Account and for any subsequent amounts deposited to the Account, the Advisory Fee shall be payable upon the deposit or market value of the account (inclusive of accruals and dividends) reaching $1,000.00 or more. The Advisory Fee will be based upon the amount of the deposit multiplied by the quarterly rate (as described above) of the applicable annual rate and charged pro-rata through the end of the calendar quarter. Each of the Fees are calculated on a “tiered” basis so that the first dollar under management receives the highest fee and only those assets over the breakpoints receive the reduced fees. For certain Solution Types, the Account will be charged a Supplemental Investment Manager Fee on the basis of the applicable Discretionary Manager. These fees are payable by the Client on Account assets at the annual rates set out on the Fees & Investment Minimum fee table located at the end of this Disclosure Brochure. The Strategist’s and Manager’s Supplemental Fee can be negotiated at the sole discretion of the Discretionary Managers. Each Discretionary Manager’s investment process and philosophy are described in their Form ADV Part 2A Disclosures Brochure, which is provided to the Client when they open an Account. To request another copy, the Client can contact their Financial Advisor or AssetMark’s Compliance department at the address on the front cover of this Brochure. Unless other arrangements are made in writing, the Custodian will debit these fees from the Account. Additional fees, such as custodian termination fees, are due where applicable, pursuant to a separate agreement with the Custodian (“Custody Agreement”). In the event the Client takes a withdrawal from their Account, AssetMark will not refund any prepaid fees related to the amount that has been withdrawn. However, upon termination of the Account, a portion of the prepaid Advisory Fees will be refunded, calculated by multiplying the daily prepaid Account Fee during the final quarter by the number of days remaining in that quarter. FEES FOR TERMINATED STRATEGIST OR NO STRATEGIST ACCOUNTS The Client may be invested in an Account that no longer receives advisory services because the Strategy in which the Account was invested has Account values are typically grouped for fee billing purposes. Advisory Fees will be calculated based on the total value of existing Accounts across a Client household. This grouping is usually referred to as “Householding” and often results in a reduction of the overall Portfolio Fees. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 11 of 38 INDIRECT INVESTMENT EXPENSES AND MUTUAL FUND FEES PAID BY CLIENT The Client will not be assessed or refunded a pro-rata portion of the Platform Fee when an Investment Solution change is made in their Account and is executed intra-quarter between quarterly billing events. The Platform Fee for the new investment Solution will be effective in the next applicable billing cycle following the execution of the Investment Change instruction, which may be the monthly or quarterly cycle depending on Client-directed activity in the account. SERVICING FEES RECEIVED BY ASSETMARK AND SHARE CLASS USE Some expenses are inherent within the investments held in Client Accounts. Mutual funds pay management fees to their investment advisers, and certain funds and money market accounts have other types of fees or charges, including 12b-1, administrative, shareholder servicing, bank servicing or certain other fees, which are typically reflected in the net asset value of these mutual funds held in Client Accounts. Such expenses are borne by all investors holding such securities in their Accounts and are separate from AssetMark’s fees or charges. As discussed above, retail share classes of mutual funds typically pay 12b-1 fees to Custodians in return for shareholder services performed by those Custodians. Certain mutual funds and ETFs selected for Client Accounts include Proprietary Funds from which AssetMark or an AssetMark affiliate receives compensation as the investment adviser, as described above. AssetMark receives management and other fees for its management of the GuideMark and GuidePath Funds. Portfolio Strategists select from the mutual funds available on each Custodian’s platform to be used in the Mutual Fund Accounts. The Custodian determines and then makes available the universe of mutual funds to be used in the AssetMark Solutions. If a mutual fund is not available, the Portfolio Strategist works with AssetMark and the Custodian to make the fund available, where possible. Mutual fund families offer a variety of funds with varying fee structures and different share classes. The funds available at the Custodians for use with the AssetMark Platform will vary among different mutual fund share classes and will generally fall into these two share class categories. Some mutual funds charge short-term redemption fees. Currently, AssetMark seeks to avoid investing Client assets in funds that charge such fees to the extent practicable, but avoidance of these fees cannot be guaranteed. MUTUAL FUND SHARE CLASS USE IN AAM STRATEGIES • Retail share class – Retail share class funds charge a 12b-1 fee of generally 0.25%, which is paid to the Custodian. Retail shares also include administrative fees, shareholder servicing and sub-transfer agent fees, which are also paid to the Custodian. There are a range of retail share classes available on the custodial platforms that also charge 12b-1 fees or administrative fees. These share classes are generally known as no-load or service shares (C shares), or load- waived A shares, Investor Shares, or NTF mutual funds, available through NTF programs at various Custodians. • Institutional share class – Institutional share class funds have lower expenses because there are no 12b-1 fee charges. However, institutional share classes can include administrative fees, shareholder servicing, and/or sub-transfer agent fees paid to the Custodian. In the AAM Strategies, mutual fund share class is selected on a fund- by-fund basis and seeks to eliminate 12b-1 fees where possible. AssetMark will seek to use institutional classes where these share classes are available. In striving for consistency across all custodial options on the Platform, the AAM Strategies will seek to select the lowest cost share class available across all Custodians. Due to specific custodial or mutual fund company constraints, situations will arise where a specific share class is not consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class may be the retail share class. OTHER COMPENSATION DISCLOSURE NTF funds generally pay Custodians, including AssetMark Trust, AssetMark’s affiliated custodian, a range of servicing fees from the 12b-1 fees and administrative service fees, which typically include shareholder servicing and sub-transfer agent fees, collected by the mutual funds. See below Administrative Service Fees Received by Affiliate. Bank money market accounts and other bank services typically charge separate fees. For more information regarding bank services, refer to Cash Management Services offered by Affiliate in Item 9 below. AssetMark will use retail share mutual funds and institutional share mutual funds. There are no separate transaction fees charged for mutual fund investments on the Platform. AssetMark does not always use the lowest cost share class. In striving for consistency across all custodial options on the Platform, AssetMark will seek to select the lowest cost share class available across all Custodians. Due to specific custodial or mutual fund company constraints, situations will arise where a specific share class is not consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class may be the retail share class. Each of the mutual funds, ETFs, alternative investments and other funds or pooled investment vehicles available on the Platform bears its own operating expenses, including compensation to the fund or sub- adviser. As an investor in the mutual funds or ETFs, the Client indirectly bears the operating expenses of the mutual funds or ETFs, as these expenses will affect the net asset value (or share price in the case of an ETF) of each mutual fund or ETF. These expenses are in addition to the Financial Advisor Fee paid to the Client’s individual Financial Advisory Firm and the Platform Fee payable to AssetMark. The ratios of fund expenses to assets vary from fund to fund according to the actual amounts of expenses incurred and fluctuations in the fund’s daily net assets. Information on the specific expenses for each of the mutual funds is set forth in the fund’s prospectus and periodic reports. Information about the specific fees charged by mutual funds is described in each fund’s prospectus. The cost of advisory and investment management services provided through the Platform can be more or less than the cost of purchasing similar services separately. For example, direct investment in a mutual fund or ETF would be less expensive than investment in the same fund through the Platform, because the Client would not bear any AssetMark Platform Disclosure BrochureThis must remain with the Client Page 12 of 38 Platform Fee. All mutual funds included in mutual fund strategies on the Platform will be available for purchase at each fund’s net asset value and with no sales charge, so that no sales commissions are incurred in connection with investment in the initial Portfolio and Portfolio rebalancing. While most mutual funds available through the Platform will charge no transaction fees, mutual funds or Custodians charge redemption fees under certain circumstances. The Platform Fee for related Accounts of any Client on the Platform is negotiable, as are Platform Fees paid on Accounts that are associated with a particular Financial Advisory Firm, subject to approval. These negotiated fees typically lower the portion of the Platform Fee that AssetMark receives. SPECIAL SERVICE FEES PAID BY CLIENT Community Inspiration Award In order to promote community involvement, AssetMark created the Community Inspiration Award to honor selected Financial Advisors across the United States who have inspired others by supporting charitable organizations in their communities. AssetMark will make a cash donation, subject to the published rules governing the program, to the Financial Advisor’s nominated charity in accordance with the following: i) the charitable organization is not a Client or prospective Client of the Financial Advisor, ii) the Financial Advisor cannot hold an officer position on the charitable organization’s board or direct funds at the charitable organization, and iii) the charitable organization must not have the ability to contribute funds or services to a candidate for public office or to a Political Action Committee. There is no direct compensation paid to an honored Financial Advisor. However, the Financial Advisor has an incentive to place, or retain Client assets on the Platform as a result of AssetMark’s contribution to their supported charitable organization. Non-standard service fees incurred as a result of special requests from Clients, such as wiring funds or overnight mailing services, will be an expense of the Client’s Account and will typically be deducted by the Custodians at the time of occurrence. An authorized officer of AssetMark or the Custodian must approve exceptions. SECURITY AND SALES-BASED FEES PAID BY CLIENT An Account can also incur fees referred to as “Regulatory Transaction Fees,” paid to brokerage firms to offset the fees the firms owe to self- regulatory organizations and U.S. securities exchanges to cover fees charged by the SEC for costs related to the government’s supervision and regulation of the U.S. securities markets and professionals. In addition, applicable Accounts will also be charged expenses related to custody of foreign securities and foreign taxes. The Client should review the agreement or schedule of fees of their selected Custodian. FINANCIAL ADVISORY FIRM AND FINANCIAL ADVISOR PROGRAM Direct and Indirect Support for Financial Advisors AssetMark sponsors annual conferences for participating Financial Advisory Firms and/or Financial Advisors designed to facilitate and promote the success of the Financial Advisory Firm and/or Financial Advisor and/or AssetMark advisory services. AssetMark offers Portfolio Strategists, Investment Managers and Investment Management Firms, who in some cases also are Sub-Advisors for the GuideMark and GuidePath Funds, the opportunity to contribute to the costs of AssetMark’s annual conferences and be identified as a sponsor. AssetMark covers travel-related expenses for certain Financial Advisors to attend AssetMark’s annual conferences, quarterly meetings or to conduct due diligence visits. In addition to, and outside of the Advisor Benefits Program, AssetMark contributes to the costs incurred by Financial Advisors in connection with conferences or other Client events conducted by the Financial Advisor or the Financial Advisory Firm. AssetMark also solicits research from Financial Advisors regarding new products or services that AssetMark is considering for Clients. In exchange for this feedback and guidance, AssetMark can offer an incentive to the Financial Advisor for their attendance at, or participation in, for example, an online survey or an in-person focus group. These programs create financial incentives for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. Financial Advisory Firms receive fees for their services and compensation from AssetMark for their advisory services to Clients, as described above under Financial Advisor Fee. Therefore, they have a financial incentive to recommend the AssetMark wrap fee program over other programs or services, which creates a conflict of interest on the part of the Financial Advisory Firms. In addition to the Platform Fee and other compensation received by AssetMark, AssetMark enters into other fee arrangements with certain Financial Advisory Firms and/or Financial Advisors as described below. Such arrangements will not increase the Platform Fee payable by the Client. However, Client’s should review and understand that these arrangements can be deemed to cause a conflict of interest because they provide Financial Advisory Firms and Financial Advisors with incentives to place and retain Client assets on the AssetMark platform. Discounted Fees for Financial Advisors Financial Advisors can receive discounted pricing or complimentary subscriptions from third-party service providers or from AssetMark or its affiliates for services such as business consulting, practice management, technology, financial planning tools and marketing- related tools and services because of their participation in the Platform. In certain cases, AssetMark receives a portion of the subscription fees paid by Financial Advisors to such third-party service providers. Discounted pricing and complimentary subscriptions can be subsidized by AssetMark. These arrangements create a financial incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. Advisor Benefits Program for Financial Advisors Under AssetMark’s Advisor Benefits Program, Financial Advisors have the option to utilize AssetMark’s advisor-directed tools, templates and best practices, or to engage with AssetMark to receive business and investment consulting, and/or education and guidance for implementing a growth plan for their businesses. Certain Financial Advisors can receive an allowance or “growth support” for reimbursement of qualified expenses incurred by the Financial Advisor based on their participation in AssetMark sponsored events, marketing initiatives, or use of technology resources and tools. Financial Advisors can also receive benefits by reaching certain levels, or tiers, on the AssetMark Platform. This program creates a financial incentive for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. Loans by AssetMark to Financial Advisory Firms AssetMark and its affiliates have made loans on a selected basis to some Financial Advisory Firms, and will continue to do so in certain circumstances. These financing arrangements result in additional revenue to AssetMark (primarily interest earned on those loans) and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has borrowed money from AssetMark and that still has a loan balance outstanding will have an incentive to continue using AssetMark’s products and services for its Clients even when AssetMark’s services can be more expensive or less appropriate for the Client. Certain financing arrangements are structured to create long-term obligations by those Financial Advisory Firms that can be AssetMark Platform Disclosure BrochureThis must remain with the Client Page 13 of 38 be more expensive or less appropriate for the Client. Therefore, these business arrangements can create a conflict of interest for Financial Advisory Firms between their own financial interests and the interests of their Clients. ASSETMARK CASH PAYMENTS TO THIRD PARTIES costly or difficult for those firms to terminate and certain of those arrangements may give AssetMark the right to convert the debt obligation into equity in the Financial Advisory Firm, giving AssetMark certain additional rights. Therefore, these loans can create an on- going conflict of interest for Financial Advisory Firms between their own financial interests tied to those financing arrangements and the interests of their Clients. Payment for testimonials/endorsements Financial Advisors may provide video, audio or documented statements endorsing AssetMark, and AssetMark may compensate the Financial Advisors for these. AssetMark makes cash payments to third parties (“Referring Firms”) for referrals (“Referral Fees”) of Financial Advisory Firms (“Referred Financial Advisory Firms”) that enter into Advisor Model Platform arrangements (“Referral Arrangements”). In certain cases, Referral Fees shall be discounted in the event that a Referring Firm receives compensation from a qualified custodian (as defined in Item 9 below under Custodial Relationships) in connection with the referral of a Referred Financial Advisory Firm. Each Referring Firm enters into a written agreement with AssetMark and discloses in writing to each prospective Referred Financial Advisory Firm the existence of the Referral Arrangement. Referral Arrangements will not increase the fees payable by Clients of Referred Financial Advisory Firms under the CSA. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Clients on the Platform include but are not limited to individuals, high- net-worth individuals, retirement plans, corporations, partnerships, trusts, insurance companies, charitable organizations and banks. Marketing Support for Financial Advisory Firms Certain Financial Advisory Firms enter into marketing arrangements with AssetMark whereby the Firms receive compensation and/or allowances in amounts based either upon a percentage of the value of new or existing Account assets of Clients referred to AssetMark by Financial Advisors, the addition of new Financial Advisors making use of the Platform, or a flat dollar amount. These arrangements provide the communication of AssetMark‘s service capabilities to Financial Advisors and their Clients in various venues, including participating in meetings, conferences and workshops. AssetMark also provides certain Financial Advisory Firms or their representatives with organizational consulting, education, training and marketing support. These arrangements create a financial incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets. If the Client’s Account is an Individual Retirement Account (“IRA”) or subject to ERISA, the Client and/or their Financial Advisor must inform AssetMark in writing, and the Client agrees to be bound by the terms of the “ERISA and IRA Supplement to AssetMark Investment Management Services Agreement.” Unless expressly agreed to in writing, AssetMark does not serve as a trustee or plan administrator for any ERISA plan, and does not advise such plans on issues such as funding, diversification or distribution of plan assets. Negotiated Fees AssetMark is permitted, in its discretion, to negotiate the Platform Fee for Clients of certain Financial Advisors. Certain Financial Advisors with higher aggregate levels of assets on the Platform are eligible for negotiated fees, which are passed through to the Client. The Financial Advisor does not earn additional compensation as a result of these negotiated fees. These arrangements create an incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. For the Guided Income Solutions, the typical Client will be an individual who is either close to retirement or currently in retirement and would like to use a portion of their savings to generate a monthly income stream. Pilot and Early Release Programs AssetMark can invite certain Financial Advisor Firms to participate in pilot or early release programs designed to solicit feedback on new product or service offerings. In exchange for participation in these programs, AssetMark may provide certain incentives to the Financial Advisor Firms such as fee waivers, or other incentives. A Client must deposit the Account minimum into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a managed Account until the Account balance reaches the required minimum. A Client’s Account will be held by the Custodian in cash or in the assets transferred in-kind until such time as the value of the deposits to the Account reaches the required minimum for investment. If accounts are at AssetMark Trust, the cash balance will be invested in the AssetMark Trust’s ICD Program. Strategist Fees In circumstances where a Financial Advisory Firm uses a Portfolio Strategist to assist in the management of a Client’s account, AssetMark will pay a strategist fee on a selected basis to the Financial Advisory Firm for use and monitoring of the model portfolio recommended by the Portfolio Strategist. This strategist fee creates a conflict of interest because the Financial Advisory Firm has an incentive to use the model portfolios produced by a Portfolio Strategist in order to keep receiving the fee, compared to other arrangements that might be less expensive or more appropriate for the Client. Clients should be aware that a reasonable amount of time will be needed to purchase, redeem, settle and/or transfer assets, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. A Client must work with a Financial Advisor who will assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet their financial needs. If a Client does not have a Financial Advisor, e.g. Financial Advisor is terminated or retires, the Client must assign a new Financial Advisor. Otherwise, the account will be deemed to be an Orphaned Account and AssetMark will take steps to terminate the Account. Transitions Program for Financial Advisory Firms AssetMark and its affiliates may enter into business arrangements designed to assist Financial Advisory Firms with succession planning, and will continue to do so. These financing arrangements result in additional revenue to AssetMark and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has agreed to share a portion of their Firm’s revenue with AssetMark and will have an incentive to continue using AssetMark’s products and services for its Clients even when AssetMark’s services can AssetMark Platform Disclosure BrochureThis must remain with the Client Page 14 of 38 Investment Minimums - Account Size account be invested in accordance with all rebalancing and adjustment instructions provided by the Portfolio Strategists unless and until the Client or Financial Advisory Firm expressly terminates the rebalancing and adjustments and/or executes written instructions to change the Strategy in which the account is invested. Client will receive notification of all account transactions in periodic account statements provided by the account Custodian. Investment Minimums are periodically reviewed and subject to change. AssetMark can, in its discretion, waive the Investment Minimum requirement from time to time. Accounts falling below the Investment Minimum can duly impair the ability to be fully invested in your selected model. It is also important to note that certain investment solutions are subject to a Minimum Account Fee, which might be charged when an account falls below the Investment Minimum. For example, this can occur when you make significant withdrawals from your account. Accounts below the Investment Minimum can be terminated by AssetMark after notice is provided to the Financial Advisor and/or the end investor. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION The Portfolio Strategists provide allocations based upon the corresponding risk profile determined by the Client and the Advisor, by which AssetMark intends to invest the Account, unless circumstances indicate modified allocations or investments are appropriate. These allocation recommendations are implemented by AssetMark in Client Accounts when they are received from the Portfolio Strategists and will result in transactions in the impacted Accounts. Portfolio Strategists will guide AssetMark with instructions to rebalance portfolios (return back to policy mix) and/or reallocate (change the target mix), either periodically or as they deem appropriate over time, depending on their specific Investment Approach and investment process. SELECTION AND REVIEW OF PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS PORTFOLIO STRATEGISTS Although some of the Portfolio Strategists creating portfolios comprised of mutual funds consider all of the mutual funds available under the Platform, certain Portfolio Strategists compose their mutual fund allocations utilizing those mutual funds managed by the Portfolio Strategist or an affiliate of the Portfolio Strategist. This creates a conflict of interest for these Portfolio Strategists, as discussed above. In addition, one or more of the Portfolio Strategists will construct their allocations using AssetMark’s Proprietary Funds. A Prospectus for the Proprietary Funds can be obtained upon request from AssetMark or the Financial Advisor. Clients should review prospectuses and consult with their Financial Advisor if they have questions regarding these Funds. The Portfolio Strategists and Investment Managers used in Model and IMA Solution Types are selected for the Platform by AssetMark in order to make available a curated range of investment options and philosophies to Clients and their Financial Advisors. The selection and due diligence process is described below. Each of the Portfolio Strategists provides to AssetMark a range of investment allocations that will correspond to some or all of the six Risk/Return Profiles, ranging from most conservative to most aggressive, as discussed above under “RISK/RETURN PROFILES”. The Portfolio Strategists use technical and/or fundamental analysis techniques in formulating their investment decisions to meet their targeted objective. Although each of the Risk/Return Profiles includes asset allocations developed by several Portfolio Strategists, each of the Portfolio Strategists nevertheless has its own investment style resulting in the use of different asset classes, and mutual fund, ETF, or investment management firm options within their asset allocations. Investment Strategies can be single asset class or multiple asset classes which may include, but are not limited to the following: • U.S. Equities: Large-Cap Growth, Large-Cap Value, Mid-Cap Growth, Mid-Cap Value, Small-Cap Growth, Small-Cap Value • International Equities: Developed Markets, Emerging Markets International, • Fixed Income: U.S. Core, High-Yield, Global, Emerging Markets • Other: REITs, Commodities, Absolute Return Strategies, Hedging Strategies and other non-standard sectors including Alternatives • Cash. The objective is to provide Clients with a variety of Investment Strategies and approaches for accomplishing the Client’s investment objectives. The Client and their Financial Advisor should review each Portfolio Strategist’s investment style prior to selecting the Portfolio Strategist and Investment Strategy for each Client Account on the Platform. AssetMark makes available to the Financial Advisory Firm and the Financial Advisor factsheets of each investment solution managed by the Portfolio Strategists and Investment Managers. This includes a brief review of each firm, including key investment management personnel, strategy process, allocation shifts and performance metrics. The Client and Financial Advisory Firm can select more than one Portfolio Strategist and/or Investment Strategy for the Client’s Accounts, and, as noted above, the Client and Financial Advisory Firm are free to change Portfolio Strategists, Investment Strategy or the mutual fund or ETF components of their Portfolios from time to time, though any change by a Client in the components of a specific asset allocation used for a Client’s Account will result in a custom portfolio for that Account which would no longer be automatically rebalanced along with the Portfolio Strategist’s rebalancing of its asset allocation. The Client is free to consult with the Financial Advisory Firm at any time concerning the portfolio, and AssetMark is available to consult with Clients and Financial Advisory Firms concerning the administration of the Platform. It is not anticipated that Clients or Financial Advisory Firms will have the opportunity to consult directly with the Portfolio Strategists concerning their asset allocation Strategies, although the Financial Advisory Firms will be provided with information concerning such Strategies and any updates or revisions to such information. For more information regarding specific Portfolio Strategists’ investment processes and philosophy, or to request a copy of a Portfolio Strategist’s Form ADV Part 2A Disclosure Brochure, a Client should contact their Financial Advisor or AssetMark’s Compliance department at the address on the front cover of this Brochure. AssetMark negotiates agreements with each Portfolio Strategist separately and the terms of these agreements vary from firm to firm, which creates a potential incentive for AssetMark to favor one Portfolio Strategist over another based on how advantageous that firm’s agreement is for AssetMark. For more information regarding Portfolio Strategists will provide AssetMark with instructions to rebalance (to most recent Model Portfolio allocations) or to reallocate (to new Model Portfolio allocations), either periodically or as they deem appropriate over time, depending on their specific Investment Approach and investment process. These adjustments to the asset allocations will result in transactions in Client accounts. The Financial Advisory Firm or the Client instructs and directs that the Client’s AssetMark Platform Disclosure BrochureThis must remain with the Client Page 15 of 38 specific Portfolio Strategist’s’ investment processes and philosophy, or to request a copy of a Portfolio Strategist’s Form ADV Part 2A Disclosures Brochure, a Client should contact the Financial Advisor or AssetMark’s Compliance department at the address on the front cover of this Brochure. INVESTMENT MANAGEMENT FIRMS AssetMark uses independent investment management firms (referred to as “Investment Managers” or “Discretionary Managers”) in the certain IMAs. person to discuss, among other things, performance, changes to their investment process and philosophy and any material organizational changes at the firm. For ongoing monitoring all findings are reported to the Due Diligence Investment Committee on a quarterly basis, or sooner based on the significance of the findings. In the event of significant news occurring within a quarter, the Due Diligence team is in immediate contact with the Strategist or Investment manager to fully understand the impact of the news. If a change in status is warranted, an interim investment committee meeting will be held, and relevant action taken. Any strategists on non-satisfactory status are listed in a report that is available on eWealthManager and are reviewed with the IOC on a quarterly basis. independent The Investment Management Firms acting as Investment Managers or Discretionary Managers in their discretionary management capacity, and acting as the Investment Management Firms in their advisory capacity, depending on the Solution Type in question, are all referred to below as Investment Management Firms in the discussion of their selection and oversight. The selection and due diligence process is described below. AssetMark negotiates agreements with each independent Investment Management Firm separately and the terms of these agreements vary from firm to firm, which creates a potential incentive for AssetMark to choose one independent Investment Management Firm over another based on how advantageous that firm’s agreement is for AssetMark. SELECTION AND DUE DILIGENCE PROCESS FOR PORTFOLIO STRATEGISTS AND INVESTMENT MANAGEMENT FIRMS AssetMark charges to Portfolio Strategists and IMA Managers that have been selected to participate on the Platform a one-time set up fee and an annual maintenance fee (which is typically tiered such that the fee will increase to the extent that Client Account assets invested in Model Portfolios and/or IMA Accounts managed by Portfolio Strategists and IMA Managers exceed certain thresholds) for performing certain functions, which may include administrative, operational, compliance, investment and marketing functions, in connection with adding and maintaining the Portfolio Strategist or IMA Manager on the Platform. This creates a conflict of interest for AssetMark because it provides a financial incentive for AssetMark to favor Portfolio Strategists and IMA Managers who agree to pay the fee in order to participate on the Platform. AssetMark offers a Strategist Data Program through which Portfolio Strategists pay an annual fee to access reports that provide additional detail with respect to assets invested in the Model Portfolios maintained by Portfolio Strategists. AssetMark also offers a Strategist Engagement Program that provides Portfolio Strategists the ability to engage with AssetMark in connection with the support and maintenance of their Model Portfolios on the Platform, including event sponsorships and Strategist Data Program participation, for a bundled annual fee. The Programs described above create a conflict of interest for AssetMark because they provide a financial incentive for AssetMark to favor Portfolio Strategists who pay the fees to participate in the Programs. INVESTMENT AND TAX RISKS Each portfolio strategist and investment manager completes a detailed questionnaire (“DDQ”) about their investment process, performance and reporting and risk management, in addition to covering business organization, compliance and ethics, operational framework, and client support. The DDQ is reviewed by AssetMark Due Diligence with compliance and ethics sections also being reviewed by AssetMark’s compliance group. An external third party is used for operational due diligence review. AssetMark’s due diligence process is deep and thorough and focuses on five key P’s; People, Philosophy, Process, Portfolio Construction and Performance. Consistency in the first four explains performance so we spend most of our time understanding the qualitative and quantitative aspects of a manager and strategy and use performance as the confirmation of our understanding. The team seeks the following in the five key P’s: 1. People – stable and tenured teams that have experience managing through different market environments. 2. Philosophy – a philosophy that is clearly defined and articulated well. Understanding the foundations to the philosophy and how it has adapted over time is critical. Clients should understand that all investments involve risk (the amount of which vary significantly), that investment performance can never be predicted or guaranteed and that the value of their Accounts will fluctuate due to market conditions and other factors. Clients who open Accounts by transferring securities instead of opening an Account with cash, should also understand that all or a portion of their securities will be sold either at the initiation of or during the course of management of their Accounts. The Client is responsible for all of the tax liabilities arising from such transactions and is encouraged to seek the advice of a qualified tax professional. AssetMark does not provide tax advice. 3. Process – a consistent application of the investment process. Demonstrating how investment decisions were made in multiple market environments and tying the decisions back to the philosophy. 4. Portfolio Construction – rigor in the risk oversight in building the portfolio. A clear discipline and process that shows how risk management is considered in the investment process. 5. Performance – The proof statement and purposefully last. The team’s evaluation of the other P’s builds up their expectations of how the strategy should perform. The actual results are used to confirm expectations and to demonstrate how the manager adds value over time. Performance for the asset allocation models by the Portfolio Strategists, are calculated monthly using a time weighted methodology in InvestCloud (f/k/a Tegra118 and Fiserv) APL trading and portfolio management system. Performance results are shown on a net of fees basis. Composite performance is calculated using actual Client Accounts. Generally, investment Solutions move from a model-tracking portfolio to composite performance reporting when at least one Account is under AssetMark’s Referral Model and meets the minimum investment amount for the specific strategy at AssetMark in the previous quarter. Performance for IMA Investment Solutions is not calculated or reviewed by AssetMark due to the custom nature of these strategies. For new searches, all findings are reported to the Due Diligence Investment Committee prior to being reviewed by the Investment Oversight Committee (“IOC”). Once selected for the Platform, the Due Diligence team conducts quarterly reviews via conference calls or in AssetMark Platform Disclosure BrochureThis must remain with the Client Page 16 of 38 Investing in securities involves risk of loss that Clients should be prepared to bear. SHAREHOLDER MATERIALS, PROXY VOTING AND CLASS ACTIONS For Client level performance, the InvestCloud APL system is used to calculate a time weighted rate of return. Performance results are displayed to each Client daily, via eWealthManager.com, if selected by the Financial Advisor and more formally quarterly via Clients’ Quarterly Performance Review, if selected by the Financial Advisor. Shareholder materials and proxy voting for Platform Accounts ASSETMARK AS PORTFOLIO STRATEGIST OR INVESTMENT MANAGER AssetMark also serves as the Portfolio Strategist and Investment Manager for certain Model and IMA Solution Types. Refer to Exhibit B – AssetMark Asset Management – Solution Types for more detailed information. INVESTMENT DISCRETION For all Accounts, Client has the right to receive prospectuses, proxy materials and other issuer-related shareholder materials concerning the securities held in their Account (the “Shareholder Materials”) and to vote all proxies and voluntary corporate actions, such as mergers, acquisitions and tender offers or similar occurrences, solicited with respect to securities held in each their Account; provided, however, that the delivery of Shareholder Materials and proxy voting rights shall be subject to the terms of the Client’s agreement with their Custodian and the selected Custodian’s policies and procedures. If an IMA Strategy is selected for the Account by the Client and/or Financial Advisor, the Discretionary Manager accepts discretionary authority to manage the assets in the Client’s Account. The Client grants the Discretionary Manager the authority to manage the assets in their Account on a fully discretionary basis. The grant of discretionary authority to the Discretionary Manager includes, but is not limited to the authority to: The Solution Types offered on the AssetMark Platform are Model Portfolios, Individually Managed Accounts (“IMAs”) and Individual Mutual Funds (“IMFs”). The Platform also offers the Advisor As Strategist and Advisor Managed Portfolios Programs. The processes for delivery of shareholder materials and voting of proxies for these are as follows. • take any and all actions on the Client’s behalf that the Discretionary Manager determines to be customary or appropriate for a discretionary investment adviser to perform, including the authority to buy, sell, select, remove, replace and vote proxies for securities, including mutual fund shares and including those advised by AssetMark or an affiliate, and other investments, for the Account, and to determine the portion of assets in the Account to be allocated to each investment or asset class and to change such allocations; • select the broker-dealers or others with which transactions for the Account will be effected; and • retain and replace, or not, any person providing services to the Discretionary Manager. REASONABLE RESTRICTIONS, PLEDGING AND WITHDRAWING SECURITIES As of March 2025, in the instance of an Account invested in a Model Portfolio Strategy or an Individual Mutual Fund, the practice of all Platform Custodians has been to forward Shareholder Materials to Client and Clients have been responsible to vote proxies and voluntary corporate actions. It is anticipated that, following notices to affected Clients, this practice will change at the end of May 2025 for those Clients who have selected AssetMark Trust as their custodian. Upon the effectiveness of this change for an Account invested in a Model Portfolio Strategy or an Individual Mutual Fund, unless other arrangements are made with respect to the securities held in the Account, the Client will direct AssetMark to receive all Shareholder Materials and to vote the proxies and voluntary corporate actions in its discretion. Client represents that, under applicable instruments or governing law, Client is authorized to make such direction. In providing this proxy voting service, AssetMark is not providing continuous monitoring of the Client Account or providing advisory services other than voting proxies and voluntary corporate actions. AssetMark allows reasonable investment limitations and restrictions when notified of such by the Financial Advisor or Client. For current Clients who have selected a third-party custodian (that is, one other than AssetMark Trust), the current practice of clients receiving Shareholder Materials, including proxies, will continue. However, if a client becomes a client of a third-party custodian after the end of May 2025, unless other arrangements are made with respect to the securities held in the Account, the Client will direct AssetMark to receive all Shareholder Materials and to vote the proxies and voluntary corporate actions in its discretion. Client represents that, under applicable instruments or governing law, Client is authorized to make such direction. In providing this proxy voting service, AssetMark is not providing continuous monitoring of the Client Account or providing advisory services other than voting proxies and voluntary corporate actions. Clients have the option to place restrictions against investments in specific securities or types of securities for their Account that are reasonable in light of the advisory services being provided under the different Solution Types offered on the Platform, understanding that any restrictions placed on an Account can adversely affect performance. Requests for such restrictions are reviewed by AssetMark to ensure that they are reasonable and will not unduly impair AssetMark’s ability to pursue the Solution Type and Strategy selected by the Client. Clients can also pledge the securities in their Account or withdraw securities from their Account (transfer in-kind to another Account or Custodian), but must do so by giving instructions in writing to AssetMark and AssetMark Trust. It is important to note that restrictions cannot be effected in certain investments or due to operational capabilities such as in a mutual funds, or at the sleeve level within a Multiple Strategy Account. Client always has the right to receive shareholder materials and vote proxies applicable to the securities in the Account. If at any time you would like to receive these materials, contact your Financial Advisor. You may also contact AssetMark at: Side-by-side management refers to managing accounts that pay performance fees (fees based on a share of capital gains on or capital appreciation of Account assets) while at the same time managing accounts that do not pay performance fees. AssetMark does not charge performance-based fees. AssetMark, Inc. Attention: Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 advisorcompliance@assetmark.com AssetMark Platform Disclosure BrochureThis must remain with the Client Page 17 of 38 In the instance of an Individually Managed Account or an Advisor Managed Account not managed through the Advisor Managed Portfolios Program, unless other arrangements are made, the Client directs the Discretionary Manager to receive all Shareholder Materials with respect to the securities held in the Client Account and to vote the proxies and voluntary corporate actions in their discretion. Client represents that, under applicable instruments or governing law, Client is authorized to make such direction. Such direction may be amended by the Client at any time by delivering written notice to the Advisor and, if applicable, to the Discretionary Manager. The Advisor shall promptly deliver any such notice through AssetMark to the Discretionary Manager. Client understands and agrees that the terms and conditions of the Client’s election to receive Shareholder Materials and vote proxies, or to delegate to the Discretionary Manager the voting of proxies and receipt of Shareholder Materials, is subject to the terms and conditions imposed by the Custodian and each Discretionary Manager, including the Advisor, if applicable. including board composition, executive and director compensation, capital structure, corporate reorganizations, shareholder rights, and social and environmental issues. AssetMark’s proxy voting policies and procedures provide for the identification of potential conflicts of interest that can occur due to business, personal or family relationships, determination of whether the potential conflict is material, and they establish procedures to address material conflicts of interest. To address voting items identified as those in which AssetMark has a material conflict of interest, AssetMark generally will rely on the third-party firm to vote according to the guidelines. Alternatively, AssetMark can also refer a proposal to the Client and obtain the Client’s instruction on how to vote or disclose the conflict to the Client and obtain the Client’s consent on its vote. AssetMark is not obligated to vote every proxy; there will be instances when refraining from voting is in the best interests of the Client. Because the interests of Clients can differ, AssetMark can vote the securities of different Clients differently. AssetMark will generally delegate the voting of all proxies by the GuideMark Funds to the sub-advisors engaged to advise the GuideMark Funds. Clients can obtain a copy of AssetMark’s complete proxy voting policies and procedures upon request. Clients can also obtain information from AssetMark about how AssetMark voted any proxies on behalf of their account(s). To obtain proxy voting information, requests should be mailed to: If an Account, for which AssetMark votes proxies, holds shares of a fund for which AssetMark acts as adviser, AssetMark will vote 100% of the shares over which it has voting authority according to instructions it receives from its Clients, which are the Fund’s beneficial shareholders. AssetMark will vote shares with respect to which it does not receive executed proxies, in the same proportion as those shares for which it does receive executed proxies. This is known as “mirror voting” or “echo voting.” Client’s right to vote proxies, and therefore its designation to another to vote proxies, cannot apply to securities that have been loaned pursuant to a securities lending arrangement. AssetMark, Inc. Attention: Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 advisorcompliance@assetmark.com ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS In the instance of an Account managed through the Advisor Managed Portfolios Program, the Client will receive Shareholder Materials for purposes of voting any voting securities and directing the voting of any proxies and voluntary corporate actions relating to the securities held in the Account. Proxy Voting for Administrative Accounts The Client retains the right to vote proxies if the Account is an Administrative/Non-Managed Account. If a Client selects an IMA Strategy, the Client’s information will be shared with the IMA Manager who has discretionary authority on the Account. Client information will not be shared with Portfolio Strategists who provide asset allocation Strategies and have no discretion over the Account. Class Actions and Similar Actions REVIEW OF ACCOUNTS The Clients and their Financial Advisors may contact AssetMark to arrange for consultations regarding the management of their Accounts. Clients should refer to their Financial Advisors to discuss and assess their current financial situation, investment needs and future requirements in order to implement and monitor investment Portfolios designed to meet the Client’s financial needs. Neither Advisor, any Discretionary Manager, AssetMark nor any Portfolio Strategist shall advise or act for the Client with respect to any legal matters, including bankruptcies or class actions, with respect to securities held in the Account. However, if you have chosen AssetMark Trust as your custodian, pursuant to your Custody Agreement, unless you opt out, you authorize AssetMark Trust to act on your behalf and as your agent and contract with a third party for Class Action Services. AssetMark Trust has contracted with Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to provide Class Action Services to AssetMark Trust custodial clients. These services offered through AssetMark Trust, including the conflicts of interest they create for AssetMark, are detailed below in item 9. AssetMark makes available periodic reports to Financial Advisory Firms for use with their Clients. These written reports, the Quarterly Performance Review (“QPR”), generally contain a list of assets, investment results, and statistical data related to the Client’s Account. We urge Clients to carefully review these reports and compare the statements that they receive from their custodian to the reports. Voting Process and Material Conflicts AssetMark has adopted proxy voting policies and procedures designed to fulfill its duties of care and loyalty to its Clients. AssetMark has adopted a set of voting guidelines provided by an unaffiliated third- party firm with which it has contracted to vote proxies on its behalf. These policies, procedures and the voting guidelines provide that votes will be cast in a manner consistent with the best interests of the Client. The specific guidelines address a broad range of issues Management of the Client’s Account The Financial Advisory Firm provides the specific advice to the Client concerning the Client’s investment Strategy for each Account, including the Solution Type, the Portfolio Strategist(s), the particular Investment Approach or sub-strategy to be chosen for the Client, and the Client’s appropriate Risk/Return Profile. The Financial Advisory Firm will also advise Clients in Individually Managed Accounts on the AssetMark Platform Disclosure BrochureThis must remain with the Client Page 18 of 38 ITEM 9 – ADDITIONAL INFORMATION DISCIPLINARY INFORMATION Investment Managers to be selected for the Client’s Account. The Financial Advisory Firm and/or the client (depending upon the specific form of Client Services Agreement or advisory agreement entered into between the Financial Advisory Firm and the Client) retains discretion to choose the Portfolio Strategist(s), the asset allocation(s) and the Investment Managers selected as the components of the Strategy for the Client’s Accounts, and will have the opportunity periodically to change the Strategy or its components, including the Solution Type, the choice of Portfolio Strategist(s), the particular asset allocation(s) or sub strategies, the Risk/Return Profile, or the Investment Managers selected for the Accounts. Clients are provided with periodic custodial reports from a custodian and AssetMark provides the Financial Advisory Firms with QPR’s for each of their Client’s Accounts. The periodic custodial reports include a listing of all investments in the Client’s account, their current valuation, and a listing of all transactions occurring during the period. The QPR’s include information concerning the allocation of the assets in each Client Account among various asset classes and the investment performance of the Client’s Account during the quarter and billing/fees. On September 26, 2023, the SEC issued an Order Instituting Administrative Cease-and-Desist Proceedings against AssetMark. The SEC alleged that, from at least September 2016 through January 2021, AssetMark failed to fully disclose that AssetMark and affiliate AssetMark Trust together set the amount of the payment that AssetMark Trust would retain as compensation from the payment received by the banks that participated in the FDIC-Insured Cash Deposit Program (“ICD Program”) (the “ICD Program Fee”), which, in turn, determined the amount that would be distributed as interest by the banks to clients. The SEC alleged that AssetMark had failed to fully disclose the associated conflicts of interest related to its role in setting the ICD Program Fee. The SEC also alleged that AssetMark, from at least January 2016 through August 2019, did not fully disclose the associated conflicts of interest related to AssetMark’s receipt of custodial support payments from certain no-transaction fee (“NTF”) mutual funds. These failures constituted breaches of AssetMark’s fiduciary duty to advisory clients. The SEC alleged that AssetMark violated Section 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 promulgated thereunder. AssetMark consented to the Order without admitting or denying the SEC’s findings. On August 25, 2016, the SEC announced a settlement with AssetMark in an order containing findings, which AssetMark neither admitted nor denied, that AssetMark violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)-1(a)(5) by allowing its staff, from July 2012 through October 2013, to circulate to prospective Clients who were considering an F-Squared managed account service offered by AssetMark, performance advertisements created by F-Squared relating to a different separately managed account service not offered by AssetMark and which misleadingly described that different service’s performance between 2001 and 2008, and that AssetMark violated Section 204(a) of the Advisers Act and Rule 204-2(a) (16) by failing to maintain records substantiating the performance in the advertisements created by F-Squared. There are no disciplinary items to report for the management team of AssetMark. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS The Client Account review function is performed by the Client’s Financial Advisor. AssetMark does not assign Client Accounts directly to specific individuals for investment supervision, and there is no single individual or class of individuals within the organization that can be identified as being solely responsible for implementing a full set of review criteria on any one Client Account. Instead, AssetMark offers a Platform of Solution Types to its Clients, each of which is a Model Portfolio to which the Client’s Account is linked. A variety of teams within the organization then have responsibility for reviewing the application of the appropriate investment guidelines to each Account. At the model level, two groups are responsible for ensuring that the investment models to which Client Accounts are linked are consistent with the guidelines and investment Strategy selected by the Client. AssetMark Due Diligence reviews those model recommendations provided by the Portfolio Strategists. AAM reviews on an ongoing basis the performance of the proprietary strategies. The Trade Operations Group monitors account adherence to models provided by Strategists and adherence to models created and maintained by AAM. AssetMark makes available QPR’s and a supplemental report is also available for use with Clients in the Guided Income Solutions. These written reports generally contain a list of assets, investment results, and statistical data related to the Client’s Account. Clients are urged to carefully review these reports and compare them to statements that they receive from their Custodian. AssetMark is direct subsidiary of AssetMark Financial Holdings, Inc., an independent U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. The following companies are under common control with AssetMark. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Conflicts do exist though, and those are noted below. The industry activities of these affiliated companies are described in further detail below:: • Atria Investments, Inc. (d/b/a Adhesion Wealth) Clients can contact their Financial Advisors to arrange for consultations regarding the management of their Accounts. Clients should refer to their Financial Advisors to discuss and assess their current financial situation, investment needs and future requirements in order to implement and monitor investment portfolios designed to meet the Client’s financial needs. • AssetMark Brokerage, LLC • AssetMark Services, Inc. • AssetMark Trust Company ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Adhesion Wealth Adhesion Wealth is a registered investment adviser with the U.S. Securities and Exchange Commission, currently providing sub- advisory services to other registered investment advisers, either directly or through a third party sponsored program. Together with their Financial Advisor, Clients invested in High Net Worth and IMA Strategies will have direct access to Investment Managers to discuss their Account. On the other hand, Clients who have selected Model Portfolios will not have access to the Model Provider or Portfolio Strategist. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 19 of 38 AssetMark Brokerage, LLC AssetMark Brokerage, LLC (“AssetMark Brokerage”) is a broker-dealer registered with the SEC and is a member of FINRA. most mutual funds held by AssetMark Trust client accounts do not pay a 12b-1 fee, administrative service fee or similar income is paid with regard to most funds held by client accounts. This income and variation in payments create conflicts because AssetMark Trust is paid this income, as described below. AssetMark Services, Inc. AssetMark Services, Inc. provides recordkeeping and administrative services to retirement plans. AssetMark Trust Company AssetMark Trust is an Arizona chartered trust company that serves as the Custodian for certain Accounts on the AssetMark Platform. AssetMark also has indirect affiliations with companies under GTCR. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Although not affiliated when AssetMark Trust contracted with the Program Administrator for services, AssetMark Trust and the Program Administrator, as described below in the FDIC-Insured Cash Program, are now under common ownership. AssetMark Trust uses sub-custodians in fulfilling its responsibilities, including National Financial Services Corp., (whose affiliated broker- dealer, Fidelity Brokerage Services, LLC, also provides brokerage and clearing services for Client Accounts), see below, Custodial Relationships. Fidelity operates as a sub-custodian for AssetMark Trust, and as sub-custodian Fidelity receives certain payments from investment companies for certain administrative and recordkeeping services. AssetMark Trust receives payments from Fidelity for the recordkeeping and other administrative duties performed by AssetMark Trust as Custodian. Because Fidelity operates as a sub-custodian for AssetMark Trust, Fidelity remits approximately 92.25% of such fees collected from these investment companies to AssetMark Trust in exchange for the custodial support services AssetMark Trust provides. If an AssetMark-advised fund, e.g., a GuidePath or GuideMark Fund, is used, Fidelity pays AssetMark Trust 100% of the payments. Below are the types of fees AssetMark Trust receives: Some employees of AssetMark are also shared with affiliated entities. This presents potential conflicts around the sharing of client’s personal information, trading practices, and supervision. To mitigate these conflicts, the Company has policies in place to supervise and monitor the activities of these shared employees. AFFILIATE SERVICES AND CONFLICTS OF INTEREST • 12b-1s, which are a cost to the shareholders of the mutual fund. If the prospectus of a mutual fund allows for 12b-1 fees to be paid for either “distribution” or “service,” it will be included in the fund’s expenses and deducted from the income the mutual fund earns. • Administrative Service Fees (“ASF’s”), which are not an expense to the shareholders of the fund. These are an expense to the mutual fund and are paid to Fidelity per an agreement between the mutual fund company and Fidelity; • Recordkeeping fees earned on ERISA plan account holdings; and • Transaction-based fees, which may or may not be expenses of the fund. AssetMark also holds fund shares directly, without using Fidelity as sub-custodian. In such a case, the fund or fund company can pay AssetMark Trust ASF’s directly. Banking Institution - AssetMark Trust With the input from their Financial Advisors, the Client chooses a Custodian from among those offered through the Platform. AssetMark Trust, an affiliate of AssetMark, is among the available Platform Custodians. If the Client chooses AssetMark Trust as their Platform Custodian AssetMark Trust is paid for custodial and brokerage services provided to Client Accounts through the Platform Fee charged their Account and, where applicable, through additional fees. Pursuant to a contract between AssetMark and AssetMark Trust, AssetMark pays AssetMark Trust for services AssetMark Trust provides its custodial Clients. Additionally, AssetMark Trust receives payments from mutual funds, mutual fund service providers and other financial institutions for certain services AssetMark Trust provides related to investments held in Client Accounts. AssetMark Trust handles transfer agency functions, shareholder servicing, sub-accounting and tax reporting functions that these financial institutions would otherwise have to perform. Such payments are made to AssetMark Trust by these financial institutions based on the amount of assets invested in Client Accounts. Any such payments to the Custodian will not reduce the Platform Fee. Some mutual funds, or their service providers, provide compensation in connection with the purchase of shares of the funds, unless prohibited by law or regulation. AssetMark Trust receives ASFs from Fidelity, banks and insurance companies, or from their respective service providers. Any such income received by AssetMark Trust is in consideration for services it provides. This amount, in the aggregate, is substantial, in consideration of the services provided by AssetMark Trust to these respective service providers and varies by mutual fund. These payments are used to offset the additional annual custody fee otherwise payable by IRA Clients and Clients with Accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). AssetMark Trust currently waives any portion of this IRA & ERISA Account Fee not offset by this income. CASH MANAGEMENT SERVICES OFFERED BY AFFILIATE Investment Companies - GuideMark Funds and GuidePath Funds The GuidePath Funds are directly managed by AAM and invested in unaffiliated mutual funds and ETFs. AAM manages the GuidePath Funds based on research provided by current Portfolio Strategists in each of the Investment Approaches. AssetMark’s Due Diligence team has ongoing oversight over the performance of the Sub-Advisers in the GuideMark and GuidePath Funds and the Portfolio Strategists on the Platform. ADMINISTRATIVE SERVICE FEES RECEIVED BY AFFILIATE If Clients select AssetMark Trust as their Platform Custodian, they will be offered the following cash management services: FDIC- Insured Cash and CDARS Programs; Securities-Backed Lines of Credit; and FDIC-insured checking accounts. AssetMark Trust does not directly provide these services; they are provided to AssetMark Trust Clients through third-party providers, and AssetMark Trust is compensated by the third parties. With the exception of the Cash Allocation (discussed below), these services are optional; Clients can opt out of the services or choose not to use them. A disclosure document further discussing these cash management services, AssetMark Trust Company Disclosures Regarding Services, will be AssetMark selects mutual funds used in their Solution Types and, generally, the mutual funds selected are institutional share class funds. However, if institutional share class funds are not available, a fund that includes a Rule 12b-1 fee can be selected. Although AssetMark Platform Disclosure BrochureThis must remain with the Client Page 20 of 38 provided to Clients who select AssetMark Trust as their Platform Custodian. Please read this disclosure to better understand the features, costs and conflicts of interest related to these services. The following is only a summary of those disclosures. assets can be aggregated with assets in other Client Accounts with AssetMark for “householding” purposes, which aggregation should result in larger aggregate balances that can reduce the rate(s) of the Platform Fee(s) applicable to other Client Account(s). If the Client has selected a tiered Financial Advisor (or “FA”) Fee, this householding or aggregation of balances can also reduce the rate of the Client’s FA Fee. Deposits in the High Yield Cash Program, however, will not be aggregated with other AssetMark Client Account assets for fee householding purposes. You should determine if you would prefer the higher interest rate(s) offered by HYC or the lower fees available through “householding.” FDIC-Insured Cash Program Cash Allocation in Accounts invested in Platform Strategies: A portion (the “Cash Allocation”) of all Client Accounts invested in a Platform Strategy is placed in cash or a cash alternative investment. If you choose AssetMark Trust as your custodian, this Cash Allocation will be placed in AssetMark Trust’s Insured Cash Deposit (“ICD”) program and deposited in one or more banks insured by the Federal Deposit Insurance Corporation (“FDIC”), unless a money market mutual fund is required or requested. AssetMark has established the target Cash Allocation at 2% in part to defray the costs of providing the Platform and to help assure cash is available to pay Financial Advisor Fees and the Platform Fee. The interest your Account earns on the 2% Cash Allocation to FDID-Insured Cash is less then what typically would be earned on a money market fund. As discussed in more detail below, because of the revenue that AssetMark and its affiliate AssetMark Trust earn from the Cash Allocation, this is a conflict of interest. Fees on Advised Accounts and Conflicts of Interest: The Platform Fee is assessed on 100% of the value of Account assets invested in Platform Strategies upon initial investment and, thereafter, at the end of each calendar quarter, even though the Cash Allocation, cash pending investment or distribution portions of the Account do not receive any investment advisory or brokerage services. (They do receive administrative and custodial services.) The Financial Advisor Fee is also assessed on 100% of the value of assets in Accounts invested in Platform Strategies. In some low interest-rate environments, the Financial Advisor Fee plus Platform Fee can exceed the amount of interest paid on the Cash Allocation. It is anticipated that, when looked at jointly, AssetMark Trust and AssetMark will receive more compensation on the Cash Allocation and cash pending investment or distribution portions of Accounts invested in the ICD Program than on Account assets invested in the Accounts’ investment Strategy. The target Cash Allocation is 2%, and the Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. Accounts enrolled in AssetMark’s Tax Management Service (“TMS)” are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives. In addition to the Cash Allocation, Client Account will also hold cash pending investment or distribution and these cash amounts will be invested in the ICD Program. Additionally, Funding Accounts will be invested in the ICD Program. (A Funding Account is used to receive cash and assets transferred in kind before sale or transfer to an advised Account.). You may opt out of the ICD Program for your Cash Allocation. If you opt out of the ICD program, your Cash Allocation will be invested in one or more money market mutual funds. Cash that is not yet in a sweep vehicle (due to trading activity, residuals or new cash in a funding account) will simply be held in cash until swept to the ICD Program or money market mutual fund, when cash is moved from the funding to managed account, or typically by the following business day. Administrative Accounts: If a Client selects an Administrative Cash Account, all of the Administrative Cash Account will be placed in the ICD Program, unless the amount of the deposit qualifies for, and the Client elects, the High Yield Cash Program, which is also part of the FDIC Insured Cash Program but one in which the interest rates credited are expected to be higher than those credited ICD Program deposits. The interest rate paid on the High Yield Cash program can be negotiable. General Securities Accounts (“GSAs”) may also hold FDIC-Insured Cash Program Funds. You may also opt out of the FDIC- Insured Cash Program, in which case your account will be invested in one or more money market funds. There is no Platform Fee and no Custodial Account Fee for Administrative Cash accounts. Any Financial Advisor Fee payable pursuant to a Client Advisory Agreement will be payable on an Administrative Cash Account unless AssetMark receives instructions not to charge the Financial Advisor Fee. Although there is no Platform Fee for Administrative Cash Accounts with deposits in the FDIC-Insured Cash Program, if the cash is deposited in the ICD Program and not the High Yield Cash Program, then those Client participation in the FDIC-Insured Cash Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust receives compensation from the Program Banks for the record keeping and administrative services it provides in connection with maintaining the FDIC-Insured Cash Program (the “Program Fee”). The interest rates paid Client Accounts under the FDIC-Insured Cash Program are determined by AssetMark Trust, in consultation with AssetMark, and are based on the interest rates paid by the Program Banks, less the Program Fees paid to AssetMark Trust by the Program Banks. In determining the interest rates paid Client Accounts, AssetMark Trust and AssetMark also consider other factors, including the rates paid by competitors. The Program Fees paid to AssetMark Trust can be up to 4% on an annualized basis viewed on a rolling twelve-month basis, and across all Deposit Accounts. The amount of the Program Fee paid to AssetMark Trust and Administrative Fee paid to the third-party Program Administrator reduce the interest rate paid on Client Program Deposits. AssetMark Trust has discretion over the amount of its Program Fee, and AssetMark Trust reserves the right to modify the Program Fees it receives from Program Banks. This discretion in setting the Program Fee creates a conflict of interest on the part of AssetMark Trust and AssetMark; the greater the Program Fee AssetMark Trust receives – which is determined by AssetMark Trust in consultation with AssetMark - the lower the interest rate paid to Clients. In certain interest rate environments, the Program Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Program Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. The gross interest rates paid by each Program Bank, which affects the interest rates paid in the FDIC-Insured Cash Program, do and are expected to vary from Program Bank to Program Bank; this creates a conflict for AssetMark Trust when selecting Program Banks in that it incentivizes AssetMark Trust to select the banks that pay higher interest rates. No part of the Program Fee is paid to Financial Advisors. Neither AssetMark nor AssetMark Trust share any revenue from the Program with individual AssetMark employees, Financial Advisory Firms who use our Platform, or Financial Advisors who provide advice to clients with Accounts on AssetMark Platform Disclosure BrochureThis must remain with the Client Page 21 of 38 our Platform. This is a mitigation against the conflict of interest relating to the fees and revenue AssetMark Trust (and AssetMark, Inc. as an affiliate) earn from the Program. Trust can be up to 4% on an annualized basis viewed on a rolling twelve-month basis across all CDs. AssetMark Trust has discretion over the amount of its Placement Fee, and AssetMark Trust reserves the right to modify the Placement Fees it receives from Destination Institutions. This discretion in setting the Platform Fee creates a conflict of interest on the part of AssetMark Trust and AssetMark; the greater the Placement Fee AssetMark Trust receives -- which is determined by AssetMark Trust in consultation with AssetMark -- the lower the interest rate paid to Clients on CDs. In certain interest rate environments, the Placement Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Placement Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. No part of the Placement Fee is paid to Financial Advisors. The Program Fees paid to AssetMark Trust can be greater or less than compensation paid to other Platform Custodians with regard to cash sweep vehicles. The interest rate Program Deposits earn with respect to the AssetMark Trust FDIC-Insured Cash Program are expected to be lower than interest rates available to depositors making deposits directly with a Program Bank or with other depository institutions. Program Banks have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Program Bank. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest and other rates available the market, including money market mutual fund rates. The Placement Fees paid to AssetMark Trust can be greater or less than compensation paid to other custodians for similar services. The interest rate CDs earn with respect to the CDARS Program offered through AssetMark Trust can be lower than interest rates available to depositors making deposits directly with, or purchasing CDs directly from, a Destination Institution or other banks or depository institutions. Destination Institutions have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Destination Institution. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest on CDs and other rates available the market, including money market mutual fund rates. If an Account’s cash is invested in a money market mutual fund (because, for example, the Account opted out of the FDIC-Insured Cash Program or is a Section 403(b)(7) custodial account), AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Program Fees it receives from Program Banks in the FDIC-Insured Cash Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers and that has been its recent experience. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Program Fee from Program Banks than the service fee from money market mutual funds. In addition to CDs, AssetMark Trust custodial clients may invest cash in the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts) and/or money market mutual funds. If an Account’s cash is invested in a money market mutual fund, AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Placement Fees it receives from Destination Institutions in the CDARS Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Placement Fee from Destination Institutions than the service fee from money market mutual funds. CDARS Program for Certificates of Deposits In addition to the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts), AssetMark Trust makes available to its custodial client a Certificate of Deposit Account Registry Service® (“CDARS”) Program that allows a depositor to deposit amounts in Certificates of Deposit (“CDs”) at one or more depository institution insured by the Federal Deposit Insurance Corporation (“FDIC”). Deposits in the CDARS Program are deposited through a network of individual “Destination Institutions” unaffiliated with AssetMark Trust. Subject to the satisfaction of certain conditions, these deposits are eligible for FDIC insurance up to the maximum amount permitted by the FDIC, currently $250,000 for all deposits held at each Destination Institution in the same legal capacity. AssetMark Trust is not a depository institution and does not issue or offer CDs. There is no Platform Fee is assessed on the CDs held in your GSA. If instructed by your Financial Advisor, a Financial Advisor Fee can be charged. Securities-Backed Lines of Credit (“SBLOC”) If Clients select AssetMark Trust to act as their Platform Custodian, they can use the holdings in their non-retirement Account(s) as collateral for a loan. Such loans are usually referred to as Securities- Backed Lines of Credit (“SBLOC”). Conflicts of Interest: Suitability: Using an Account as collateral for a loan is not suitable for all Clients. Securities-backed loans involve a number of risks, including the risk of a market downturn, tax implications if pledged securities are liquidated, and the potential increase in interest rates, and other risks. If the value of pledged securities drops below certain levels, the borrower can be required to pay down the loan and/or pledge additional securities. Clients must consider these risks and whether a securities- backed loan is appropriate before applying. Clients should consider these issues and discuss their financial position and objectives and whether using their investments as collateral for a loan is appropriate with their Financial Advisor. Client participation in the CDARS Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust receives compensation from the Destination Institutions for the placement of deposits in CDs through the CDARS Program (the “Placement Fee”). (The third-party administrator of the CDARS Program also receives a fee (“CDARS Administrative Fee”) from the Destination Institutions.) AssetMark Trust, in consultation with AssetMark, determines the amount of its Placement Fee, and the Placement Fee reduces the interest rates paid by the Destination Institutions on the CDs under the CDARS Program, as does the CDARS Administrative Fee paid to the third-party CDARS Program Administrator. In determining the Placement Fee, AssetMark Trust and AssetMark consider a number of other factors, including the rates paid on CDs in competitor programs. The Placement Fees paid AssetMark There are two general ways for a Client to apply for a loan using the assets in their non-retirement AssetMark Trust custodial Account(s) as collateral: 1. Apply for a loan through a lender available through AssetMark Platform Disclosure BrochureThis must remain with the Client Page 22 of 38 AssetMark Trust’s Cash Advantage™ Lending service; or 2. Apply for a loan from the lending institution of the Client’s choice. year (for prospectus deliveries). This receipt by AssetMark Trust creates a conflict of interest in that it is to AssetMark Trust’s advantage to offer Broadridge Class Action Services to its clients. AssetMark Trust addresses this conflict by this disclosure, by making clear to clients that they can opt out of the services and by having a procedure for them to do so. An additional conflict exists as follows. Clients can choose as the Strategy for their Account one managed by AssetMark Trust affiliate, AssetMark. AssetMark would then have the conflict of choosing for its advisory clients securities likely to be involved in class actions, because such could increase the likelihood that AssetMark Trust clients would choose to use Class Action Services. AssetMark Trust and AssetMark, address this conflict by disclosing it. AFFILIATE FEE INCOME AND ASSOCIATE CONFLICTS DISCLOSURE AssetMark Trust Company’s Cash Advantage™ Lending Service: AssetMark Trust has established relationships with two separate lenders to which Clients can apply for a line of credit under AssetMark Trust’s Cash Advantage™ Lending service. Currently, the two lenders are Supernova Lending, Inc. (“Supernova”) and The Bancorp Bank, an FDIC-insured bank (“Bancorp”). AssetMark’s arrangements with these lenders are designed to streamline the loan application process and provide the lenders access to information about the Accounts that Clients use as collateral for the loans. AssetMark Trust is not affiliated with either Supernova or Bancorp, and each is responsible for its own services. Clients may also use their own lender. AssetMark Trust does not have the authority to encourage Clients to take a loan and does not have the authority to decide whether one of the lenders in its Cash Advantage™ Lending service will offer Clients loans. The interest rate paid for a line of credit can be negotiated. Compensation and conflicts of Interest: AssetMark Trust benefits if a Client takes a loan because the lenders in the Cash Advantage™ Lending service pay AssetMark Trust compensation based on outstanding loan balances. AssetMark Trust has discretion to reduce its compensation in order to reduce the interest rate charged a loan. AssetMark Trust has a conflict of interest with respect to the interest rates charged on loans; the higher the compensation AssetMark Trust receives, the more expensive the loans are for Clients. GPS Fund Strategies and GPS Select Client Accounts invested in these Strategies will receive allocations, determined by AssetMark, among AssetMark ‘s Proprietary Funds. AssetMark receives fees from the Proprietary Funds in which these Accounts invest. The fees differ between Funds and the total fees collected will vary depending upon the profile selected by the Client and the fund allocation within each profile. If a Client elects the GPS Fund Strategies, the Client authorizes and instructs that the Account be invested pursuant to the selected profile, acknowledges that fund advisory and other fees collected by AssetMark will vary, and approves of the fee payments to AssetMark. The Client will be given prior notice if these allocations or mutual funds change resulting in fee payments and, unless the Client or the Financial Advisor gives notice to AssetMark, the Client consents to these changes. If a Client selects GPS Select, the Client authorizes and instructs that the Account be invested pursuant to the selected profile and acknowledges that AssetMark is permitted to modify Fund allocations within a range such that fund management fees earned by AssetMark can vary within a range of 0.30% of the assets in the Strategy. Client approves fund allocations within this range and acknowledges Client will not receive prior notice of the fund allocation changes unless such allocations would exceed the 0.30% range. Deposit Accounts Opened through AssetMark Trust Company’s Cash Advantage™ Service If Clients select AssetMark Trust as their Platform Custodian, they can choose to open a deposit (checking) account at Bancorp, the FDIC-insured bank that offers online banking services and debit cards through AssetMark Trust’s Cash Advantage™ service. Bancorp deposit accounts and AssetMark non-retirement custodial accounts can be linked, so that amounts can be automatically transferred between accounts based upon the minimum and maximum targets set for balances in the Client’s Bancorp checking account. AssetMark Trust benefits financially if Clients open accounts at Bancorp because Bancorp pays AssetMark Trust compensation based on the average monthly balances in Clients’ deposit accounts. CLASS ACTION SERVICES OFFERED BY AFFILIATE For more information regarding the fees collected by AssetMark when using these Strategies, refer to the allocation tables provided in Exhibit C at the end of the Disclosure Brochure. To the extent that an IMA Manager invests Account assets in, or a Portfolio Strategist makes an allocation to, a fund managed by AssetMark or an AssetMark affiliate, AssetMark or the AssetMark affiliate will typically earn investment advisory or other fees from the fund. To the extent that AssetMark makes an allocation or invests Account assets in a fund managed by an AssetMark affiliate, AssetMark will rebate a portion of the fees paid. INCENTIVE COMPENSATION Certain AssetMark associates, typically sales associates, are eligible to receive compensation pursuant to a Sales Incentive Plan (“SIP”). Payments under a SIP are based on meeting certain production goals in support of AssetMark’s long-term growth strategy and profitability but are not based on specific product offerings. Financial Advisors, not AssetMark associates, are responsible for a Client’s suitability and/or investment recommendations. AssetMark can also provide additional incentives for affiliate (Adhesion Wealth Services) program referrals or to promote services, e.g. tax management services. Certain AssetMark associates are also eligible to receive. AssetMark Trust has contracted with Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to provide Class Action Services to AssetMark Trust custodial clients. Broadridge will be compensated for its Class Action Services to AssetMark Trust clients by retaining 20% of class action proceeds payable to AssetMark Trust clients (who have not opted out of the Class Action Services). AssetMark Trust also uses Broadridge as a service provider for other services. Broadridge is compensated by AssetMark Trust or another party, such as the security issuer, depending on the service. For example, AssetMark Trust pays Broadridge to deliver prospectuses related to the holdings in client accounts to AssetMark Trust clients, but the security issuer pays Broadridge for delivery of proxy materials. Broadridge provides incentives to AssetMark Trust to use Broadridge by providing rebates to AssetMark Trust if multiple services are used. AssetMark Trust receives payments from Broadridge based on the compensation Broadridge receives for delivery of proxy materials to AssetMark Trust clients, and the rate used to calculate these payments will increase if Broadridge Class Action Services are used. The rebate paid by Broadridge to AssetMark Trust (which is based on the compensation Broadridge receives for proxy material delivery from the security issuer) can exceed the amount of fees paid by AssetMark Trust to Broadridge during the AssetMark Platform Disclosure BrochureThis must remain with the Client Page 23 of 38 BROKERAGE PRACTICES CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING TRADE EXECUTION AND BROKERAGE ALLOCATION The Financial Advisory Firm provides investment advisory services to the client. The following summary describes the Code of Ethics for AssetMark, as the Platform sponsor. Trading is directed by and is the responsibility of AssetMark or the Discretionary Manager, if applicable. Subject to the Client’s chosen Solution Type and Strategies, AssetMark or the Discretionary Manager gives instructions for the purchase and sale of securities for Client Accounts. AssetMark or the Discretionary Manager selects the broker-dealers or others with which transactions for Client Accounts are effected. There is often an additional charge by the Platform Custodian, if AssetMark or the Discretionary Manager, as applicable, determines to trade away from the selected brokerage firm. AssetMark has adopted a Code of Ethics (the “Code”) that is intended to comply with the provisions of Rule 204A-1 under the Advisers Act, which requires each registered investment adviser to adopt a code of ethics setting forth standards of conduct and requiring compliance with federal securities laws. Additionally, the Code is designed to comply with Section 204A of the Advisers Act, which requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by any person associated with such investment adviser. The Code requires that all “Supervised Persons” (including officers and certain affiliated persons and employees of AssetMark) in carrying out the operations of AssetMark, adhere to certain standards of business conduct. Specifically, the Code requires that these persons: (i) comply with all applicable laws, rules and regulations; (ii) avoid any conflict of interest with regard to AssetMark and its Clients; (iii) avoid serving their personal interests ahead of the interests of AssetMark and its Clients; (iv) avoid taking inappropriate advantage of their position with AssetMark or benefiting personally from any investment decision made; (v) avoid misusing corporate assets; (vi) conduct all of their personal securities transactions in compliance with the Code; and (vii) maintain, as appropriate, the confidentiality of information regarding AssetMark’s operations. AssetMark or the Discretionary Manager, if applicable, will generally direct most, if not all transactions to the Platform Custodian. Trades are bundled by Custodian in trading blocks and submitted for execution on a pre-determined randomized rotation, or through simultaneous submission to all Custodians. In addition, if the selected Custodian is AssetMark Trust, generally most, if not all transactions will be directed to Fidelity Brokerage Services, LLC, and/or National Financial Services, LLC (collectively and individually “Fidelity”) or other broker-dealers selected by AssetMark, and contracted with by AssetMark Trust, in view of their execution capabilities, and because the selected broker-dealer(s) is paid by AssetMark or AssetMark Trust and generally does not charge Client Accounts transaction based fees or commissions for its execution service. In certain circumstances, better execution could be available from broker-dealers other than the broker-dealer(s) generally used by the Client’s Custodian. AssetMark, or other Discretionary Manager is permitted to trade outside the selected broker-dealer(s). For Accounts custodied at AssetMark Trust, AssetMark, or the Discretionary Manager as applicable, can combine purchase and sale transactions for a security into a single brokerage order. By combining the purchase and sale transactions into a single brokerage order, Clients that are buying a security will receive the same average price as Clients that are selling the same security and Clients selling will receive the same average price as Clients that are buying the same security, based on the single net order placed by AssetMark. This aggregation process could be considered to result in a cross transaction among affected Client Accounts. The Code contains a number of prohibitions and restrictions on personal securities transactions and trading practices that are designed to protect the interests of AssetMark and its Clients. First, the Code prohibits trading practices that have the potential to harm AssetMark and/or its Clients, including excessive trading or market timing activities in any Account that AssetMark manages, trading on the basis of material non-public information, and trading in any “Reportable Security” when they have knowledge the security is being purchased or sold, or is being considered for purchase or sale by the Accounts managed by AssetMark or any AssetMark-advised mutual funds. Second, the Code mandates the pre-clearance of certain personal securities transactions, including transactions in securities sold in initial public offerings or private placements. The Code also requires the pre-clearance of Reportable Security transactions for certain Access Persons (“Access Persons” is a segment of the Supervised Persons group that have access to AssetMark pre-trade information). Finally, the Code requires Access Persons to submit, and the Chief Compliance Officer (the “CCO”) to review initial and annual holdings, and quarterly transaction reports. AssetMark utilizes StarCompliance to provide enhanced tracking of certain employee transactions and gives AssetMark the ability to analyze those employee trades against certain parameters and transactions in its managed Accounts or any Proprietary Funds. Access Persons also utilize this system to annually certify their receipt of, and compliance with, the Code and pre-clear their Reportable Security transactions, if they are required to do so by the Code. Clients should be aware that the arrangement that AssetMark Trust has with Fidelity described above creates a financial incentive for AssetMark to utilize that broker-dealer regardless of execution quality, in order to avoid incurring the charges that accompany trading with other broker-dealers. This incentive creates an actual or potential conflict of interest to the extent that AssetMark utilizes Fidelity to execute trades for Client Accounts when higher quality execution might be available through other broker-dealers. However, in fulfilling its fiduciary obligations, AssetMark evaluates the execution quality received by Clients at their selected Custodians on a periodic basis. Any execution trends over a period of time are researched and discussed at AssetMark’s quarterly Execution Review Committee meeting. In addition, some investment solutions that have historically only been available at AssetMark Trust, are now available at other Custodians. All Supervised Persons under the Code are responsible for reporting any violations of the Code to the CCO. The Code directs the CCO to submit reports to the Board of Trustees of any AssetMark-advised mutual funds regarding compliance with the Code, and to impose sanctions on violators, as warranted. AssetMark will provide a copy of the Code to any Client or prospective Client upon request. ETFs are traded daily at market determined prices on a national exchange in a similar manner to individual equity securities. Although ETFs are priced intra-day in the same manner as equity securities, the actual timing of trade order execution varies, depending upon trade volume, systems limitations and issues beyond AssetMark’s control, and the actual fulfillment of trade orders by the broker in the market can take place at different prices and different times AssetMark Platform Disclosure BrochureThis must remain with the Client Page 24 of 38 RECEIPT OF EXECUTION REPORTS AssetMark does not utilize soft dollars by directing trades to broker- dealers and accumulating soft dollar credits. AssetMark receives execution reports from vendors such as Abel Noser and Fidelity, which it uses to review best execution of trades on the Platform. AssetMark does not pay directly for these reports. The Client’s asset-based Platform Fee, which includes custody, does not vary depending on whether AssetMark receives these execution reports or not. CUSTODIAL RELATIONSHIPS throughout the day. AssetMark submits ETF trades for a given day to each broker in a random order, or simultaneously where possible, to provide the most feasibly equivalent execution for all participating Clients. On days with heavy trade volumes, AssetMark can utilize “not held” and/or “limit order” instructions in an attempt to reduce market impact on the price received for the security. When a Portfolio Strategist implements a reallocation adjustment or rebalance to its ETF strategy, and/or in the case of exceptionally high volume requests, AssetMark can utilize an alternate agency broker or an “authorized participant” liquidity provider selected by AssetMark to execute orders for Clients at multiple custodians, and then “step out” those trades to those custodians on a net fee basis. AssetMark also seeks and can rely upon a Portfolio Strategist’s recommendation for stepping out to an alternative broker when executing the Portfolio Strategists reallocation. There are no separate fees charged for ETF trades that are stepped out to an alternate broker, unless in the case of a broker trading on an agency basis, in which case their flat fee will be included in the execution price. On a quarterly basis, AssetMark’s Execution Review Committee will review the step out trade activity in the Accounts. AssetMark receives Model Portfolios or trade recommendations from Strategists on a non-discretionary basis. There can be instances in which the policy of a specific Strategist or Discretionary Manager is to effect trades in the Accounts of their discretionary Clients before delivering Model Portfolios to non- discretionary Clients. ACCOUNT LIQUIDITY RESERVE AssetMark does not provide custodial services to its Clients. AssetMark is determined to have custody of client funds in accordance with the SEC’s Custody Rule given the affiliation between AssetMark and AssetMark Trust, the qualified custodian of the Advisor’s clients’ assets. Given this determination, AssetMark will engage an independent public accountant to conduct an annual, independent surprise audit of client funds and securities. Client assets are held with banks, financial institutions or registered broker-dealers (“Platform Custodians” or “Custodians”) that are qualified Custodians under Advisers Act Rule 206(4)–2. Clients will receive custodial account statements directly from their selected Platform Custodian at least quarterly. Clients are urged to carefully review those statements and compare the custodial statements to the quarterly performance reviews that are available to them. The Client agrees to review all Account Statements, trade confirmations and other notices and confirmations of information and promptly notify AssetMark of any errors within 10 days. AssetMark shall not be liable for any losses due to errors that remain unreported for more than 10 days after receipt of mailed Account Statements, trade confirmations and other notices and confirmations of information or the electronic posting of such documents. Not all Solution Types are offered at all Custodians. to the following The AssetMark Platform provides access Platform Custodians: • AssetMark Trust, an Arizona trust company and affiliate of AssetMark, 3200 North Central Avenue, Seventh Floor, Phoenix, Arizona 85012. Its mailing address is P.O. Box 80007, Phoenix, Arizona 85060. • Charles Schwab & Co., Inc. (“Schwab”). 7801 Mesquite Bend Drive, To properly maintain cash flows for Client needs, a portion of all Client Accounts invested in a Strategy is maintained in a short-term investment vehicle. This liquidity reserve (or “Cash Allocation”) is generally referred to as the Custodian’s cash “sweep” vehicle. The Cash Allocation target is 2%, and an Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. (Note: Accounts enrolled in AssetMark’s Tax Management Service (“TMS)” are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives.) Ste. 112, Irving, TX 75063 • Fidelity Brokerage Services, LLC (“Fidelity”). 200 Seaport Boulevard, Boston, MA 02210. • Pershing Advisor Solutions (“PAS”). One Pershing Plaza, Jersey City, NJ 07399. The sweep vehicle for the Cash Allocation will differ by the Custodian and Strategy selected by the Client. At AssetMark Trust, it is usually AssetMark Trust’s Insured Cash Deposit (“ICD”) Program but depending upon the Strategy selected for the account, could be a money market mutual fund or other short-term pooled investment vehicle. Additionally, an AssetMark Trust Client can opt out of the ICD Program for the Account’s Cash Allocation, in which case the Account will be invested in one or more money market funds (see FDIC-Insured Cash Program, above). DELIVERY OF FUND REDEMPTION PROCEEDS On an exception basis, AssetMark can allow for the selection of a Platform Custodian not listed above. The assets of each Client Account are custodied at a Platform Custodian, and each Client must contract separately with their selected Platform Custodian for custodial services. Payment for the custodial and brokerage services provided by the Platform Custodian to the Account are included in the AssetMark Platform Fee. Refer to “Custodial Account Fees and Servicing Costs” below, for more information on what is included in the Platform Fee. The Client authorizes the Custodian to debit Platform Fees from the Account. Mutual funds are included in some Client Accounts. Under certain economic or market conditions or other circumstances, mutual funds pay redemption proceeds by an in-kind distribution of securities in lieu of cash. Mutual funds, broker-dealers or transfer agents can experience delays in processing orders, or suspend redemptions or securities trading under emergency circumstances declared by the SEC, the New York Stock Exchange or other stock exchanges or regulatory agencies. All Client Accounts are separately maintained on the records of the Client’s selected Custodian. With regard to AssetMark Trust, Client funds and securities are typically held in omnibus accounts at various banks, broker-dealers and mutual fund companies. The holdings of these omnibus accounts reflect book-entry securities, which AssetMark Trust allocates to the individual Client Accounts on AssetMark Platform Disclosure BrochureThis must remain with the Client Page 25 of 38 its own records. AssetMark Trust uses sub-custodians in fulfilling its responsibilities, including National Financial Services Corp., (whose affiliated broker-dealer, Fidelity Brokerage Services, LLC, also provides brokerage and clearing services for Client Accounts), and JP Morgan Chase (f/k/a Bank One). AssetMark has negotiated with each Platform Custodian the compensation that AssetMark will pay the Custodian for providing custodial and brokerage services to Client Accounts. AssetMark provides third-party Platform Custodians with significant support services with respect to the custodial services that the Custodians must perform, including, for example, reviewing new Account paperwork and communicating with Financial Advisors to resolve incomplete custodial paperwork. These Services are taken into consideration when AssetMark and each Custodian negotiate the compensation that AssetMark will pay the Custodian for providing custodial and brokerage services to Client Accounts. The amount of the compensation that AssetMark pays differs between Custodians. Additionally, AssetMark generally receives more revenue when Clients choose AssetMark Trust as their Custodian. These differences in payments and revenue create conflicts of interest for AssetMark. AssetMark addresses these conflicts by having the same Platform Fee apply regardless of the Custodian chosen and by allowing the Client to choose their own Custodian, which can be AssetMark’s affiliated Custodian, AssetMark Trust. Although the Platform Fee is the same among Custodians, different fees for incidental expenses can apply. Pursuant to the services agreement between AssetMark and AssetMark Trust, AssetMark reallocates expenses for non-advisory services that AssetMark provides to AssetMark Trust. These services are primarily administrative in nature, all of which are provided by AssetMark for the benefit of all affiliates, including AssetMark Trust. PROSPECTUSES & OTHER INFORMATION The Client, with the assistance of their Financial Advisor, shall select a Custodian for their Account. The Custodian selected by the Client shall send periodic account statements detailing the Client’s individual Account(s), including portfolio holdings and market prices, all transactions (such as trades, cash contributions and withdrawals, in-kind transfers of securities, interest and dividend or capital gains payments) for each individual Client Account, and fee deductions. The Custodian will also provide full year-end tax reporting for taxable accounts and fiscal year-end reporting for Accounts held for tax-qualified entities; and access to electronic or web-based inquiry system that provides detailed information on each Client’s Account, on a daily basis. Additionally, Clients can inquire about their current holdings and the value of their Accounts on a daily basis by electronic or web-based access. The Custodian can also send a Transaction Acknowledgement to the Client for all cash contributions, withdrawals and in-kind transfers as they occur. Although Clients usually waive receipt of individual transaction confirmations, a Client can elect, by written request to their Custodian, to receive a confirmation of each security transaction and such confirmations will thereafter be provided. A Client can incur termination fees from another custodian when transferring their account to ATC. ATC can elect to reimburse these termination fees to the Client. This arrangement can be deemed to cause a conflict of interest because they provide Financial Advisory Firms and Financial Advisors and their Clients with incentives to place Client assets with ATC, and ATC and AssetMark can earn more revenue. The Custodians will mail a letter of acknowledgement confirming the establishment of an Account and receipt of assets, to the Account’s address of record. Clients are strongly encouraged to review all statements, acknowledgements and correspondence sent by the Custodian. CUSTODIAL ACCOUNT FEES AND SERVICING COSTS The Client designates AssetMark, or the applicable Discretionary Manager, as their agent and attorney-in-fact to obtain certain documents related to securities purchased on a discretionary basis for their Account. If the Client selects AssetMark Trust as their Custodian, Clients waive receipt of prospectuses, shareholder reports, proxies and other shareholder documents. This waiver can be rescinded at any time by written notice to AssetMark. Clients that select a Custodian other than AssetMark Trust, i.e., PAS, or Fidelity elect to receive prospectuses, shareholder reports, proxies and other shareholder materials for Accounts invested in a Mutual Fund Strategy or Guided Portfolios, i.e., GPS Fund Strategies or GPS Select. The Client is entitled to receive materials related to a Proprietary Funds advised by AssetMark. FINANCIAL INFORMATION In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition in this Item. AssetMark has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has never been the subject of a bankruptcy proceeding. The Platform Fee is a “wrap” fee and includes payment for advisory, administrative, custodial and brokerage services. AssetMark pays each Platform Custodian to provide custodial and brokerage services to Client Accounts. Clients do not pay transaction fees on any trades made in the Solution Types available on the Platform, unless described in the separate Custody Agreement with their selected Custodian. There are some Solution Types that do incur additional fees at the Custodian, such as fixed-income solutions or those that hold alternative or option products. Additionally, AssetMark Trust charges an annual Administrative Custody Fee of $25.00 and reserves the right to waive this fee at its discretion. ITEM 10 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS Not applicable to AssetMark as the Platform sponsor. Each Client will enter a custodial agreement with their selected Custodian and be provided a fee schedule or schedule of charges. Refer to the Custody Agreement or schedule of charges for specific fees applicable to the Client Account that are not included in AssetMark’s Platform Fee. For example, the Custodians can also charge termination fees and various other miscellaneous fees for wires, returned checks and other non-standard activity on an Account such as fees for alternative investments. Custody fees can also apply to Accounts in Solution Types that are either closed or no longer offered to new Clients. As well, for some legacy strategies on the AssetMark Platform no longer available to new investors, AssetMark continues to use retail share classes. All custody fee details are clearly presented in each Custodian’s fee schedule and separate custody agreement. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 26 of 38 EXHIBIT A – SOLUTION TYPES – MODEL PROVIDERS AND INDIVIDUAL MANAGED ACCOUNTS ASSETMARK PLATFORM MODEL PORTFOLIOS INDIVIDUALLY MANAGED ACCOUNTS PROPRIETARY 3RD PARTY PROPRIETARY 3RD PARTY GPS Fund Strategies Acadian 4 AssetMark Custom HNW City National Rochdale (HNW) GPS Select1 AlphaSimplex CIBC (HNW) Guided Income Solutions2 Clark PUMA (HNW) Algorithmic Investment Models (former Beaumont) Market Blend - Global William Blair (HNW) Market Blend - US AllianceBernstein4, 5 Parametric - Custom MarketDimensions BlackRock 4, 5 Fixed-Income OBS DFA/EFS Portfolios Capital Group (American Funds)4 Parametric Savos Fixed Income – Laddered Bonds WealthBuilder Brown Advisor 4, 5 Capital Group AssetMark Asset Builder Dorsey Wright Clark AssetMark Personal Values DoubleLine3 Nuveen AssetMark Income Builder Federated-Hermes 4 I Savos Preservation Fiera Capital 4 Savos GMS/PMP1 First Trust Savos USRC Franklin Templeton 4 Savos Personal Portfolios1 Hartford (Wellington)4 GuidePath Managed Futures3 JP Morgan 4 Julex6 S N O T U L O S T N E M T S E V N I Kensington Logan 4 Morningstar4 Neuberger Berman 3, 4 New Frontier Nuveen 5 PIMCO Principal (Principal Edge)4 State Street Stone Ridge3 VanEck WestEnd William Blair 4 FINANCIAL ADVISOR CUSTOM ACCOUNTS¹ Multi-Strategy Account (MSA) Custom GPS Select Custom Savos GMS and PMP OTHER SERVICES AND NON-MANAGED ACCOUNTS Administrative Accounts General Securities Account ICD and High Yield Cash INVESTMENT VEHICLES closed-end mutual funds; open-end mutual funds; ETFs, alternatives, stocks, fixed income, bonds, options, preferred stocks; treasury bonds, bills and notes, bank notes. ¹ Financial advisor can customize this Model Portfolio to more closely reflect the Client’s specific needs or preferences 2 Goal or target-based Solution 3 Individual Mutual Fund or Model Provider offers at least one Individual Mutual Fund solution 4 Offers at least one equity model; used in SMA Program 5 Offers at least one ESG model 6 Closed to new business AssetMark Platform Disclosure BrochureThis must remain with the Client  Page 27 of 38 EXHIBIT B – ASSETMARK ASSET MANAGEMENT – SOLUTION TYPES available with or without an exposure to alternative investment mutual funds. With the assistance of the Financial Advisor, the Client’s selected GPS Fund Strategy will take into account the Client’s investment objective, if the Client is in an accumulation or distribution phase, if the Client seeks to have exposure to alternative investments or not, or seeks to use GPS Fund Strategies as a focused strategy in order to complement other Solution Types selected for the Client Portfolio. AssetMark Asset Management (“AAM”) serves as the Portfolio Strategist and Investment Manager for the proprietary Models and IMA Solution Types described below. AAM can exercise its discretion by making investment decisions that are tailored to one specific proprietary solution and not applicable to all proprietary solutions on the Platform. Investment Objective: Accumulation vs. Distribution. MODEL PORTFOLIOS Guided Portfolios • GPS Fund Strategies Accumulation Objective. An accumulation objective typically refers to investors who are still working and seeking to build their wealth base. A blended mix of Investment Strategies with an emphasis on growth of capital is used. • GPS Select Mutual Fund Solution Types • Market Blend (GuideMark Funds) • OBS/DFA • AssetMark Asset Builder Distribution Objective. A distribution objective typically refers to investors who are in or near retirement and seeking to take withdrawals from their asset base over time. A blended mix of Investment Strategies with an emphasis toward providing income with a secondary objective of growth of capital is used. • AssetMark Personal Values • AssetMark Income Builder Exchange-Traded Fund (“ETF”) Solution Types • MarketBlend Focused GPS Fund Strategies. Focused GPS Fund Strategies provide a means for Clients to access pre-set strategies based primarily on the Client’s risk profile and their desire for focused exposure to one or more Investment Strategies used to complement other Solution Types selected for the Client Portfolio. Mutual Fund/ETF Blend Solution Types • WealthBuilder • MarketDimensions Core Markets Focused. Strategies seek to provide exposure to growth of capital markets and are generally allocated to Core solutions blending a mix of equities and bonds. Savos Solution Types • IMA Accounts, (Equity Balanced, Fixed-Income, and Custom High-Net Worth) Tactical Focused. Strategy seeks to provide flexible exposure to the equity market dependent on risk environment and for defensive equity exposure. • Savos Preservation Strategy • Savos GMS Accounts Tactical-Low Volatility Focused. Strategies seek to provide flexible exposure to the equity market alongside flexible bond exposures in a blended mix. • Savos PMP Accounts • Savos US Risk Controlled Strategy, and • Savos Personal Portfolios Low Volatility Focused. Strategy seeks to provide a low correlation to equities with low volatility experience similar to bonds for risk management purposes. Guided Income Solutions I. GUIDED PORTFOLIOS Multi-Asset Income Focused. Seeks to provide a blend of income and growth, and depending on the profile. A core position in the GuidePath Multi-Asset Income Fund is held with complementary exposure to GuidePath Growth Allocation, Tactical Allocation and Absolute Return. GPS Fund Strategies GPS Select For GPS Fund Strategies, AssetMark will provide investment allocations across Investment Strategies based on investment objectives, market outlook, risk profile and other preferences. As of the date of this Brochure, the GPS Fund Strategies primarily utilize NTF mutual funds advised by AssetMark, the GuidePath Funds. AssetMark advised mutual funds, including the GuidePath Funds, are collectively known as “Proprietary Funds. For GPS Select, AssetMark will provide investment allocations across Investment Approaches based on investment objectives, market outlook, risk profile and other preferences. Additionally, AssetMark will select the mix of Portfolio Strategists and Investment Managers, including AAM Solutions and Proprietary Funds. AAM starts with a baseline allocation across Investment Strategies; however, these allocations will tilt over time based on their view of the risk environment. AssetMark is compensated by the Proprietary Funds for its advisory services provided to the Proprietary Funds. The Platform Fee for the GPS Fund Strategies is lower than that charged for strategies with third party funds. The Platform Fee for the GPS Fund Strategies does not include a charge for advisory services but pays for custodial, trading, administrative and other services. GPS Select will invest in Strategies which include investments in both mutual funds and ETFs. Mutual fund share class is selected on a fund by fund basis and seeks to utilize institutional share classes. Some mutual funds have both institutional share classes, which do not charge fund shareholders 12b-1 fees but which typically do charge fund shareholders for shareholder servicing or sub-transfer agent fees, and retail share classes, which charge fund shareholders 12b-1 fees as well as shareholder servicing fees or sub-transfer agent fees. AssetMark will seek to use institutional classes where AAM starts with a baseline allocation across Investment Strategies; however, these allocations will tilt over time based on their view of the risk environment. This allocation mix is met with the use of GuidePath Funds and, as needed, GuideMark Funds. GPS Fund Strategies are AssetMark Platform Disclosure BrochureThis must remain with the Client Page 28 of 38 discussed above AssetMark will seek to utilize the lowest cost mutual fund share class for Accounts in the GPS Select Solutions, however, because of limitations on the securities available at the Platform Custodians, there will be circumstances where AssetMark is not able to obtain the lowest cost mutual fund share class available, and will have exercised “discretion” in selecting an alternative share class. Refer to Exhibit C at the back of this Disclosure Brochure for more information. MUTUAL FUND SOLUTION TYPES Market Blend Mutual Fund Strategies Market Blend Strategies use Proprietary Funds, and in Market Blend Strategies, AssetMark provides the following strategic asset allocation Strategies. With the assistance of the Financial Advisor, Clients can select from the following Market Blend Mutual Fund Strategies: these share classes are available. AssetMark has determined that for most Clients, transaction fee mutual funds and share classes would be more expensive than non-transaction fee mutual funds and share classes. The Platform Fee for these solutions is used to pay for the administration and servicing of the Accounts that AssetMark performs. In striving for consistency across all custodial options on the Platform in GPS Select, AssetMark will seek to select the lowest cost share class available across Custodians and that aligns the stated program Account minimum and allocation weighting of funds held with the fund’s prospectus requirements. Due to specific custodial or mutual fund company constraints, the institutional share class is not always consistently available. In those cases, AssetMark will seek to invest Clients in the lowest cost share class that is commonly available across Custodians. The institutional share class is typically lower, however, in some cases, the lowest share class can be the retail share class. See Servicing Fees Received by Custodians, Including AssetMark Trust Company and Share Class Use in Item 4, Service, Fees and Compensation. • Global GuideMark Market Blend • US GuideMark Market Blend With the assistance of the Financial Advisor, Clients can select from the following GPS Select products: • Select Wealth Preservation. Strategy seeks to preserve capital while keeping up with inflation and is allocated with a blended mix to selected Strategist portfolios across Investment Strategies. This Strategy is designed for wealth preservation and protection from inflation. • Select Accumulation. Strategies seek growth of capital and are allocated with a blended mix to selected Strategist portfolios Investment Strategies. • Select Distribution. Strategies seek a blend of income and growth of capital and are allocated with a blended mix to selected Strategist portfolios Investment Strategies. Strategist selection will be focused toward Strategists managing to a multi-asset income mandate or where income is a large component of the Strategy. This Strategy is also designed to provide an enhanced level of income and to control portfolio volatility. These Strategies will provide a strategic asset allocation across seven to ten core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the portfolio. The Global model will take global exposures while the US model will take domestic exposures. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. The investment vehicles used to implement the Strategy are the proprietary GuideMark Funds that provide exposure to each of the asset classes. AAM manages the Market Blend Strategies and the underlying Proprietary Funds, but the Client, with the advice of the Financial Advisor, chooses whether to invest, or remain invested, in the Market Blend Strategies. AAM does not advise the Client whether to invest, or to remain invested, in the Market Blend Strategies. Focused GPS Select are based primarily on the Client’s risk profile and desire for focused exposure to one or more Investment Strategies used to complement other Solution Types selected for the Client Portfolio. • Select Low Volatility. Strategy seeks to provide a low correlation to equities with low volatility experience and is allocated with a blended mix to selected Strategist portfolios mainly emphasizing bonds. This focused investment Strategy targets low volatility with a low level of return. It is important to note that Client Accounts invested in Market Blend Mutual Fund Strategies will receive allocations, determined by AAM, among the GuideMark Funds. AssetMark will receive advisory fees from the mutual funds in which these Accounts invest. The mutual fund advisory fees differ between funds and the total fund advisory fees collected by AssetMark will vary depending upon the profile selected by the Client and the fund allocation within each profile. If a Client, as advised by the Financial Advisor, selects a Market Blend Mutual Fund Solution, the Client authorizes and instructs that the Account be invested pursuant to the selected profile, acknowledges that the fund advisory fees collected by AssetMark will vary, and approve of the fund advisory fee payments to AssetMark, within the ranges provided In Exhibit C. The Client will be given notice if these ranges or funds change and it results in a higher average weighted fee earned. Unless the Client or Financial Advisor gives notice to AAM, Client consents to these changes. See Exhibit C for more information. • Select Tactical. Strategies seek to provide flexible exposure to the equity market alongside flexible bond exposures and are allocated with a blended mix to selected Strategist portfolios across mainly defensive equity and bond Investment Strategies. This focused investment Strategy seeks to limit participation in extreme market downturns while generally participating in normal markets. Higher risk profiles will hold higher exposure to Tactical Strategies while lower risk profiles will hold higher exposures to Diversifying Strategies. • Select Multi-Asset Income. Strategies seek to provide a blend of income and growth, and are allocated with a blended mix to selected Strategist portfolios across Investment Strategies. This focused investment Strategy seeks to provide an enhanced level of income across changing markets. AssetMark manages GPS Select using limited discretionary authority. While AssetMark will exercise limited discretion on the Portfolio asset allocation within portfolio investment sleeves, AssetMark relies upon the third-party Strategists to conduct individual security selection. As AssetMark Asset Builder AAM provides strategic asset allocation services utilizing mutual funds. Client asset allocations are dependent on the stated risk parameters and investment objectives of the Client. Assets are managed on a discretionary basis. Clients can transfer existing investments to fund the Account; however, all transferred assets will be liquidated and invested to the appropriate asset allocation without regard to any taxable gains or losses that can result. Periodic Account reviews will include Account rebalancing. Rebalancing can be performed without consideration for any realized taxable gains or losses that result. Clients can place reasonable restrictions on Accounts. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 29 of 38 MUTUAL FUND AND ETF BLEND SOLUTION TYPES MarketDimensions Strategies AssetMark Income Builder Income Builder is an asset allocation strategy designed to provide a higher level of current yield in comparison to traditionally asset allocated portfolios with a similar risk profile. Income Builder will allocate the portfolio across a variety of fixed income and equity investments: traditional fixed income, high yield fixed income, income and growth and traditional equities. While Income Builder is designed to provide a higher current yield, a higher yield is not guaranteed. For the MarketDimensions Strategies, AAM will seek to create strategic global portfolios through a combination of multiple asset classes including equities and fixed income. In seeking to maximize total return, these Strategies allocate to a diversified portfolio of domestic and international equity securities, domestic and international fixed income securities, and cash equivalent money market securities indirectly using Dimensional Fund Advisors mutual funds and ETFs (DFA Funds). With the assistance of the Financial Advisor, Clients can select from the following MarketDimensions Strategies. • Standard. The Global Standard Strategy will represent asset classes selected from the broad universe of DFA Funds. • Tax-Sensitive. The Tax-Sensitive Strategy will represent asset classes seeking to use tax-advantaged DFA Funds where possible. The Strategy will be reallocated typically one to two times per year. AAM will monitor the Strategies’ exposures to the asset classes on an ongoing basis for excessive drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. AssetMark Socially and Faith Based Screened Portfolios (Values Based Portfolios) At a Client’s request, AAM will offer portfolios managed for various social or faith based considerations (“Personal Values Portfolios”). Such portfolios can be offered under the Asset Builder and the AssetMark Custom High Net Worth strategies. Personal Values Portfolio allocations are typically constructed from mutual funds, but can also include Separately Managed Accounts, individual securities, closed-end funds and exchange traded funds. Mutual funds utilized in Personal Values Portfolios are selected from a more limited menu of mutual funds than “traditional” allocations. As a result, and though not expected, risk characteristics and performance returns of Personal Value Portfolios could vary significantly from our traditional Portfolios. Personal Values Portfolios can also be limited to certain investment types and securities and therefore, may not be fully diversified. You may wish to discuss these limitations with your Financial Advisor. Minimum Account sizes for applicable service levels apply and are subject to negotiation. ETF SOLUTION TYPES Beginning or after June 2025, AssetMark will no longer manage these strategies. Dimensional Fund Advisors will be assuming direct oversight and management of these strategies. Market Blend ETF Strategies OBS Strategies With the assistance of the Financial Advisor, Clients can select from the following Market Blend ETF Strategies: AAM will seek to create strategic global portfolios through a combination of multiple asset classes including equities and fixed income. In seeking to maximize total return, these Strategies allocate to a diversified portfolio of domestic and international equity Securities, domestic and international fixed income Securities, and cash equivalent money market securities indirectly using DFA Funds. These strategies will bias towards the factors favored by Dimensional Fund Advisors. With the assistance of the Financial Advisor, Clients can select from the following OBS Strategies. • AssetMark DFA/EFS. The Flagship Strategy will represent asset classes selected from the broad universe of DFA Funds. • Global Market Blend Strategies. These Strategies will provide a global strategic asset allocation across core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the Portfolio. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. On at least an annual basis the asset class exposures are reviewed for reallocation of the Strategy. The investment vehicles used to implement the Strategy are ETFs that are representative of the cap-weighted indices for each of the asset classes and lower cost. • AssetMark DFA/EFS. Enhanced International. The Enhanced International Strategy will represent asset classes selected from the broad universe of DFA Funds and will tilt exposures more towards international markets. The Strategies will be reviewed at least annually for reallocation. AAM will monitor the strategies’ exposures to the asset classes on a quarterly basis for excessive drift against volatility-based targets and will rebalance the Strategies if targets are breached. Beginning or after June 2025, AssetMark will no longer manage these strategies. Dimensional Fund Advisors will be assuming direct oversight and management of these strategies. WealthBuilder Strategies • US Market Blend Strategies. These Strategies will provide a domestic strategic asset allocation across core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the Portfolio. Asset class exposures are reviewed on an ongoing basis for drift against volatility-based targets and relative to the updated model based on new data being available. Where the drift exceeds pre-set criteria, the Account will be rebalanced or reallocated to the revised allocations. On at least an annual basis the asset class exposures are reviewed for reallocation of the Strategy. The investment vehicles used to implement the Strategy are ETFs that are representative of the cap-weighted indices for each of the asset classes and lower cost. Investment Strategies based on For WealthBuilder Strategies, AAM will provide strategic investment allocations across investment objectives, market outlook, risk profile and other preferences to provide AssetMark Platform Disclosure BrochureThis must remain with the Client Page 30 of 38 Savos GMS, PMP, US Risk Controlled and Savos Personal Portfolios AAM manages UMAs and is also referred to as Discretionary Manager providing discretionary investment management services. AAM selects securities directly for Client Accounts. IMA Accounts are permitted to hold investments selected by AAM, and these investments can include, but are not limited to, some or all of the following types of securities: ETFs; equities, closed-end mutual funds; open-end mutual funds; preferred stocks; Treasury bonds, bills and notes; and bank notes. The asset allocation decisions, and security selection decisions will be made solely by AAM at its discretion. seeking to grow their capital. AAM combines a Core Market globally focused Core portfolio of ETFs with complementary third-party mutual funds that represent other Investment Strategies. The Strategy will also be comprised of a 2% allocation to cash. For more information regarding the cash allocation, refer to the ICD Program section under Other Financial Industry Activities and Affiliations and Affiliate Conflicts of Interest. The goal of the portfolio is to manage risk efficiently through diversification of Strategy. The Core Market portfolio will provide a strategic asset allocation across seven to ten core asset classes in an effort to capture broad capital market returns while seeking to balance the pursuit of maximum total return against the control of risk in the portfolio. The portfolio is globally diversified with asset class exposures reviewed on a quarterly basis for drift against volatility-based targets. Where the drift exceeds pre-set criteria, the Account will be rebalanced. The mutual funds complement the Core Market portfolio and are selected based upon their representation of the approach. Each Fund undergoes deep due diligence before being used within the Strategy, and institutional shares are used. On an annual basis, the portfolio’s exposures are reviewed for reallocation of the Strategy. SAVOS SOLUTION TYPES For IMA Accounts, AAM employs comprehensive analysis, including specific mathematical, technical and/or fundamental tools and risk- control criteria in the management of Client Accounts. The focus of AAM as Discretionary Manager is to add value to each Client’s Account through: (i) the strategic and tactical determination and implementation of asset allocation levels; (ii) the selection of securities with investment characteristics which AAM believes are appealing; and (iii) the formation of portfolios with risk management options to match the portfolio to the Client’s chosen level of risk tolerance. • Savos Preservation Strategy • Savos GMS Accounts • Savos PMP Accounts • Savos US Risk Controlled Strategy For GMS and PMP accounts, a risk management strategy is implemented through the use of fixed income strategies. Portfolio allocations for these risk management strategies will vary based on individual Client objectives within target allocations established and monitored by AAM. • Custom Accounts - Savos Personal Portfolios - Savos Fixed Income Strategies • AssetMark Custom High Net Worth GMS & PMP Accounts Clients who select the GMS or PMP Account as their Solution Type must deposit at least $25,000 into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $25,000. A Client’s Account will be held by the Platform Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $25,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. Savos Preservation Strategy For the - Savos Preservation Strategy, AAM provides discretionary investment management services to the Account, and the Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and such other authorities appropriate for a discretionary manager of an investment account. In the Savos Preservation Strategy, the Client and their Financial Advisor need not make further selections to specify the Strategy for the Account. The Savos Preservation Strategy considered to be Risk/Return Profile 1 as a bond Investment Strategy. In a GMS or PMP Account, the Client authorizes AAM to provide discretionary investment management services to the Account. The Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and the other authorities appropriate for a discretionary manager of an investment account. AAM is permitted to invest the Account in individual securities, pooled investment vehicles, such as mutual funds or ETFs or in other securities or investments. The primary investment objective of the Savos Preservation Strategy is to generate a positive real (after-inflation) return over each 12 month period. A secondary objective is to limit the strategy’s sensitivity to changes in interest rates. Intra-year volatility and performance will vary and are independent of the Strategy’s primary investment objective. There is no guarantee that the Strategy’s primary and secondary investment objective will be met in all market conditions. The Account will be invested primarily in mutual funds and ETFs. Additionally, AAM is permitted to use one or more Proprietary Funds within the Strategy. The Strategy for each Proprietary Fund is described in more detail in the prospectus for the fund. All Proprietary Funds are registered investment companies for which AssetMark serves as investment adviser. is permitted to invest in, among other things, This Strategy “opportunistic” or “specialized” asset categories, which can include real estate, commodities, precious metals, energy and other less traditional asset classes, with no geographic restrictions. AAM will adjust the holdings in a GMS or PMP Account on an ongoing basis. In some instances, AAM will sell or readjust GMS or PMP Account holdings to take advantage of certain opportunities to reduce taxes for the Client. Additionally, AAM is permitted to use one or more Proprietary Funds within the Strategy. The Strategy for each Proprietary Fund is described in more detail in the Proprietary Funds’ prospectus. All Proprietary Funds utilized are registered investment companies for which AssetMark serves as investment adviser. Additionally, Clients should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets during the annual adjustment period, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. Such transactions can take three or more business days. AssetMark Platform Disclosure BrochureThis must remain with the Client  Page 31 of 38 Custom and Advisor - Custom Accounts The GMS or PMP Account is a Core Investment Strategy allocating across equities and fixed income. The type of fixed income used will vary depending on the risk profile selected. There are two main investment mandates that a client can choose between: • High Dividend – The account will primarily be allocated to U.S. stocks and tilted towards dividend paying securities which can include significant allocations to real estate and high dividend paying stocks. The Client, with the assistance of the Financial Advisor, can request that AAM deviate from standard allocations for the selected GMS or PMP Strategy. Such an Account is considered a Custom GMS or PMP Strategy. The Custom GMS and PMP Strategy can be customized (1) based on a tax-managed transition plan, (2) due to a request to reduce net capital gains on an ongoing basis, or (3) due to a request for other customization. • Global – The account will be allocated to U.S. and international securities (including emerging markets). With the assistance of the Client’s Financial Advisor, the Client selects a Risk/Return Profile for the GMS or PMP Account. Only Profiles numbered two (2) through six (6) that is Moderate, Moderate Growth, Growth and Maximum Growth are available. US Risk Controlled Strategy If the Client requests a tax-managed transition, AAM will take commercially reasonable efforts to limit the immediate realization of net gains related to securities transferred in-kind. Clients can also ask that certain securities not be purchased for their Custom account. Clients can request the implementation of socially responsible screens, of Global Industry Classification Standard (“GICS”) codes or social themes, or the exclusion of specific securities by CUSIP. Requests for restrictions are reviewed by AssetMark to ensure that they are reasonable and will not unduly impair AssetMark’s ability to pursue the Strategy selected by the Client. Clients can also request a Custom Account consistent with a proposal or product sheet provided by AAM for the Account. Contact your AssetMark consultant for more information. Clients who select the US Risk Controlled Strategy as their Solution Type must deposit at least $25,000 into their account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $25,000. Discretionary authority includes the authority, without first consulting with the Client to buy, sell, remove and replace securities and to determine the allocations to each investment, select broker-dealers, vote proxies, and take any and all other actions on the Client’s behalf that AAM determines is customary or appropriate for a discretionary investment adviser to perform. A Client’s Account will be held by Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $25,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. Additionally, the Client, can choose to participate in a program in which their Financial Advisor, in consultation with AAM, can request further customization for their Client’s Account (“Advisor – Custom Accounts” or “ACA”). The Financial Advisory Firm will be solely responsible for determining the additional customization and the suitability for the Client. AAM, in its discretion, will determine the implementation of the ACA. The Financial Advisory Firm will be solely responsible for determining the additional customization. The Financial Advisory Firm can request that AAM recommend to the Financial Advisory Firm asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the custom models developed by the Financial Advisory Firm may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for the GMS or PMP Accounts described below. The GMS or PMP Platform Fee schedules will be charged to the Client Account, unless otherwise negotiated between the Financial Advisory Firm and AAM. Savos Personal Portfolios In the US Risk Controlled Strategy, the Client authorizes AAM to provide discretionary investment management services to the Account. The Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and other discretionary authorities. AAM retains the right to allocate across asset classes, which will include such recommended securities, in its own discretion. AAM invests the Account in individual securities and ETFs. Clients who select the Savos Personal Portfolios must deposit at least $150,000 into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a “Discretionary Account” until the Account balance reaches the required minimum $150,000. A Client’s Account will be held by Custodian in cash or in any assets transferred in-kind until such time as the value of the deposits to the Account reaches the required $150,000 minimum for investment. AAM reserves the right, in its sole judgment, to accept certain investments below the standard minimum. The US Risk Controlled Strategy adjusts equity exposure, seeking to limit losses in extreme market declines while participating in equity market returns most of the time. AAM will adjust the holdings in the US Risk Controlled Strategy based on a proprietary indicator. AAM will sell or readjust holdings where appropriate based on the indicator. During periods of heightened market volatility, AAM will have the ability to adjust the holdings to a non-equity alternative. During periods of low market volatility, AAM will have the ability to adjust the holdings to use a leveraged investment to obtain additional market exposure. Additionally, Clients should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets during the adjustment period, and AssetMark will not be held liable for losses due to market value fluctuations during the time taken for these transactions. Such transactions can take three or more business days. In Savos Personal Portfolios, the Client authorizes AAM to provide discretionary investment management services to the Account. The Client grants AAM the authority to buy and sell securities and investments for the Account, to vote proxies for securities held by the Account and other discretionary authorities. AAM retains the right to allocate across asset classes, which will include such recommended securities, in its own discretion. AAM invests the Account in individual securities, mutual funds and ETFs. The US Risk Controlled Strategy is a defensive U.S. equity solution (Tactical Limit Loss) and is offered in a single risk profile. Profile six (6), Maximum Growth. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 32 of 38 AssetMark Custom High Net Worth Savos Personal Portfolios is a Core Investment Strategy Invested in a mix of traditional asset classes, mainly equities and fixed income, and a tactical Strategy. Savos Personal Portfolios seeks to provide total return through the combination of multiple asset classes predominantly in equity and fixed income. The tactical sleeve adjusts equity exposure, seeking to limit losses in extreme market declines while participating in equity market returns most of the time. The fixed income holdings will include a combination of ETFs and/or mutual funds selected to maximize the yield of the fixed income sleeve while managing to pre-defined risk limits. The Tax-Sensitive Strategies will offer an optional, personalized tax-managed transition in the Account and will also offer tax-loss harvesting to Clients. There are two main investment mandates a client can choose between: • Growth and Growth Tax-Sensitive - The Strategy focuses on growth whereby equity exposure is taken across U.S. and international equity market securities (including emerging markets), targeting stocks selected to maximize exposure to equity style factors such as value, momentum, and quality. The AssetMark Custom High Net Worth service is available through AAM. The minimum Account size for this Account is $500,000. AAM uses a number of the Strategies and advisory services in providing discretionary investment management services to the Custom High Net Worth Account. AAM can invest the Account in direct securities, pooled investment vehicles, such as open-end mutual funds, closed end investment companies, including ETFs, or in other securities or investments. AAM retains the right to allocate across asset classes, in its own discretion. Portions of the Account will also be managed by third-party model providers that AAM selects, retains and replaces in its discretion. For the fixed income portion of the Custom High Net Worth Account, AAM will use pooled vehicles or have a third-party Discretionary Manager manage with discretion that portion of the Client’s Account. AAM will remove, add or replace the third-party Discretionary Manager in its discretion. The Client grants AAM the authority to buy and sell securities for the Account and to vote proxies for securities held by the Account. When a third-party Discretionary Manager is used, the Client grants that third-party Discretionary Manager the authority to buy and sell securities and investments and to vote proxies for securities held in that portion of the Account it manages. • Dividend and Dividend Tax-Sensitive - The Strategy focuses on growth and income whereby equity exposure targets stocks that exhibit positive exposure to equity style factors including dividend yield. The Savos Personal Portfolios follow the Core Markets Investment Approach. Profiles numbered three (3) through six (6), are available for the Savos Personal Portfolios, and can be customized based on a tax-managed transition plan. Savos Personal Portfolios - Custom Clients in the AssetMark Custom High Net Worth service have the option to place restrictions against investments in specific securities or types of securities for their Account that are reasonable in light of the advisory services being provided. Requests for such restrictions are reviewed by AAM to ensure that they are reasonable and will not unduly impair AAM’ ability to pursue the Account’s investment objective. As may be limited by the Custodian’s policies and procedures, Clients can also pledge the securities in their Account or withdraw securities from their Account (transfer in-kind to another Account or Custodian), but must do so by giving instructions in writing to the Custodian. Savos Fixed Income Strategies For Savos Fixed Income Accounts, AAM acts as Investment Manager for Client Accounts. The available Mandates for the Savos Fixed Income Accounts are as follows: A Savos Personal Portfolio - Custom Account can be customized within a specific range across equity, fixed-income and tactical allocations. The Client, with the assistance of their Financial Advisor, can select from various Savos Strategies. In doing so, and by selecting within the range of pre-determined allocations, a Savos Personal Portfolios - Custom Account will be established. Each equity, fixed-income and tactical allocation is referred to as a “sleeve” allocation. • Laddered Bond Mandates. These Strategies invest the Account in either U.S. Treasury, U.S. Agency or U.S. Treasury Inflation Protected bonds, with an intermediate or short duration, typically on a buy and hold basis. AAM will make available the specific range of pre-determined allocations, which range will be updated from time to time. The number of sleeves selected can vary from a minimum of one to a maximum of nine sleeve selections, to comprise the entire Savos Personal Portfolios - Custom Account. There is an investment minimum of $20,000 in the equity and tactical sleeve, and $10,000 for the fixed- income sleeve. • Municipal, Duration-based and the High Income Mandates. These standard Strategies invest the Account in closed-end funds, ETFs or mutual funds to obtain relevant exposure specific to desired asset categories. The Custom Savos Personal Portfolio Strategy can be customized based on a tax-managed transition plan. The Financial Advisory Firm and the Financial Advisor will be solely responsible for determining the Risk Return profile, additional customization and the suitability for the Client Account. AAM, in its discretion, will determine the implementation of the AAM Personal Portfolio - Custom. AAM does not provide any individualized investment advice to Savos Personal Portfolios - Custom. The asset allocation classification of the custom models developed by the Financial Advisory Firm may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure. Profiles numbered one (1) through six (6), are available for the Savos Personal Portfolios Custom Account. • Advisor - Custom Accounts. The Client can choose to participate in a program in which their Financial Advisor, in consultation with AAM, can request further customization for their Client’s Account (“Advisor – Custom Accounts” or “ACA”). The Financial Advisory Firm will be solely responsible for determining the additional customization and the suitability for the Client. AAM, in its discretion, will determine the implementation of the ACA. The Financial Advisory Firm can request that AAM recommend to the Financial Advisory Firm asset allocations or investment selections for the ACA, but AAM does not provide any individualized investment advice to ACA. The asset allocation classification of the custom models developed by the Financial Advisory Firm may not be consistent with the Investment Approaches or Risk Return Profiles described in this Disclosure Brochure for the Fixed Income strategies described above, and the AAM Fixed Income Platform Fee schedule will be charged to the Client Account, unless otherwise negotiated between the Financial Advisory Firm and AAM. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 33 of 38 SAVOS DYNAMIC HEDGING FEATURE ASSETMARK GUIDED INCOME SOLUTIONSSM The Dynamic Hedging feature is offered within certain Solution Types managed by AAM. The primary investment objective of the Dynamic Hedging feature is to mitigate losses resulting from a severe and sustained decline in the broad-based equity markets. AAM will implement the Dynamic Hedging feature by investing in any number of hedging, fixed income or other protective investment vehicles. Investment Objective The goal of the Dynamic Hedging feature is to participate in the growth of equity markets while also providing risk management protection during periods of sustained and severe equity market decline. The Dynamic Hedging feature seeks to allow investors to stay invested for the long term by partially offsetting extreme declines in the equity markets while also seeking to provide positive total returns in rising markets. Risks The Guided Income Solutions are designed to provide Clients with a regular income stream from their investment Account based on the Client’s objectives and specified criteria. In this program, the Financial Advisor provides the Client criteria, such as desired income and frequency. Based on these responses, a Guided Income Solutions portfolio and portfolio risk profile, seeking to generate the targeted level of distributions, will be suggested for the Client. The Financial Advisor can accept that portfolio or amend the Client criteria based on the Client objectives, risk tolerance or other factors before making a final Guided Income Solution portfolio election. Each risk profile is linked to the portfolio’s remaining life. A portfolio that is within 10 years of its end date is deemed to be Profile 1, a portfolio that has more than 10 years but less than 20 years until its end date is deemed to be Profile 2, and a portfolio that has more than 20 years until its end date is deemed to be Profile 3. The portfolio will be broadly diversified and seeks to meet the portfolio’s stated investment time horizon; however, there is no assurance that the time horizon can be met. On an annual basis, the portfolios will be reviewed and the portfolio risk profiles will be adjusted to reflect the remaining life of the portfolio. No Guarantee; Expressed or Implied The Guided Income Solutions advisory service will primarily invest in three GuidePath Funds. GuidePath Funds do not charge a 12b-1 fee. There is no Platform Fee for the Guided Income Solutions. See Servicing Fees Received by Custodians, including AssetMark Trust Company and Share Class Use in Fees and Compensation section, and the Fees & Minimum table at the back of this Disclosure Brochure. Each GuidePath Fund is managed to a stated investment objective as outlined in the Fund prospectus. Please refer to the Fund prospectus for more information, including any fees. The phrase “risk management protection” or simply “protection” should in no way be regarded as a guarantee against losses or even the mitigation of losses. Similarly, the word “participation” should in no way imply positive gains during periods of rising equity markets. The primary goal of the Dynamic Hedging feature is to provide some degree of mitigation of losses during sustained and severe declines in the broad-based equity markets, (and participation in gains during rising markets), but this is not a guarantee. AAM may or may not be successful in achieving the investment objective in any individual calendar year. The Dynamic Hedging feature should not be expected to mitigate losses occurring over short periods of time, nor should the Dynamic Hedging feature be expected to mitigate losses occurring from market declines that are relatively small or minor. For each Guided Income Solutions portfolio, AssetMark will allocate assets across three “buckets” whereby each bucket will be invested in a specific GuidePath Fund. The allocation across the buckets shift in conjunction with changes in the remaining time horizon, long- term market conditions, or other factors as deemed appropriated by AssetMark. Limiting Circumstances for Participation in Upside Equity Market Movements For Accounts established at Custodian AssetMark Trust, the Financial Advisor can also elect to have the Client’s regular income stream adjusted for inflation. For the inflation adjusted models, on an annual basis, AssetMark will adjust the expected income distribution to reflect any increase in the U.S. rate of inflation. The inflation adjustment will begin at the beginning in the year following the Client’s participation in the Guided Income Solution Strategy. The annual adjustment will be based on AssetMark’s long-term inflation projection. Another goal of Dynamic Hedging is to allow growth in the equity portion of a Client’s Account to increase the value of the overall Account. This is the “participation” portion of Savos’ “participation and protection” objective. Clients who elect Dynamic Hedging should know that the “cost” of the protection is likely to reduce returns when equity markets are increasing in value. Clients invested in the Guided Income Solutions should understand that their regular income stream can include principal and the principal balance of the Account can be depleted prior to the portfolio’s target end-date and therefore, distributions can end earlier than expected. Income distributions refers to cash distributions of earnings and/or principal. This drag would generally result because (i) the hedging vehicles used by AAM to implement the Dynamic Hedging feature moves inversely to equity markets, and (ii) the cost of the hedging vehicles used in the Dynamic Hedging feature are more likely to increase in declining equity market conditions. As a result, the level of participation and protection of a Client’s Account will vary depending upon market environment and the specific path of market returns. Dynamic Hedging can fall while the overall equity market is rising in certain time intervals, and will fall more than the overall equity markets in certain intervals. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 34 of 38 EXHIBIT C – PROPRIETARY MUTUAL FUND SOLUTIONS - CONFLICTS OF INTEREST DISCLOSURES MUTUAL FUNDS FEES RETAINED BY ASSETMARK The Accounts of Clients who select a GPS Fund Strategy will be invested in mutual funds advised by AssetMark. This creates a conflict because AssetMark receives Management Fees and Administrative Service Fees from these mutual funds, the Management Fees retained by AssetMark can differ and AssetMark will determine the allocations of Account value among these funds. AssetMark addresses this conflict by providing additional information below regarding the maximum fees AssetMark can retain. The maximum net Management Fee retained by AssetMark from a fund in GPS Fund Strategies is 0.40% of average daily net assets, and the maximum Administrative Service Fee paid AssetMark is 0.25%. Therefore, the maximum fee that AssetMark can retain from a mutual fund in a GPS Funds Strategies account is 0.65% of average daily net assets. AssetMark is also compensated by the Platform Fee charged for the GPS Fund Strategies, which is less than that charged for strategies with third party funds and ranges from 0.25% to 0.10% (depending upon Account assets, with the first $250,000 of Account value always being charged the highest 0.25% fee). The Platform Fee for the GPS Fund Strategies does not include a charge for advisory (or management) services but pays for custodial, trading, administrative and other services. In selecting a GPS Fund Strategy, the Client agrees to the receipt by AssetMark of the maximum 0.65% Management Fee plus Administrative Fee (paid by the fund) plus the applicable Platform Fee (charged at the Account level) and that this fee is reasonable compensation to AssetMark. AssetMark’s management of a GPS Fund Strategy can result in internal fund fees to AssetMark lower than the 0.65% authorized by the Client. Listed below are the mutual funds advised by AssetMark in which AssetMark can invest GPS Fund Strategy accounts and the maximum fee that AssetMark can retain from each fund as a percentage of average daily net assets of the mutual funds. If a fund has a sub-adviser, the minimum that AssetMark can pay the sub-adviser is deducted in the amount shown as retained by AssetMark. AssetMark can waive part or all of its management fee, and AssetMark can also recoup previously waived fees and assumed expenses, but these possibilities are not considered in the below-reported maximum retained fees. Some funds invest in shares of other funds; the fees paid these underlying funds are not included in the below-reported fees. The Client should refer to the funds’ prospectuses and other shareholder materials for information, including fees, regarding the funds. Additional mutual funds can be added to those that receive allocations. If an added fund results in a fee greater than 0.65% being paid to AssetMark, the Client will be given notice. MUTUAL FUNDS MAXIMUM FEES RETAINED BY ASSETMARK GuidePath Growth Allocation Fund 0.50% GuidePath Conservative Allocation Fund 0.50% GuidePath Tactical Allocation Fund 0.60% GuidePath Absolute Return Fund 0.60% GuidePath Managed Futures Strategy Fund 0.60% GuidePath Flexible Income Allocation Fund 0.50% GuidePath Multi-Asset Income Allocation Fund 0.60% GuideMark Large Cap Core 0.60% GuideMark World ex-US Service 0.60% Since the amount that AssetMark is paid by each mutual fund varies, changes by AssetMark to the allocations of mutual funds in Client Accounts can change what AssetMark receives in fees from the funds. GPS Fund Strategies include strategies with “Accumulation of Wealth,” “Distribution of Wealth” and “Focused” investment objectives. AssetMark anticipates making periodic changes to allocations among mutual funds in the Accumulation of Wealth and Distribution of Wealth investment objectives but does not anticipate any material allocation changes for Accounts invested in the Focused investment objectives. Listed below, for each Profile in each Strategy offered in the Accumulation of Wealth and Distribution of Wealth investment objectives is the maximum retained fee and the range of retained fees that AssetMark can receive assuming the possible asset allocations that AssetMark anticipates for that Profile and objective. For the strategies in the Focused investment objectives, only the maximum possible retained fee is listed because AssetMark anticipates that a change, if any, in the allocations will not materially affect the maximum fee. If an allocation change or the addition of a new mutual fund results in a maximum retained fee for a Strategy greater than that listed below, the Client will be given notice. The Maximum Net Revenue for the GuidePath Absolute Return Fund reflects a fee waiver currently in place for the Fund. GPS FUND STRATEGIES MAX NET REVENUE RANGE OF NET REVENUE GPS ACCUMULATION OF WEALTH 1 0.59% 0.54% - 0.59% 2 0.59% 0.54% - 0.59% 3 0.58% 0.53% - 0.58% 4 0.57% 0.52% - 0.57% 5 0.58% 0.53% - 0.58% AssetMark Platform Disclosure BrochureThis must remain with the Client Page 35 of 38 GPS DISTRIBUTION OF WEALTH 2 0.61% 0.56% - 0.61% 3 0.64% 0.59% - 0.64% 4 0.64% 0.59% - 0.64% GPS FUND STRATEGIES MAX NET REVENUE GPS FUND STRATEGIES MAX NET REVENUE GPS ACCUMULATION - NO ALTERNATIVE EXPOSURE GPS FOCUSED CORE MARKETS 1 0.54% 1 0.50% 2 0.54% 2 0.49% 3 0.53% 3 0.49% 4 0.52% 4 0.49% 5 0.53% 5 0.49% GPS DISTRIBUTION, NO ALTERNATIVE EXPOSURE GPS FOCUSED LOW VOLATILITY 2 0.57% 1 0.54% 3 0.60% GPS FOCUSED TACTICAL 4 0.60% 5 0.59% GPS FOCUSED TACTICAL GPS FOCUSED MULTI-ASSET INCOME 2 0.55% 2 0.55% 3 0.56% 3 0.59% 4 0.58% 4 0.56% Mutual funds advised by AAM are available only through the AssetMark Platform and are dependent on the continued vitality of the AssetMark Platform for their commercial viability. GPS SELECT Part of Platform Fee is credited to Account AAM serves as investment manager for GPS Select and will allocate account value across investment Strategies, and among Strategists and investment managers within those investment Strategies. Included within these investment options are strategies managed by AAM and the investment options include allocations to mutual funds advised by AAM. AssetMark pays fees to various strategists and investment managers that it allocates account value to but does not pay such fees to third parties when it allocates account value to Strategies it manages. Further, AssetMark receives compensation from mutual funds they advise. For GPS Select, the Platform Fee is 0.95%. In selecting GPS Select, the Client agrees to the receipt by AssetMark of this 0.95% fee and that this fee is reasonable compensation to AssetMark. However, an amount of 0.30% is credited back to the Account, resulting in a net Platform Fee of 0.65% for assets invested in GPS Select. The purpose of the 0.30% credit is to ensure that, regardless of the allocation decisions made by AAM, the Client will receive a Platform Fee credit that is at least as much as any additional compensation AssetMark might retain due to the allocations that AssetMark is permitted to make pursuant to the GPS Select investment guidelines. MARKET BLEND MUTUAL FUND STRATEGIES Mutual Fund Fees retained by AssetMark The Accounts of Clients who select a GuideMark Market Blend Mutual Fund Strategy will be invested in Proprietary Funds advised by AssetMark. AssetMark will receive Management Fees and Administrative Service Fees from these funds, the Management Fees retained by AssetMark can differ and AssetMark will determine the allocations of Account value among these funds. AssetMark addresses this conflict by providing additional information below regarding the maximum fees AssetMark can retain. The maximum net Management Fee retained by AssetMark from a fund in a GuideMark Market Blend Mutual Fund Strategy is 0.45% of average daily net assets, and the maximum Administrative Service Fee paid to AssetMark is 0.25%. Therefore, the maximum fee that AssetMark can receive from a mutual fund in a GuideMark Market Blend Mutual Fund Strategy is 0.70% of average daily net assets. AssetMark is also compensated by the Platform Fee charged for the GPS Fund Strategies, which is less than that charged for strategies with third party funds and ranges from 0.25% to 0.10% (depending upon Account assets, with the first $250,000 of Account value always being charged the highest 0.25% fee). The Platform Fee for the GPS Fund Strategies does not include a charge for advisory (or management) services but pays for custodial, trading, administrative and other services. AssetMark Platform Disclosure BrochureThis must remain with the Client Page 36 of 38 In selecting a GuideMark Market Blend Mutual Fund Strategy, the Client agrees to the receipt by AssetMark of the maximum 0.70% Management Fee plus Administrative Fee (paid by the fund) plus the applicable Platform Fee (charged at the account level) and that this fee is reasonable compensation to AssetMark. AAM’s management of a GuideMark Market Blend Mutual Fund Strategy can result in internal fund fees to AssetMark lower than the 0.70% authorized by the Client. Listed below are the Proprietary Funds in which AssetMark is permitted to invest GuideMark Market Blend Mutual Fund accounts and the maximum fee that AssetMark can retain from each fund as a percentage of average daily net assets of the mutual funds. If a fund has a sub-adviser, the minimum that AssetMark can pay the sub-adviser is deducted in the amount shown as retained by AssetMark. AssetMark can waive part or all of its management fee, and AssetMark can also recoup previously waived fees and assumed expenses, but these possibilities are not considered in the below-reported maximum retained fees. The Client should refer to the funds’ prospectuses and other shareholder materials for information, including fees, regarding the Funds. Mutual funds can be added to those that receive allocations. If an added fund results in a fee greater than 0.70% being paid to AssetMark, the Client will be given notice. MUTUAL FUNDS MAXIMUM FEES RETAINED BY ASSETMARK GuideMark Large Cap Core 0.60% GuideMark Small/Mid Cap Core 0.70% GuideMark Core Fixed Income 0.60% GuideMark Emerging Markets 0.61% GuideMark World ex-US Service 0.60% Since the amount that AssetMark is paid by each Proprietary Fund, changes by AssetMark to the allocations of Proprietary Funds in Client Accounts can change what AssetMark receives in fees from the funds. Listed below, for each Profile in each Strategy offered in Market Blend Mutual Fund Strategies, is the maximum retained fee that AssetMark can receive, assuming the possible asset allocations that AssetMark anticipates for that Profile and objective. If an allocation change or the addition of a new Proprietary Fund results in a maximum retained fee for a Strategy greater than that listed below, the Client will be given notice. MARKET BLEND STRATEGIES MAX NET REVENUE GLOBAL GUIDEMARK MARKET BLEND 2 0.59% 3 0.60% 5 0.60% 6 0.61% US GUIDEMARK MARKET BLEND 2 0.60% 3 0.61% 5 0.61% 6 0.62% Additionally, if AssetMark Trust is chosen as Custodian, AssetMark Trust will be paid Shareholder Service Fees. The third-party Platform Custodians (Custodians other than AssetMark Trust) also receive service fee payments from the mutual funds in the Market Blend Mutual Fund Strategies. GUIDED INCOME SOLUTIONS The Accounts of Clients who select a Guided Income Solution will be invested in the following Proprietary Funds. MUTUAL FUNDS MANAGEMENT FEE BY ASSETMARK GuidePath Conservative Income Fund 0.35% GuidePath Income Fund 0.45% GuidePath Growth and Income Fund 0.45% AssetMark will receive Management Fees and a 0.25% Administrative Service Fee from these mutual funds. There is no Platform Fee for the Guided Income Solutions. 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K 5 2 $ 3 e m o c n I d e x i F e v i t c A s o v a S , i , t h g i r W s r o s i v d A d n E t s e W l , 8 e m o c n I d e x i F d e r e d d a L y e s r o D S M G s o v a S , x e l u J t n o m u a e B a t n e m e p p u S s o i l o f t r o P d e d i u G e m o c n I d e d i u G s n o i t u l o S % 0 % 0 % 0 % 0 % 0 % 0 % 0 0 0 0 , 0 5 $ — s m u m n M l a t i p a C k r a l C 2 F M F M l e e F % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 % 5 1 . 0 % 5 1 . 0 % 5 1 . 0 % 5 1 . 0 0 0 0 , 5 2 $ y r a t e i r p o r P 5 3 e m o c n I d e x i F n e e v u N % 5 3 % 0 3 % 8 2 % 5 2 % 0 2 % 0 1 r e g a n a M , i n u M e t a i d e m r e t n , F T E y t r a P - d r i h T a n o i t u t i t s n I % 0 1 . 0 % 5 1 . 0 % 0 2 . 0 % 5 2 . 0 % 0 5 . 0 % 0 6 . 0 , F T E y t r a P - d r i h T l a n o i t u t i t s n I % 0 5 . 0 . 0 . 0 . 0 . 0 . 0 . 0 0 0 0 , 5 2 $ l I d e r e d d a L , , p u o r G l l a t i . s t n e i l , ) e e r F - x a T d n a x a T s t n u o c c A d e g a n a M y l l a u d i v i d n I y t r a P - d r i h T 3 e m o c n I d e x i F % 7 2 . 0 % 7 2 . 0 % 7 2 . 0 % 2 2 . 0 % 2 2 . 0 % 2 2 . 0 % 2 2 . 0 K 0 5 2 $ - K 5 2 1 $ a t n e m e p p u S p a C ( c F T E y r a t e i r p o r P F M % 5 0 . 0 % 5 1 . 0 % 5 4 . 0 F T E y r a t e i r p o r P 5 F M % 0 4 . 0 % 5 3 . 0 % 0 3 . 0 % 0 2 . 0 % 0 2 . 0 % 0 2 . 0 0 0 0 , 5 2 $ i , e m o c n I y r o s v d a n a g r o M P J s A M S % 0 7 . 0 % 0 7 . 0 % 7 6 . 0 % 4 6 . 0 % 0 6 . 0 % 5 5 . 0 % 0 5 . 0 K 0 0 1 $ - K 0 5 $ s A M S % 5 0 . 0 % 0 1 . 0 h t i d e x i F , t n e m t s e v n I ) s A M S ( G S E 6 1 k r a M e d i u G % 5 2 . 0 % 5 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 % 0 1 . 0 0 0 0 , 0 1 $ , 2 r e d l i , s t l A c i t s i n u t r o p p O w e s u , I n w o r B , F T E ( l r e g r e b u e N , A M d e t a r e d e F c i t a m e h T k c E n a V k c E n a V i n a g o L 2 s e u l a V , k c o R k c a l B r o s v d a , p u o r G l e e F e e F ( k c o R k c a l B n o t e p m e T n i l k n a r F l l i t e e r t S e t a t S u B t e s s A k r a M t e s s A l a t i p a C t h g i r , a r e i F W i s r o s i v d A d n E t s e W l l i i , s e v i t a n r e t l A t s u r T t s r i F , e n i L e l b u o D a c n a n fi i i l , ) n o i t a c o l l , n i e t s n r e B e c n a i l l a t n e m e p p u S A , y r o s i v d A , s e m r e H , n a g r o M P J , d r o f t r a H , e g d E l a p i c n i r P , n a m r e B l a p i c n i r P , n a i d a c A l a n o s r e P k r a M t e s s A K 0 5 2 $ < K 0 0 5 $ - K 0 5 2 $ M 1 $ - K 0 0 5 $ M 2 $ - M 1 $ M 3 $ - M 2 $ M 5 $ - M 3 $ + M 5 $ m u m n M s e i g e t a r t S K 0 5 2 $ < a t n e m e p p u S s t n u o c c A d e g a n a M y l e t a r a p e S , x e l p m S a h p A , ) I F R r a t s g n i n r o M , e l b i x e l F l a b o l G A , s e m e h T p o T t s u r T t s r i F , n o i t p u r s i D r e i t n o r F w e N y e s r o D , x e l u J t n o m u a e B K 0 0 5 $ - K 0 5 2 $ M 1 $ - K 0 0 5 $ M 2 $ - M 1 $ M 3 $ - M 2 $ M 5 $ - M 3 $ + M 5 $ m u m n M 4 2 0 2 R E B M E C E D F O S A r o F & s e e F AssetMark Platform Disclosure BrochureThis must remain with the Client  Page 38 of 38 . l f o O C M I P 9 s d n u F e n o t S l , . c n d e c n a h n E I e t a i l , e t i r i a u d v d n e n i L e l b u o D r e l l i h S , E P A C r e g r e b u e N n a m r e B W t u P S D N E R T d e g a n a M , s e r u t u F d e fi i s r e v i D e g d i R s e v i t a n r e t l A I a u t u M i l i f f a n a , , k r a M t e s s A I f o d n a A R N F p u o r G F T E k r a l C , e m o c n I , e m o c n I e v e e s h c a e o t n o i t a c o e v i l l i d e x i i 3 e m o c n l a t i p a C e t a i d e m r e t n I , i n u M l a t i p a C e l b a x a T e e r F - x a T d e x i F , n e e v u N e v i t c A s o v a S d e x i F s o v a S s r e d d a L i t c A F I r e b m e m n o s v d a , e r u s o l c s i D e h t o t C L L 5 , 3 e m o c n y r a t e I r e f e r , t n e m e g a n a M i . s d n u f i l d n o B s o v a S s r e d d a L i r p o r P d e r e d d a L d e x F . s e c n a t s n i — s t n u o c c A d e g a n a M y l l l e m o s n i , s n o i t u o s 3 e m o c n 8 e m o c n I I l l t e s s A k r a M t e s s A , M T e g a r e k o r B k r a M t e s s A y b a u d i v i d n i c i r t e m a r a P y t r a P - d r i h T d e r e d d a L d e x i F I d e x i F a u t u m y r a t e i r p o r p i l . s e s s a c e r a h s i l i i t n e m t s e v n e e F m r o f t a P e h t i d e t u b i r t s d m a i l l i , e g d E a r e i F i W n i l k n a r F , p u o r G e r a i . e d a r t l e r u s o s ’ k r a M t e s s A e s u , n i e t s n r e B e c n a i l l r e p ) s A M S , n a i d a c A A , k c o R k c a l B , y r o s i v d A n w o r B l a t i p a C d e t a r e d e F , s e m r e H , l a t i p a C , n o t e l p m e T , d r o f t r a H , n a g r o M P J , n a g o L , r a t s g n i n r o M r e g r e b u e N , n a m r e B , l a p i c n i r P l a p i c n i r P , k c E n a V r i a l B y l e t a r a p e S d e g a n a M s t n u o c c A ( . s e n a p m o c i l c s i t a h t 0 2 $ y d e t a . s r o s v d a l l i s u o i r a v e h t . n o s s m m o C e g n a h c x E d n a i i i s e v a w k r a M t e s s A i l m a i l l i d / o f n i / r o f i l i f f a n u a t e r d n a e r a h s A g n d u c n a c p y t W i n a t r e c s e g e t a r t s , , h t r o W d n a e r a n o s d n u F ® h t a P e d u G d n a m o c . s e i t i r u c e S y l l a u d i v i d n l k r a M t e s s A h g i H m o t s u C t e N l a t i p a C k r a l C d e z i l a n o s r e P A M U r i a l B m o t s u C I d e g a n a M 8 s t n u o c c A . l o t e b a . s e e f l i i l a v a e t a r a p e s l , y r u s a e r T % 0 0 1 S U e h t n i i l i r o f e r a h t i s o ® k r a M e d u G i l e m o c n I e r a . n r u t e R i i i s t s i g e t a r t s l l ) . s t n u o c c A y g e t a r t S e p i t l u M d n a s e r u s o c s d t s e r e t n A k r a l C s u l p ( d e x i F l a t o T s o v a S d n a A M U ) s e i g e t a r t s s e i g e t a r t S e h t e l b a t e l b a l i a v a S P G m o t s u C t c e l e S S P G m o t s u C t c e l e S d e d u G o f t r o P i i f o s d n u F ) e e F n o i t c a s n a r T o N s t s g e t a r t s s e s n e p x e d n a , s e e f . s e g e t a r t s n a g r o M P J d n a e s e h T . t n u o c c a e h t w d e r e t s g e r , s d n u F s t c o t ( F T N i l d e x i F , i d n u F - T i l f n o c , d r a d n a t S r e s v d a e b a c . d e v r e s e r d n E t s e W s e d o m S B O k r a M t e s s A O C M I P , , t h g i r i l y t r a p - d r i h t w e N t n e m t s e v n i i W , t n o m u a e B k r a m t e s s a w w w o t o g e s a e l , x e l p m S a h p l A c i t s i n u t r o p p O - i t l u M A T , p p a i 2 F M d n a l a b o l G p , I s t h g i r l n a c i r e m A n o , k c E n a V , s m u m n m e b l l n o t g n i s n e K l t n a t r o p m , n r u t e R e t u l o s b A f o d e s i r p m o c , ) s t l A / A y e s r o D i , w , ) n o i t a c o l l y t n e m t s e v n 6 2 0 2 / 1 1 P X E G S E n e e v u N i i | y a m r o f . c n I i y r a t e i r p o r p n a G S E A T , I F R k r a M t e s s A y b C l i r a m , x e l u J , ) I s . s t n e d e v a w s i k r a M t e s s A l i i i l a n o i t u t i t s n 4 2 0 2 s ’ m , s e e f F, T E y t r a P - d r i h T I / G S E , F T E , e v i s s a P / e v i t c A i c , s d n u F n a c i r e m A A M ( k c o R k c a l B , s t l A r e g a n a M R T I F k r a l C t s u r T t s r i F , e n i L e l b u o D w o L t s u r T t s r i F , s e v i t a n r e t l A t s r i F , e m o c n I d e x i F n o i t a r u D t s r i F , e r o C k s i R c i g e t a r t S t s u r T t s u r T t s r i F , s e m e h T p o T t s u r T r e f f u B y t i u q E S U d e r e d d a L t s e V , n o t e l p m e T n i l k n a r F , l e d o M F T E ( n a g r o M P J , e l b i x e l F l a b o l G A M r a t s g n i n r o M , e m o c n I d e g a n a M ( A e m o c n I , r e i t n o r F , t e e r t S e t a t S s r o s i v d A k c o R k c a B g n d u c n i r i f . c n . c n 1 1 e e f I I , . s d n u f l i r p e r a | l l i , t n e m u c o d s i e h t . s d n u F ® k r a M e d u G e h t y a w a . t i b h x E o t e b a t n u o c c A d e g a n a M y i . r o s i v d a l a i c n a n fi r u o y t c a t n o c e s a e l p s h T i h t l i l l ( o t t e k r a M d e t c e e s d n u f , a v a l y r o s v d a i i r e f e R i 0 5 3 $ s e d u c n . k r a M t e s s A y b d e r e f f o e s o h t o t , k r a M t e s s A i , k r a M t e s s A , k r a M t e s s A 4 2 0 2 © 1 9 9 2 1 7 8 6 f o n o e r a : i a e h t n o d e s a b d e t h g e w d n a d e t c e e s t s g e t a r t s h c a e r o f e u d e h c s e e f y g e t a r t s - e g n s e v o b a e h t n o d e s a b e r a t n u o c c a A S M n a r o f d e g r a h c s e e f e h T e m o c n I l a n o s r e P h t i k r a M t e s s A a u d v d n r e s v d a s o i l o f t r o P I : ) i k r a M t e s s A l k r a M t e s s A r e f e r 5 F M F, T E y r a t e F T E i l e d a r t g n d u c n i s r e v i s d n u F i A S M ( l w e s u s e g e t a r t s e s e h t n h t i s e p y t , 2 r e d l i u B t e s s A k r a M t e s s A i r p o r P d n e l B M S r e d l i u B h t l a e W k r a M t e s s A , r e d l i u B s n o i s n e m D t e k r a M , s o i l o f t r o P , s o i l o f t r o P S F E / A F D S B O k r a M t e s s A , 2 s e u l a V 5 4 4 2 t e k r a m y e n o m - l i = e m o c n I t n e m t s e v n t n u o c c a t u o b a n o i t a m r o f n i i : s n o i t u o S d n u F a u t u M l l t n e r r u c l i e h t a u t u m ® k r a M e d u G s n a t n o c . c n r o s v d a d e x F I , y p o c a e v i e c e r o T s n o i t u o s i l i i r o p e e w s i i i 0 2 5 4 9 A C l e e F m r o f t a P m u m n M w d e s u s d n u F i a u d v d n I l l l ® k r a M e d i u G y g e t a r t s l i e t e l p m o c t s o m e h t i a c n a n fi i d n a m o t s u C k r a M t e s s A y r a t e i r p o r P a d o t s u C r e h t O , k r a M t e s s A t e e r t S t n a r G 5 5 6 1 r o o F h t 0 1 , d r o c n o C 5 4 3 5 - 4 6 6 - 0 0 8 a u n n A a u t u M s h T s d n u F ® k r a M e d i u G , 7 d n e l B t e k r a M , 7 d n e l B t e k r a M s e i g e t a r t S 6 , 1 k r a M e d u G , 7 r e i t n o r F w e N ® k r a M e d i u G S U l a u d i v i d n I , s d n u F ® h t a P e d i u G l a b o l G Y R O G E T A C Y B S M R I F T N E M T S E V N . 8 . 9 t n u o c c A y g e t a r t S e p i t l u M a u t u M y r a t e i r p o r P I r o F . e r u h c o r B r o F . 1 . 2 , s e e f d e s a b - n o i t c a s n a r T . 3 . 4 . 5 . 6 r o F . 7 AssetMark Platform Disclosure BrochureThis must remain with the Client 

EFFECTIVE MARCH 26, 2025 AssetMark Disclosure Brochure Form ADV – Part 2A SEC File Number − 801 56323 IA Firm CRD Number - 109018 ITEM 1 – COVER PAGE This AssetMark Disclosure Brochure provides information about the qualifications and business practices of AssetMark (“AssetMark”). If you have any questions about the contents of this Brochure, please contact AssetMark using the above information. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. AssetMark is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. AssetMark, Inc. Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 800-664-5345 assetmark.com Additional information about AssetMark also is available on the SEC’s website at www.adviserinfo.sec.gov. R210_AssetMarkADVPart2A_2025_03  Form ADV–Part 2A Disclosure Brochure Page ii ITEM 2 – MATERIAL CHANGES This section provides a summary of material changes that were made to this brochure since the last update. It includes changes to AssetMark’s Platform and is intended to help Clients determine if they want to review this brochure in its entirety, or contact their Financial Advisor with questions about the changes. AssetMark may make interim updates to this brochure throughout the year. However, you will receive notice of any material changes, which must also be filed with the SEC. To request a copy of the most recent disclosure brochure, write to: AssetMark, Inc. Attention: Adviser Compliance 1655 Grant Street, 10th Floor Concord, CA 94520 800-664-5345 assetmark.com advisorcompliance@assetmark.com There have been no material changes since the last Form ADV Part 2A Appendix 1 update in September 2024. This must remain with the Client  Page 1 of 15 ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i ITEM 2 – MATERIAL CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii ITEM 3 – TABLE OF CONTENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ITEM 4 – ADVISORY BUSINESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 ITEM 5 – FEES AND COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 7 – TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 9 – DISCIPLINARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 11 – CODE OF ETHICS AND PERSONAL TRADING; PARTICIPATION IN CLIENT TRANSACTIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . 9 ITEM 12 – BROKERAGE PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 ITEM 13 – REVIEW OF ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 ITEM 15 – CUSTODY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 ITEM 16 – INVESTMENT DISCRETION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 ITEM 17 – VOTING CLIENT SECURITIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 ITEM 18 – FINANCIAL INFORMATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 APPENDIX 1 INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 2 of 15 ITEM 4 – ADVISORY BUSINESS ASSETMARK AND ITS OWNERSHIP STRUCTURE as the Discretionary Manager; for others, a third-party manager serves as Discretionary Manager and AssetMark has no role in trading for the IMA. AssetMark is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since 1999 providing various investment advisory and consulting services to other advisors and investment Clients. AssetMark and AssetMark Trust Company (“AssetMark Trust”) are wholly owned subsidiaries of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc is an independent, U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. AssetMark is the sponsor of the AssetMark Platform (the “Platform”) through which it offers its advisory services to its clients. AssetMark Wealth Solutions includes AssetMark Asset Management (“AAM”), Due Diligence, Investment Consulting, and other portfolio, wealth, and practice solutions. AAM is responsible for AssetMark‘s proprietary investment strategies. AssetMark serves as the investment adviser for the following registered investment companies that are available in certain Solution Types under the Platform: 1) GuideMark Funds (no-load sub-advised mutual funds) 2) GuidePath Funds (no-load funds of funds and a sub-advised managed • Individual Mutual Fund (“IMF”) – Client accounts are allocated to a single mutual fund and is intended to complement other Solution Types available on the AssetMark Platform, as part of the Client’s overall Portfolio. The IMF’s used in this advisory service can be Proprietary or third-party funds. Each IMF is not available at all Custodians. Clients should be aware that the Platform Fees charged by AssetMark for this service can be higher or lower than those charged by others in the industry or directly from the third-party mutual fund provider, and that it can be possible to obtain the same or similar services from other investment advisers at lower or higher rates. AssetMark may waive the Platform Fee in its discretion. A Prospectus for any individual mutual fund made available under this Solution Type can be obtained upon request from AssetMark or the Client’s Financial Advisor. Clients should review fund prospectuses and consult with their Financial Advisor if they have questions regarding these IMF Solution Types. The mutual funds shares selected for use can be institutional or retail shares, and can include administrative service fees, sub-transfer agency fees and/or 12b-1 fees, that are fees borne by Clients. See Servicing Fees Received by Custodians, including AssetMark Trust and Share Class Use for a discussion of 12b-1 fees, administrative service fees and sub-transfer agency fees and the Fees & Investment Minimums table at the back of this Disclosure Brochure for the Platform Fees charged IMFs. futures mutual fund) Any Solution Type can be implemented with a number of options, including a range of Risk/Return Profiles (the “Risk/Return Profiles”) and investment approaches (the “Investment Approaches”), each described above, so that the Client can customize a strategy by which each of the Client’s Accounts under the Platform will be managed or maintained. The specific Solutions and the components of the strategy selected for the Client’s Account are referred to as the Client’s investment “Strategy.” AssetMark is not registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor, based on its determination that it may rely on certain exemptions from registration provided by the Commodity Exchange Act and the rules thereunder. The CFTC has not passed upon the availability of these exemptions to AssetMark. Additionally, solely with respect to the GuidePath Managed Futures Strategy Fund, AssetMark is registered as a “commodity pool operator” under the Commodity Exchange Act (“CEA”) and the rules of the CFTC. The Client’s Strategy can be implemented with a number of features and alternatives, such as: DESCRIPTION OF ADVISORY SERVICES • a range of Risk/Return Profiles; AssetMark offers various Platform options (“Solution Types”) for the Client’s investment objectives and financial condition. • selection of one or more Investment Strategies • a group of available Portfolio Strategists or Investment Managers; SOLUTION TYPES and AssetMark makes available three general “Solution Types” (or “Solutions”) on the Platform. • various individually managed accounts (“IMA”), so that the Client, as advised by the Financial Advisor, can create a Strategy by which each of the Client’s Accounts under the Platform will be managed or maintained. Some Solution Types are available through third-party Investment Management Firms unaffiliated with AssetMark. Other Solution Types are proprietary Strategies available through AAM. AssetMark makes available fact sheets and other information to assist the Financial Advisor in making an informed decision. • Model Portfolios – Client Accounts are allocated among securities and other investment vehicles on a non-discretionary basis pursuant to Model Portfolios provided by “Portfolio Strategists” (also referred to as “Model Providers”). Model Portfolios include mutual fund and ETF investment strategies and Separately Managed Accounts (“SMA”). SMA Model Portfolios are allocated among securities and other investment vehicles in accordance with the model and are typically selected for a specific asset class. AssetMark will serve as the Overlay Manager (described below) with regard to SMA accounts. • Individually Managed Accounts (“IMA”) – the Client Account is managed, and individual Client Account trades are implemented on a discretionary basis by a “Discretionary Manager” (also referred to as an “Investment Manager”). For some IMAs, AssetMark serves AAM acts as Portfolio Strategist providing Model Portfolios through a number of Solutions. It is also among the Discretionary Managers offered on the Platform. With respect to those Strategies in which AssetMark acts as a Discretionary Manager, its obligations are accordingly those of a Discretionary Manager and include the selection of securities for the Account (consistent with the Strategy (described below) selected by the Financial Advisor and Client) and trade execution. Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 3 of 15 INVESTMENT SUPERVISORY SERVICES – REFERRAL PLATFORM in pre-determined allocations to various AssetMark provides investment supervisory services to clients which are described in more detail in the wrap-program Referral Disclosure Brochure as Appendix 1 Form ADV Part 2A as AssetMark’s “Referral Disclosure Brochure.” AssetMark serves as the Portfolio Strategist and Investment Manager for the Guided Portfolios, which includes the GPS Fund Strategies and GPS Select. GPS Fund Strategies shall invest in pre- determined allocations of the GuidePath Funds. GPS Select will invest Investment Approaches as well as additional investment options within each Investment Approach and will make allocations to various Portfolio Strategists and Investment Managers. Through AAM, AssetMark offers the following advisory services or Solution Types to Clients. the AssetMark AssetMark receives client referrals through representatives of broker dealer firms and investment advisory firms (these firms are referred to as “Financial Advisory Firms”). AssetMark manages each Client Account according to the Client’s selected Solution Types under the terms of Investment Management Services Agreement (“IMSA”). Guided Portfolios • GPS Fund Strategies • GPS Select As of 12/31/2024, AssetMark had $77.4 billion in assets under management in the Referral model platform. This includes assets held in proprietary mutual funds. Mutual Fund Solution Types • Market Blend (GuideMark Funds) INVESTMENT SUPERVISORY SERVICES – MUTUAL FUNDS • OBS/DFA • AssetMark Asset Builder In addition to providing the foregoing investment supervisory services, AssetMark is also the investment adviser for: • AssetMark Personal Values 1) GuideMark Funds (no-load sub-advised mutual funds) • AssetMark Income Builder 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund) Exchange-Traded Fund (“ETF”) Solution Types • MarketBlend Mutual Fund/ETF Blend Solution Types • WealthBuilder AssetMark charges the following Advisory Fees for the funds described above, which include fees paid by AssetMark to the respective Subadvisors(s) for each Funds. • MarketDimensions GuideMark Funds GuideMark Large Cap Core Fund 0.45% Savos Solution Types • IMA Accounts, (Equity Balanced, GuideMark Emerging Markets Fund 0.59% GuideMark Small/Mid Cap Core Fund 0.57% Fixed-Income, and Custom High-Net Worth) • Savos Preservation Strategy GuideMark World ex.-US Fund 0.50% • Savos GMS Accounts GuideMark Core Fixed Income Fund 0.40% • Savos PMP Accounts • Savos US Risk Controlled Strategy, and GuidePath Funds GuidePath Growth Allocation Fund 0.25% • Savos Personal Portfolios GuidePath Conservative Allocation Fund 0.25% GuidePath Tactical Allocation Fund 0.35% Guided Income Solutions GuidePath Absolute Return Allocation Fund 0.35% GuidePath Multi-Asset Income Allocation Fund 0.35% GuidePath Flexible Income Allocation Fund 0.25% GuidePath Managed Futures Strategy Fund 1.05% Administrative/Non-Managed Account. An Administrative/Non-Managed Account can also be provided as an administrative convenience for the Client. Assets in an Administrative/Non-Managed Account are not managed or advised by AssetMark, and AssetMark is not responsible for their investment or management. GuidePath Conservative Income Fund 0.35% GuidePath Income Fund 0.45% GuidePath Growth and Income Fund 0.45% Solutions No Longer Offered. AssetMark manages other solution types which are no longer offered to new clients. These solutions continue to be managed in accordance with the respective client agreement. Clients with these services may contact AssetMark for more information. Further information about the GuideMark Funds and the GuidePath Funds, can be obtained by requesting a Prospectus from AssetMark. As of 12/31/2024, AssetMark had $2.6 billion in mutual fund assets under management. Detailed information about AssetMark and the services and products it provides to clients are set forth in the specific Disclosure Brochures for each of its services. Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 4 of 15 OTHER SERVICES – ADVISOR PLATFORM OTHER SERVICES – TAX MANAGEMENT SERVICES In addition to the investment supervisory services offered clients directly by AssetMark upon referral by Financial Advisory Firms, the Solution Types are offered by Financial Advisory Firms serving as the investment advisor for their clients with accounts invested through the Platform. For these Financial Advisory Firms and their clients, AssetMark serves as the Platform sponsor and provides the Financial Advisory Firms with administrative and consulting services. These services are described in more detail in the wrap-program Platform Disclosure Brochure as Appendix 1 of Form ADV Part 2A as AssetMark’s “Platform Disclosure Brochure.” As of 12/31/2024, AssetMark had $68.4 billion in assets under administration on the Advisor Model Platform. This includes assets invested in proprietary mutual funds. The Tax Management Services (“TMS”) is designed to improve the after-tax return for the Client’s Account. The application of TMS can cause the account to stray from the Strategy and Risk/Return Profile selected for the Account. AssetMark does not provide tax planning, accounting, or legal advice or services. The TMS Services fee is ten basis points (0.10%) with a $100 minimum annual fee per account . TMS fees can be negotiable. Accounts enrolled in TMS can trade at different times than other accounts on the AssetMark Platform invested in than same strategy and can hold higher cash allocations due to minimum trade size, rounding and other factors. TMS accounts will not be automatically rebalanced if the cash allocation exceeds a 2% threshold. The cash allocations will be invested in the cash “sweep” vehicle at the client’s selected Custodian, which for AssetMark Trust Company is usually its Insured Cash Deposit (“ICD”) Program. OTHER SERVICES - ASSETMARK RETIREMENT SERVICES OTHER SERVICES – EFFICIENT EDGE Through its Retirement Services, AssetMark offers Model Portfolios to retirement plan custodial platforms such as Mid-Atlantic Trust Company, Matrix Trust Company and National Financial Services (Fidelity Investments) and delivers and utilizes the AssetMark strategies (“Models Portfolios”). These Model Portfolios are accessed by retirement plans through Third Party Administrators (“TPAs”). A description of these services is outlined in more detail in the Disclosure Brochure Form ADV Part 2A, as AssetMark Retirement Services Disclosure Brochure. As of 12/31/2024, the AssetMark Retirement Services had $1.6 billion in assets. The Efficient Edge Advisory Service is offered by AssetMark exclusively to owners of variable annuity and variable life insurance contracts (“Variable Contracts”) issued by Genworth Life and Annuity Insurance Company (“GLAIC”) and Genworth Life Insurance Company of New York (“GLICNY”), both former affiliates of AssetMark. The Efficient Edge Advisory Service is an asset allocation service through which owners of Variable Contracts have the value in their Variable Contract sub-accounts allocated pursuant to the investment objective, or “Model,” they select. There is no separate, additional charge to Variable Contract owners for the Efficient Edge service. A description of these services is outlined in more detail in the Disclosure Brochures attached to Appendix 1 of this Form ADV Part 2A, as AssetMark’s “Efficient Edge Disclosure Brochure” and “Efficient Edge RetireReady Disclosure Brochure.” OTHER SERVICES – RESEARCH AND MODEL PORTFOLIOS AssetMark does not charge separate fees for its services under the Efficient Edge program, but Variable Contract owners do pay charges and fees in connection with their ownership of the Variable Contracts and these fees may increase in connection with use of the Efficient Edge Advisory Service. For example, transfer fees may apply on re- allocations of value among sub-accounts of the Variable Contract. AssetMark offers the Research and Model Portfolios through affiliated or third party platforms for investment advisors, banks, and other providers. AssetMark provides asset allocation, economic and market updates, investment strategy support materials and investment portfolio support or may be licensed to provide investment models to other platforms. As of 12/31/2024, the Efficient Edge advisory service had $543.7 million in assets. As of 12/31/2024, the Model Portfolios advisor service had $578.2 million in assets. OTHER SERVICES – BANK AND TRUST COMPANIES OTHER SERVICES – INVESTMENT CONSULTING The AssetMark Platform for Banks and Trust Companies offers certain “Investment Solutions” and “Tools” that enable banks and trust companies to provide investment advisory and related services to their trust and other clients. A description of these services is outlined in more detail in the Disclosure Brochure attached to Appendix 1 of this Form ADV Part 2A, as AssetMark ‘s “Bank and Trust Company Platform Disclosure Brochure.” As of 12/31/2024, The Bank and Trust Company service had $55 million in assets. ITEM 5 – FEES AND COMPENSATION All fees are subject to negotiation. Please refer to each Disclosure Brochure for complete details on the fees for each service. A Financial Advisory Firm or Financial Advisor can request that AssetMark consult on the creation of practice-based models that include Platform Solutions to meet specific goals and/or objectives sought by the Financial Advisory Firm or Financial Advisor. These models can include proprietary and/or third-party Solutions. The Financial Advisory Firm and Financial Advisor will continue to be responsible for determining the final combination of Solutions used in their practice-based models and the suitability of these Solutions for their Client(s). AssetMark does not provide individualized investment advice to Clients or to the Financial Advisor for individual client accounts. There is typically no fee for this service, but the Financial Advisor is expected to make an asset commitment to the Platform, which creates a conflict of interest for the Financial Advisor. The inclusion of a proprietary Solution creates a conflict of interest for AssetMark if selected by the Financial Advisory Firm and Financial Advisor because AssetMark receives fees for the management of proprietary Solutions. Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 5 of 15 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Side-by-side management refers to managing accounts that pay performance fees (fees based on a share of capital gains on or capital appreciation of Account assets) while at the same time managing accounts that do not pay performance fees. AssetMark does not charge performance-based fees. ITEM 7 – TYPES OF CLIENTS would retain as compensation from the payment received by the banks that participated in the FDIC-Insured Cash Deposit Program (“ICD Program”) (the “ICD Program Fee”), which, in turn, determined the amount that would be distributed as interest by the banks to clients. The SEC alleged that AssetMark had failed to fully disclose the associated conflicts of interest related to its role in setting the ICD Program Fee. The SEC also alleged that AssetMark, from at least January 2016 through August 2019, did not fully disclose the associated conflicts of interest related to AssetMark’s receipt of custodial support payments funded through payments from certain no-transaction fee (“NTF”) mutual funds. The SEC alleged that these failures constituted breaches of AssetMark’s fiduciary duty to advisory clients. The SEC alleged that AssetMark violated Section 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 promulgated thereunder. AssetMark consented to the Order without admitting or denying the SEC’s findings. AssetMark provides various investment supervisory services to a variety of Clients, including but not limited to individuals, high net worth individuals, retirement plans, corporations, partnerships, trusts, insurance companies, charitable organizations and banks. CONDITIONS OF MANAGING ACCOUNTS AssetMark imposes a minimum dollar value of assets as a condition to a number of the Solution Types available on the Platform. See the Disclosure Brochures for the minimum account sizes for specific Solution Types. Account minimums are reviewed periodically and are subject to change. Exceptions to the minimum initial investment must be approved by an authorized officer of AssetMark. An account whose value falls below the minimum can be closed by AssetMark upon written notice to the client. On August 25, 2016, the SEC announced a settlement with AssetMark in an order containing findings, which AssetMark neither admitted nor denied, that AssetMark violated Section 206(4) of the Advisers Act and Rule 206(4)-1(a)(5) by allowing its staff, from July 2012 through October 2013, to circulate to prospective clients who were considering an F-Squared managed account service offered by AssetMark, performance advertisements created by F-Squared relating to a different separately managed account service not offered by AssetMark and that misleadingly described that different service’s performance between 2001 and 2008, and that AssetMark violated Section 204(a) of the Advisers Act and Rule 204-2(a)(16) by failing to maintain records substantiating the performance in the advertisements created by F-Squared. There are no disciplinary items to report for the management of AssetMark. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS AFFILIATED COMPANIES In the analysis of individual securities and in seeking out sources of information in the performance of the services described herein, AssetMark relies on a number of external sources, research service providers and unaffiliated third-party Portfolio Strategists and Investment Management Firms, as more fully described in each Disclosure Brochure. The following companies are under common control with AssetMark. For those affiliated companies you may interact with in connection with your AssetMark relationship, their industry activities and any conflicts of interest are described in further detail below: • Atria Investments, Inc. (d/b/a “Adhesion Wealth”) • AssetMark Brokerage, LLC • AssetMark Services, Inc. • AssetMark Trust Company AssetMark offers a wide array of investment products, and hence the investment strategies used to implement these products vary. In general, AssetMark offers a variety of risk profiles for each of its investment products, in which the levels of risk seek to accommodate a wide spectrum of clients. The strategy for varying the level of risk taken in each product is to offer greater levels of risk management for products that seek higher levels of protection. Risk management tools include, but would not be limited to fixed income instruments, mutual funds, derivatives, and active asset allocation strategies. AssetMark also allows third-party Investment Managers to advise or implement its programs and as such allows these third-party managers to pursue their investment strategies as well. AssetMark also seeks the advice of unaffiliated third-party Portfolio Strategists and other consultants on the asset allocation decisions appropriate for each product. Adhesion Wealth Adhesion Wealth. is a registered investment adviser with the U.S. Securities and Exchange Commission, currently providing sub- advisory services to other registered investment advisers, either directly or through a third party sponsored program. ITEM 9 – DISCIPLINARY INFORMATION AssetMark Brokerage, LLC AssetMark Brokerage, LLC (“AssetMark Brokerage”) is a broker-dealer registered with the SEC and is a member of FINRA. AssetMark Services, Inc. AssetMark Services, Inc. provides recordkeeping and administrative services to retirement plans. On September 26, 2023, the SEC issued an Order Instituting Administrative Cease-and-Desist Proceedings against AssetMark. The SEC alleged that, from at least September 2016 through January 2021, AssetMark failed to fully disclose that AssetMark and affiliate AssetMark Trust together set the amount of the payment that AssetMark Trust Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 6 of 15 AssetMark Trust Company AssetMark Trust is an Arizona chartered trust company that serves as the Custodian for certain Accounts on the AssetMark Platform. regard to most funds held by client accounts. This income and variation in payments create conflicts because AssetMark Trust is paid this income, as described below. AssetMark also has indirect affiliations with companies under GTCR. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Although not affiliated when AssetMark Trust contracted with the Program Administrator for services, AssetMark Trust and the Program Administrator, as described below in the FDIC-Insured Cash Program, are now under common ownership. Some employees of AssetMark are also shared with affiliated entities. This presents potential conflicts around the sharing of client’s personal information, trading practices, and supervision. To mitigate these conflicts, the Company has policies in place to supervise and monitor the activities of these shared employees. AssetMark Trust uses sub-custodians in fulfilling its responsibilities, including National Financial Services Corp., (whose affiliated brokerdealer, Fidelity Brokerage Services, LLC, also provides brokerage and clearing services for Client Accounts), see below, Custodial Relationships. Fidelity operates as a sub-custodian for AssetMark Trust, and as sub-custodian Fidelity receives certain payments from investment companies for certain administrative and recordkeeping services. AssetMark Trust receives payments from Fidelity for the recordkeeping and other administrative duties performed by AssetMark Trust as Custodian. Because Fidelity operates as a sub-custodian for AssetMark Trust, Fidelity remits approximately 92.25% of such fees collected from these investment companies to AssetMark Trust in exchange for the custodial support services AssetMark Trust provides. AFFILIATE SERVICES AND CONFLICTS OF INTEREST If an AssetMark-advised fund, e.g., a GuidePath or GuideMark Fund, is used, Fidelity pays AssetMark Trust 100% of the payments. Below are the types of fees AssetMark Trust receives: The conflicts of interest described here are also included in each applicable Disclosure Brochure for Advisory and Other Services, as described in Item 4. • 12b-1s, which are a cost to the shareholders of the mutual fund. If the prospectus of a mutual fund allows for 12b-1 fees to be paid for either “distribution” or “service,” it will be included in the fund’s expenses and deducted from the income the mutual fund earns. • Administrative Service Fees (“ASFs”), which are not an expense to the shareholders of the fund. These are an expense to the mutual fund and are paid to Fidelity per an agreement between the mutual fund company and Fidelity; • Recordkeeping fees earned on ERISA plan account holdings; and • Transaction-based fees, which may or may not be expenses of the fund. Banking Institution - AssetMark Trust With the input from their Financial Advisors, the Client chooses a Custodian from among those offered through the Platform. AssetMark Trust, an affiliate of AssetMark, is among the available Platform Custodians. If the Client chooses AssetMark Trust as their Platform Custodian, AssetMark Trust is paid for custodial and brokerage services provided to Client Accounts through the Platform Fee charged their Account and, where applicable, through additional fees. Pursuant to a contract between AssetMark and AssetMark Trust, AssetMark pays AssetMark Trust for services AssetMark Trust provides its custodial Clients. Additionally, AssetMark Trust receives payments from mutual funds, mutual fund service providers and other financial institutions for certain services AssetMark Trust provides related to investments held in Client Accounts. AssetMark Trust handles transfer agency functions, shareholder servicing, sub-accounting and tax reporting functions that these financial institutions would otherwise have to perform. Such payments are made to AssetMark Trust by these financial institutions based on the amount of assets invested in Client Accounts. Any such payments to the Custodian will not reduce the Platform Fee. Some mutual funds, or their service providers, provide compensation in connection with the purchase of shares of the funds, unless prohibited by law or regulation. AssetMark also hold fund shares directly, without using Fidelity as sub- custodian. In such a case, the fund or fund company can pay AssetMark Trust ASFs directly. AssetMark Trust receives ASFs from Fidelity, banks and insurance companies, or from their respective service providers. Any such income received by AssetMark Trust is in payment for administrative services it provides. This amount, in the aggregate, is substantial, in consideration of the services provided by AssetMark Trust to these respective service providers and varies by mutual fund. These payments are used to offset the additional annual custody fee otherwise payable by IRA Clients and Clients with Accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). AssetMark Trust currently waives any portion of this IRA & ERISA Account Fee not offset by this income. CASH MANAGEMENT SERVICES OFFERED BY AFFILIATE Investment Companies - GuideMark Funds and GuidePath Funds The GuidePath Funds are directly managed by AAM and invested in unaffiliated mutual funds and ETFs. AAM manages the GuidePath Funds based on research provided by current Portfolio Strategists in each of the Investment Approaches. AssetMark Due Diligence has ongoing oversight over the performance of the Sub-Advisers in the GuideMark and GuidePath Funds and the Portfolio Strategists on the Platform. ADMINISTRATIVE SERVICE FEES RECEIVED BY AFFILIATE AssetMark selects mutual funds used in their Solution Types and, generally, the mutual funds selected are institutional share class funds. However, if institutional share class funds are not available, a fund that includes a Rule 12b-1 fee can be selected. Although most mutual funds held by AssetMark Trust client accounts do not pay a 12b-1 fee, administrative service fee or similar income is paid with If Clients select AssetMark Trust as their Platform Custodian, they will be offered the following cash management services: FDIC-Insured Cash and CDARS Programs; Securities-Backed Lines of Credit; and FDIC-insured checking accounts. AssetMark Trust does not directly provide these services; they are provided to AssetMark Trust Clients through third-party providers, and AssetMark Trust is compensated by the third parties. With the exception of the Cash Allocation (discussed below, these services are optional; Clients can opt out of the services or choose not to use them. A disclosure document further discussing these cash management services, AssetMark Trust Company Disclosures Regarding Services, will be provided to Clients who select AssetMark Trust as their Platform Custodian. Please read this disclosure Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 7 of 15 to better understand the features, costs and conflicts of interest related to these services. The following is only a summary of those disclosures. calendar quarter, even though the Cash Allocation, cash pending investment or distribution portions of the Account do not receive any investment advisory or brokerage services. (They do receive administrative and custodial services.) The Financial Advisor Fee is also assessed on 100% of the value of the assets in Accounts invested in Platform Strategies. In some low interest-rate environments, the Financial Advisor Fee plus Platform Fee can exceed the amount of interest paid on the Cash Allocation. It is anticipated that, when looked at jointly, AssetMark Trust and AssetMark will receive more compensation on the Cash Allocation and cash pending investment or distribution portions of Accounts invested in the ICD Program than on Account assets invested in the Accounts’ investment Strategy. FDIC-Insured Cash Program Cash Allocation in Accounts invested in Platform Strategies: A portion (the “Cash Allocation”) of Client Accounts invested in a Platform Strategy is placed in cash or a cash alternative investment. If you choose AssetMark Trust as your custodian, this Cash Allocation will be placed in AssetMark Trust’s Insured Cash Deposit (“ICD”) program and deposited in one or more banks insured by the Federal Deposit Insurance Corporation (“FDIC”). The target Cash Allocation is 2%, and the Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. (Note: Accounts enrolled in AssetMark’s Tax Management Service (“TMS)” are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives.) In addition to the Cash Allocation, a Client Account can also hold cash pending investment or distribution and these cash amounts will be invested in the ICD Program. Additionally, Funding Accounts will be invested in the ICD Program. (A Funding Account is used to receive cash and assets transferred in kind before sale or transfer to an advised Account.) You may opt out of the ICD Program for your Cash Allocation. If you opt out of the ICD program, your Cash Allocation will be invested in one or more money market mutual funds Cash that is not yet in a sweep vehicle (due to trading activity, residuals or new cash in a funding account) will simply be in cash until swept to the ICD program or money market mutual fund, when cash is moved from the funding to managed account, or typically by the following business day. Client participation in the FDIC-Insured Cash Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust receives compensation from the Program Banks for the record keeping and administrative services it provides in connection with maintaining the FDIC-Insured Cash Program (the “Program Fee”). The interest rates paid Client Accounts under the FDIC- Insured Cash Program are determined by AssetMark Trust – in consultation with AssetMark, and are based on the interest rates paid by the Program Banks, less the Program Fees paid to AssetMark Trust by the Program Banks. In determining the interest rates paid Clients Accounts, AssetMark Trust also considers other factors, including the rates paid by competitors. The Program Fees paid to AssetMark Trust can be up to 4% on an annualized basis viewed on a rolling twelve- month basis, and across all Deposit Accounts. The amount of the Program Fee paid to AssetMark Trust and Administrative Fee paid to the third-party Program Administrator reduce the interest rate paid on Client Program Deposits. AssetMark Trust has discretion over the amount of its Program Fee, and AssetMark Trust reserves the right to modify the Program Fees it receives from Program Banks. This discretion in setting the Program Fee creates a conflict of interest on the part of AssetMark Trust; the greater the Program Fee AssetMark Trust receives – which is determined by AssetMark Trust in consultation with AssetMark – the lower the interest rate paid to Clients. In certain interest rate environments, the Program Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Program Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. The gross interest rate paid by each Program Bank, which affects the interest rates paid in the FDIC-Insured Cash Program, do and are expected to vary from Program Bank to Program Bank; this creates a conflict for AssetMark Trust when selecting Program Banks in that it incentivizes AssetMark Trust to select the banks that pay higher interest rates. No part of the Program Fee is paid to Financial Advisors. Administrative Accounts: If a Client selects an Administrative Cash Account, all of the Administrative Cash Account will be placed in the ICD Program, unless the amount of the deposit qualifies for, and the Client elects, the High Yield Cash Program, which is also part of the FDIC Insured Cash Program but one in which the interest rates credited are expected to be higher than those credited ICD Program deposits. The interest rate paid on the High Yield Cash program can be negotiable. General Securities Accounts (“GSAs”) may also hold FDIC-Insured Cash Program funds. You may opt out of the FDIC-Insured Cash Program, in which case your account will be invested in one or more money market funds. There is no Platform Fee and no Custodial Account Fee for Administrative Cash accounts. Any Financial Advisor Fee payable pursuant to a Client Advisory Agreement will be payable on an Administrative Cash Account unless AssetMark receives instructions not to charge the Financial Advisor Fee. Although there is no Platform Fee for Administrative Cash Accounts with deposits in the FDIC-Insured Cash Program, if the cash is deposited in the ICD Program and not the High Yield Cash Program, then those assets can be aggregated with assets in other Client Accounts with AssetMark for “householding” purposes, which aggregation should result in larger aggregate balances that can reduce the rate(s) of the Platform Fee(s) applicable to other Client Account(s). If the Client has selected a tiered Financial Advisor (or “FA”) Fee, this householding or aggregation of balances can also reduce the rate of the Client’s FA Fee. Deposits in the High Yield Cash Program, however, will not be aggregated with other AssetMark Client Account assets for fee householding purposes. You should determine if you would prefer the higher interest rate(s) offered by HYC or the lower fees available through “householding.” The Program Fees paid to AssetMark Trust can be greater or less than compensation paid to other Platform Custodians with regard to cash sweep vehicles. The interest rate Program Deposits earn with respect to the AssetMark Trust FDIC-Insured Cash Program can be lower than interest rates available to depositors making deposits directly with a Program Bank or with other depository institutions. Program Banks have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Program Bank. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest and other rates available the market, including money market mutual fund rates. Fees on Advised Accounts and Conflicts of Interest: The Platform Fee is assessed on 100% of the value of Account assets invested in Platform Strategies upon initial investment and, thereafter, at the end of each If an Account’s cash is invested in a money market mutual fund (because, for example, the Account opted out of the FDIC-Insured Cash Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 8 of 15 Program or is a Section 403(b)(7) custodial account), AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Program Fees it receives from Program Banks in the FDIC-Insured Cash Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers and that has been its recent experience. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Program Fee from Program Banks than the service fee from money market mutual funds. Destination Institution or other banks or depository institutions. Destination Institutions have a conflict of interest with respect to setting interest rates and do not have a duty to provide the highest rates available on the market and can instead seek to pay a low rate; lower rates are more financially beneficial to a Destination Institution. This is in contrast to money market mutual funds, which have a fiduciary duty to seek to maximize the rates they pay investors consistent with the funds’ investment strategies. There is no necessary linkage between the bank rates of interest on CDs and other rates available the market, including money market mutual fund rates. In addition to CDs, AssetMark Trust custodial clients may invest cash in the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts) and/or money market mutual funds. If an Account’s cash is invested in a money market mutual fund, AssetMark Trust receives and expects to receive service fees from the mutual fund or its service providers. AssetMark Trust expects the Placement Fees it receives from Destination Institutions in the CDARS Program to be at a higher rate than any service fee it will receive from money market mutual funds or their service providers. This is a conflict of interest for AssetMark Trust in that it expects to receive a higher Placement Fee from Destination Institutions than the service fee from money market mutual funds. Securities-Backed Lines of Credit (“SBLOC”) CDARS Program for Certificates of Deposits In addition to the FDIC-Insured Cash Program (and its ICD and HYC deposit accounts), AssetMark Trust makes available to its custodial client a Certificate of Deposit Account Registry Service® (“CDARS”) Program that allows a depositor to deposit amounts in Certificates of Deposit (“CDs”) at one or more depository institution insured by the Federal Deposit Insurance Corporation (“FDIC”). Deposits in the CDARS Program are deposited through a network of individual “Destination Institutions” unaffiliated with AssetMark Trust. Subject to the satisfaction of certain conditions, these deposits are eligible for FDIC insurance up to the maximum amount permitted by the FDIC, currently $250,000 for all deposits held at each Destination Institution in the same legal capacity. AssetMark Trust is not a depository institution and does not issue or offer CDs. There is no Platform Fee is assessed on the CDs held in your GSA. If instructed by your Financial Advisor, a Financial Advisor Fee can be charged. loan. Such Conflicts of Interest: If Clients select AssetMark Trust to act as their Platform Custodian, they can use the holdings in their non-retirement Account(s) as collateral for a loans are usually referred to as Securities-Backed Lines of Credit (“SBLOC”). receives compensation from Suitability: Using an Account as collateral for a loan is not suitable for all Clients. Securities-backed loans involve a number of risks, including the risk of a market downturn, tax implications if pledged securities are liquidated, and the potential increase in interest rates, and other risks. If the value of pledged securities drops below certain levels, the borrower can be required to pay down the loan and/or pledge additional securities. Clients must consider these risks and whether a securities-backed loan is appropriate before applying. Clients should consider these issues and discuss their financial position and objectives and whether using their investments as collateral for a loan is appropriate with their Financial Advisor. There are two general ways for a Client to apply for a loan using the assets in their non-retirement AssetMark Trust custodial Account(s) as collateral: 1. Apply for a loan through a lender available through AssetMark Trust’s Cash Advantage™ Lending service; or 2. Apply for a loan from the lending institution of the Client’s choice. Client participation in the CDARS Program results in financial benefits for AssetMark Trust and its affiliates that create conflicts of interest. AssetMark Trust the Destination Institutions for the placement of deposits in CDs through the CDARS Program (the “Placement Fee”). (The third-party administrator of the CDARS Program also receives a fee (“CDARS Administrative Fee”) from the Destination Institutions.) AssetMark Trust, in consultation with AssetMark, determines the amount of its Placement Fee, and the Placement Fee reduces the interest rates paid by the Destination Institutions on the CDs under the CDARS Program, as does the CDARS Administrative Fee paid to the third-party CDARS Program Administrator. In determining the Placement Fee, AssetMark Trust and AssetMark consider a number of other factors, including the rates paid on CDs in competitor programs. The Placement Fees paid AssetMark Trust can be up to 4% on an annualized basis viewed on a rolling twelve-month basis across all CDs. AssetMark Trust has discretion over the amount of its Placement Fee, and AssetMark Trust reserves the right to modify the Placement Fees it receives from Destination Institutions. This discretion in setting the Platform Fee creates a conflict of interest on the part of AssetMark Trust and AssetMark; the greater the Placement Fee AssetMark Trust receives – which is determined by AssetMark Trust in consultation with AssetMark – the lower the interest rate paid to Clients on CDs. In certain interest rate environments, the Placement Fee is a substantial source of revenue to AssetMark Trust and, indirectly, to AssetMark Financial Holdings, Inc. AssetMark Trust can reduce its Placement Fees and can vary the amount of the reductions between Clients and the amount of interest paid Clients. No part of the Placement Fee is paid to Financial Advisors. AssetMark Trust Company’s Cash Advantage™ Lending Service: AssetMark Trust has established relationships with two separate lenders to which Clients can apply for a line of credit under AssetMark Trust’s Cash Advantage™ Lending service. Currently, the two lenders are Supernova Lending, Inc. (“Supernova”) and The Bancorp Bank, an FDIC-insured bank (“Bancorp”). AssetMark’s arrangements with these lenders are designed to streamline the loan application process and provide the lenders access to information about the Accounts that Clients use as collateral for the loans. AssetMark Trust is not affiliated with either Supernova or Bancorp, and each is responsible for its own services. Clients may also use their own lender. AssetMark Trust does not have the authority to encourage Clients to take a loan and does not have the authority to decide whether one of the lenders in its Cash Advantage™ Lending service will offer Clients loans. The interest rate paid for a line of credit can be negotiable. The Placement Fees paid to AssetMark Trust can be greater or less than compensation paid to other custodians for similar services. The interest rate CDs earn with respect to the CDARS Program offered through AssetMark Trust can be lower than interest rates available to depositors making deposits directly with, or purchasing CDs directly from, a Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 9 of 15 AFFILIATE FEE INCOME AND ASSOCIATE CONFLICTS DISCLOSURE Compensation and conflicts of Interest: AssetMark Trust benefits if a Client takes a loan because the lenders in the Cash Advantage™ Lending service pay AssetMark Trust compensation based on outstanding loan balances. AssetMark Trust has discretion to reduce its compensation in order to reduce the interest rate charged a loan. AssetMark Trust has a conflict of interest with respect to the interest rates charged on loans; the higher the compensation AssetMark Trust receives, the more expensive the loans are for Clients. Deposit Accounts Opened through AssetMark Trust Company’s Cash Advantage™ Service GPS Fund Strategies and GPS Select Client Accounts invested in these Strategies will receive allocations, determined by AssetMark, among AssetMark ‘s Proprietary Funds. AssetMark receives fees from the Proprietary Funds in which these Accounts invest. The fees differ between Funds and the total fees collected will vary depending upon the profile selected by the Client and the fund allocation within each profile. If a Client elects the GPS Fund Strategies, the Client authorizes and instructs that the Account be invested pursuant to the selected profile, acknowledges that fund advisory and other fees collected by AssetMark will vary, and approves of the fee payments to AssetMark. The Client will be given prior notice if these allocations or mutual funds change resulting in fee payments and, unless the Client or the Financial Advisor gives notice to AssetMark, the Client consents to these changes. If Clients select AssetMark Trust as their Platform Custodian, they can choose to open a deposit (checking) account at Bancorp, the FDIC- insured bank that offers online banking services and debit cards through AssetMark Trust’s Cash Advantage™ service. Bancorp deposit accounts and AssetMark non-retirement custodial accounts can be linked, so that amounts can be automatically transferred between accounts based upon the minimum and maximum targets set for balances in the Client’s Bancorp checking account. AssetMark Trust benefits financially if Clients open accounts at Bancorp because Bancorp pays AssetMark Trust compensation based on the average monthly balances in Clients’ deposit accounts. CLASS ACTION SERVICES OFFERED BY AFFILIATE If a Client selects GPS Select, the Client authorizes and instructs that the Account be invested pursuant to the selected profile and acknowledges that AssetMark is permitted to modify Fund allocations within a range such that fund management fees earned by AssetMark can vary within a range of 0.30% of the assets in the Strategy. Client approves fund allocations within this range and acknowledges Client will not receive prior notice of the fund allocation changes unless such allocations would exceed the 0.30% range. For more information regarding the fees collected by AssetMark when using these Strategies, refer to the allocation tables provided in Exhibit C at the end of the Referral and Platform Disclosure Brochures. INCENTIVE COMPENSATION Certain AssetMark associates, typically sales associates, are eligible to receive compensation pursuant to a Sales Incentive Plan (“SIP”). Payments under a SIP are based on meeting certain production goals in support of AssetMark’s long-term growth strategy and profitability but are not based on specific product offerings. Financial Advisors, not AssetMark associates, are responsible for a Client’s suitability and/or investment recommendations. AssetMark can also provide additional incentives for affiliate (Adhesion Wealth Services) program referrals or to promote services, e.g. tax management services. Certain AssetMark associates are also eligible to receive compensation based on meeting production goals specific to AssetMark’s proprietary strategies. These incentives create a conflict of interest because AssetMark associates can earn more compensation in support of AssetMark’s business profitability and growth. ITEM 11 – CODE OF ETHICS AND PERSONAL TRADING; PARTICIPATION IN CLIENT TRANSACTIONS AssetMark Trust has contracted with Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to provide Class Action Services to AssetMark Trust custodial clients. Broadridge will be compensated for its Class Action Services to AssetMark Trust clients by retaining 20% of class action proceeds payable to AssetMark Trust clients (who have not opted out of the Class Action Services). AssetMark Trust also uses Broadridge as a service provider for other services. Broadridge is compensated by AssetMark Trust or another party, such as the security issuer, depending on the service. For example, AssetMark Trust pays Broadridge to deliver prospectuses related to the holdings in client accounts to AssetMark Trust clients, but the security issuer pays Broadridge for delivery of proxy materials. Broadridge provides incentives to AssetMark Trust to use Broadridge by providing rebates to AssetMark Trust if multiple services are used. AssetMark Trust receives payments from Broadridge based on the compensation Broadridge receives for delivery of proxy materials to AssetMark Trust clients, and the rate used to calculate these payments will increase if Broadridge Class Action Services are used. The rebate paid by Broadridge to AssetMark Trust (which is based on the compensation Broadridge receives for proxy material delivery from the security issuer) can exceed the amount of fees paid by AssetMark Trust to Broadridge during the year (for prospectus deliveries). This receipt by AssetMark Trust creates a conflict of interest in that it is to AssetMark Trust’s advantage to offer Broadridge Class Action Services to its clients. AssetMark Trust addresses this conflict by this disclosure, by making clear to clients that they can opt out of the services and by having a procedure for them to do so. An additional conflict exists as follows. Clients can choose as the Strategy for their Account one managed by AssetMark Trust affiliate, AssetMark would then have the conflict of choosing for its advisory clients securities likely to be involved in class actions, because such could increase the likelihood that AssetMark Trust clients would choose to use Class Action Services. AssetMark Trust and AssetMark address this conflict by disclosing it. AssetMark has adopted a Code of Ethics (the “Code”) that is intended to comply with the provisions of Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”), which requires each registered investment adviser to adopt a code of ethics setting forth standards of conduct and requiring compliance with federal securities laws. Additionally, the Code is designed to comply with Section 204A of the Advisers Act, which requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by any person associated with such investment adviser. The Code requires that all “Supervised Persons” (including officers Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 10 of 15 ITEM 12 – BROKERAGE PRACTICES AssetMark has full discretionary authority under the respective client agreements to select the securities to be bought or sold and the amount of securities to be bought or sold for those client Accounts on the Platform for which it serves as the primary investment adviser. AssetMark’s authority is limited by the parameters of the Solution Type and Strategy identified for each client Account for which it acts as primary investment advisor. For more detailed information, see AssetMark’s “Referral Disclosure Brochure.” and certain affiliated persons and employees of AssetMark) in carrying out the operations of AssetMark, adhere to certain standards of business conduct. Specifically, the Code requires that these persons: (i) comply with all applicable laws, rules and regulations, (ii) avoid any conflict of interest with regard to AssetMark and its Clients, (iii) avoid serving their personal interests ahead of the interests of AssetMark and its Clients, (iv) avoid taking inappropriate advantage of their position with AssetMark or benefiting personally from any investment decision made, (v) avoid misusing corporate assets, (vi) conduct all of their personal securities transactions in compliance with the Code, and (vii) maintain, as appropriate, the confidentiality of information regarding AssetMark’s operations. AssetMark does not have such authority to determine the securities and amounts to be bought or sold for client Accounts on the Platform for which third party Financial Advisory Firms act as the clients’ primary investment advisor. For more detailed information, see AssetMark’s “Platform Disclosure Brochure.” As Adviser of the GuideMark and GuidePath Funds, AssetMark has delegated to the Fund Sub Advisors the authority to determine securities and amounts of securities to be bought or sold by the Funds. In each case, the authority is to be exercised within the disclosed investment objectives of each Fund. For more information, refer to the Funds’ Prospectus, available from AssetMark on request. When AAM selects mutual funds used in the Savos solutions, it generally selects mutual funds that are “no transaction fee” funds or “NTF”, or institutional funds, when available. Generally, NTF funds pay Custodians ASFs for services provided. The Code contains a number of prohibitions and restrictions on personal securities transactions and trading practices that are designed to protect the interests of AssetMark and its Clients. First, the Code prohibits trading practices that have the potential to harm AssetMark and/or its Clients, including excessive trading or market timing activities in any account that AssetMark manages, trading on the basis of material non-public information, and trading in any “Reportable Security” when they have knowledge the security is being purchased or sold, or is being considered for purchase or sale by the Accounts managed by AssetMark or any AssetMark-advised mutual funds. Second, the Code mandates the pre-clearance of certain personal securities transactions, including transactions in securities sold in initial public offerings or private placements. The Code also requires the pre-clearance of Reportable Security transactions for certain Access Persons (Access Persons is a segment of the Supervised Persons group that has access to AssetMark information). Finally, the Code requires Access Persons to submit, and the Chief Compliance Officer (the “CCO”) to review, initial and annual holdings, and quarterly transaction reports. As investment adviser for Referral model Accounts, AssetMark directs trades to the Clients’ selected custodian with the exception of Savos investment solutions available only at AssetMark Trust. To the extent that AssetMark Trust is designated as custodian, trades within its authority, and such execution services are compensated according to AssetMark Trust’s standard rates for custodial services. AssetMark also has the authority to select brokers other than AssetMark Trust. AssetMark utilizes StarCompliance to provide enhanced tracking of certain employee transactions and gives AssetMark the ability to analyze those employee trades against certain parameters and transactions in its managed Accounts or any AssetMark-advised funds. Access Persons also utilize this system to annually certify their receipt of, and compliance with, the Code and pre-clear their Reportable Security transactions, if they are required to do so by the Code. All Supervised Persons under the Code are responsible for reporting any violations of the Code to the CCO. The Code directs the CCO to submit reports to the Board of Trustees of any AssetMark-advised mutual funds regarding compliance with the Code, and to impose sanctions on violators, as warranted. AssetMark will provide a copy of the Code to any Client or prospective Client upon request. For Platform Accounts managed by third party Financial Advisory Firms, the Financial Advisory Firms and/or the clients have the authority to select the broker/custodians to be used, though the pool of custodians made available for use on the Platform for mutual fund and ETF accounts is determined by AssetMark. Platform Custodians charge for their services according to established custodial fee schedules. Each Client will enter a custodial agreement with their selected Custodian and be provided a fee schedule or schedule of charges. Refer to the Custody Agreement or schedule of charges for specific fees applicable to the Client Account. For example, the Custodians can also charge termination fees and various other miscellaneous fees for wires, returned checks and other non-standard activity on an Account such as fees for alternative investments. Custody fees can also apply to Accounts in Solution Types that are either closed or no longer offered to new Clients. All custody fee details are clearly presented in each Custodian’s fee schedule and separate custody agreement. As Advisor of the GuideMark and GuidePath Funds, AssetMark has delegated to the Fund Sub Advisors the authority to select brokers and dealers to be used and the commission rates to be paid, subject to AssetMark’s supervision. AssetMark Trust, an affiliated trust company, effects securities transactions on behalf of AssetMark clients whose accounts are held in custody by AssetMark Trust. AssetMark Trust is not paid any transaction-based compensation for effecting transactions, but is paid shareholder servicing or administration fees by mutual fund families or others in connection with the transactions in such custodial accounts. AssetMark Trust exercises no discretion over such accounts, but effects transactions only at the direction of AssetMark, clients or their third-party investment advisors. AssetMark does not anticipate any potential conflicts of interest in the execution of transactions, but AssetMark’s role with respect to the execution of transactions will be subject to the Code of Ethics described above. AssetMark or the Discretionary Manager, if applicable, will generally direct most, if not all transactions to the Account Custodian selected by the client. In certain circumstances, better execution is available from broker-dealers other than the broker-dealer(s) generally used by the Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 11 of 15 With respect to its role as the Adviser of the GuideMark and GuidePath Funds, AssetMark has negotiated an institutional commission schedule with one specific brokerage firm, Abel Noser, Inc., to execute transactions on behalf of certain of the GuideMark and GuidePath Funds for a commission cost of .60 cents per share based on the total volume of trades executed, and has encouraged the Subadvisors to use their best efforts to direct trades to Abel Noser when such direction satisfies their internal “best execution” guidelines. Neither AssetMark nor any of the Subadvisors receive any “soft dollar” benefits from Abel Noser for the direction of trades pursuant to the above arrangement. Able Noser does, however, provide detailed transaction reporting to the GuideMark and GuidePath Funds, and Platform accounts, which analyzes the commission and execution cost of all trades executed in the Fund portfolios and client portfolios on the Platform (with the exception of the Savos UMAs), including both trades executed by Abel Noser and those executed by other brokers independently selected by the Subadvisors. RECEIPT OF EXECUTION REPORTS Client’s Custodian. AssetMark, or other Discretionary Manager in the instance of IMA Accounts, can trade outside the selected broker- dealer(s). Although ETFs are priced intra-day in the same manner as other equity securities, AssetMark directs trades for ETFs to the Custodian selected by the Client and the Financial Advisory Firm once daily. The actual timing of trade order execution will vary, depending upon trade volume, systems limitations and issues beyond AssetMark’s control. In any case, all ETF trades for a given day are placed at the same time in order to provide the most feasibly equivalent execution for all participating clients. With respect to ETF Accounts which may include ETFs for which it may be impracticable to execute transactions in a single day in response to a Portfolio Strategist’s adjustments and rebalancing of its ETF asset allocation model, the Client instructs, authorizes and directs that such Accounts be traded in accordance with instructions on timing and price levels given by AssetMark to the Custodian, which AssetMark will obtain from the Portfolio Strategist to the extent practicable or, in the case of exceptionally high volume requests, in accordance with instructions provided by AssetMark to an alternate broker or “authorized participant” liquidity provider selected by AssetMark with the instruction to provide liquidity on a net fee basis. AssetMark does not utilize soft dollars by directing trades to broker- dealers and accumulating soft dollar credits. AssetMark receives execution reports from vendors such as Abel Noser and Fidelity, which it uses to review best execution of trades on the Platform. AssetMark does not pay directly for these reports. The client’s asset-based custody fee does not vary depending on whether AssetMark receives these execution reports or not. ACCOUNT LIQUIDITY RESERVE As Overlay Manager for a Separately Managed Accounts Investment Solution, AssetMark intends to invest the Account consistent with the models provided by the Portfolio Strategist, unless circumstances indicate that modified allocations or investments are appropriate. The Client may specify the initial Portfolio Strategist for the Account and will be given notice of any change to that Portfolio Strategist. AssetMark may remove or replace the Portfolio Strategists on the Account in its discretion. The Overlay Manager will have limited discretionary authority to execute transactions in each Account necessary to (i) track any reallocations, rebalance or other adjustments to the SMA asset allocations constructed by the Portfolio Strategists, (ii) implement changes recommended by the Portfolio Strategists; (iii) effect sale transactions of specified securities as directed by the Client and purchases of replacement securities; and (iv) implement any individual securities restrictions imposed on the Account by the Client. To properly maintain cash flows for Client needs, a portion of all Client Accounts invested in a Strategy is maintained in a short-term investment vehicle. This liquidity reserve (or “Cash Allocation”) is generally referred to as the Custodian’s cash “sweep” vehicle. The Cash Allocation target is 2%, and an Account’s Cash Allocation is rebalanced quarterly if the allocation falls below 1.5% or is more than 2.5% of total Account assets. (Note: Accounts enrolled in TMS are not included in the quarterly rebalance. TMS is an optional service that AssetMark offers for some strategies on its Platform. Accounts enrolled in TMS may have Cash Allocations of more than 2%. TMS will review the Cash Allocation on an ongoing basis, with the objective to bring it to the 2% target, but with priority given to TMS objectives.) All security transactions created for accounts in Savos solution types are sent to the Custodian selected by the client for execution at approximately market open. ETF security transactions for non-Savos products are sent to the custodian selected by the client for execution. Trades are bundled and submitted for execution on a random basis by the Trade Operations Group and AAM in accordance with established procedures. Security transactions submitted by PSG and AAM will be placed in accordance established procedures. Insured Cash Deposit The sweep vehicle for the Cash Allocation will differ by the Custodian and Strategy selected by the Client. At AssetMark Trust, it is usually AssetMark Trust’s (“ICD”) Program, but depending upon the Strategy selected for the account could be a money market mutual fund or other short-term pooled investment vehicle. Additionally, an AssetMark Trust Client can opt out of the ICD Program for the Account’s Cash Allocation, in which case the Account will be invested in one or more money market funds (see FDIC-Insured Cash Program, above). ITEM 13 – REVIEW OF ACCOUNTS AssetMark has negotiated rates with, and encouraged Subadvisors to use a specific brokerage firm. For more information, refer to the Funds’ Prospectus, available from AssetMark on request. AssetMark has established an electronic interface with certain brokerage and custodial firms with whom clients can establish accounts by executing a separate agreement with such broker or custodian. The electronic interfaces established between AssetMark and such firms allow AssetMark to receive and transmit account data electronically to the firms to effectively provide account administration, trading and reporting for client accounts. A list of such firms will be provided by AssetMark upon request. The trading and custodial expenses incurred by the client are set forth in the separate agreement executed by the client and the broker or custodian. Said charges may be more or less than those of other brokers providing similar services. AssetMark does not receive any research or other services from any broker or custodian except as specifically discussed below. AssetMark does not assign client accounts directly to specific individuals for investment supervision, and hence there is not a single individual or class of individuals within the organization that can be identified as being solely responsible for implementing a full set of review criteria on any one client account. Instead, AssetMark offers a platform of Solution Types to its clients, each of which is a model Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 12 of 15 Firms” and their representatives are referred to as the “Financial Advisors”). The Financial Advisors consult with Clients to assess their financial situation and identify their investment objectives in order to implement Solution Types and Strategies designed to meet the Client’s financial needs. A Financial Advisor referring a Client to AssetMark for advisory services interviews the Client and makes a determination that a Solution Type is suitable for the Client before making the referral to AssetMark. Working with the Financial Advisor, a Client selects an Solution Type for the Client’s Account, and the components of the Client’s Strategy, including the Client’s desired and appropriate Risk/Return Profile. Financial Advisors are required to contact Clients at least annually regarding the suitability of the Client’s chosen Solution Type(s). AssetMark manages each Client Account according to the Client’s selected Solution Type under the terms of the AssetMark IMSA. Financial Advisory Firms receive fees for their services and compensation from AssetMark for referrals of Clients, as described previously in the Fees section under Financial Advisor Fee. portfolio to which the client’s account is linked. A variety of teams within the organization then have responsibility for reviewing the application of the appropriate investment guidelines to each account. At the model level, one group is responsible for ensuring that the investment models to which client accounts are linked are consistent with guidelines: AAM reviews those model recommendations provided by the third-party investment strategists offering solution types on the AssetMark platform. AAM creates and monitors the model recommendations offered to clients within the Savos investment strategies available on the AssetMark platform. Other groups within the organization monitor the degree to which individual client accounts adhere to the investment models monitored by AAM or created and monitored by AAM. These groups include Trade Operations, which monitors account adherence to models provided by third-party strategists and, adherence to models created and maintained by AAM. Finally, a group known as the Adviser Services Group (“ASG”) deals directly with the Financial Adviser to resolve any issues that might arise in the client’s own review (or the adviser’s review) of the account. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ADDITIONAL COMPENSATION In addition to the compensation payable under the IMSA, Client Services Agreement (which certain clients whose Financial Advisors make use of the Advisor Platform, enter into, hereinafter the “CSA”), or other similar agreements, AssetMark enters into other fee arrangements with certain Financial Advisory Firms and/or Financial Advisors in the manner set forth below. Such arrangements will not increase the fees payable under the IMSA, CSA, or other similar agreement, by the Client. Advisor Benefits Program for Financial Advisors The Custodians of Platform clients typically receive a Shareholder Servicing Fee from each mutual fund family included in the client Accounts. This fee generally ranges from 0.25% to 0.35% per annum of the amount invested through the Platform in the mutual funds of each fund family. Additionally, AssetMark provides the Custodians certain services with respect to the custody arrangements. In addition, AssetMark receives, and in the future can receive, marketing expense reimbursements from certain Portfolio Strategists and mutual fund companies, which reimbursements are intended to offset a portion of AssetMark’s costs incurred in marketing the Platform. AssetMark refers clients to other registered investment advisors and can receive referral fees based on a portion of the fees paid by the clients to these advisors. The full terms of such referral arrangements will be disclosed to such clients in writing at the time they execute an agreement with the advisors. Under AssetMark’s Advisor Benefits Program, Financial Advisors have the option to utilize AssetMark’s advisor-directed tools, templates and best practices, or to engage with AssetMark to receive business and investment consulting, and/or education and guidance for implementing a growth plan for their businesses. Certain Financial Advisors can receive an allowance or “growth support” for reimbursement of qualified expenses incurred by the Financial Advisor based on their participation in AssetMark sponsored events, marketing initiatives, or use of technology resources and tools. Financial Advisors can also receive benefits by reaching certain levels, or tiers, on the AssetMark Platform This program creates a financial incentive for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. AssetMark receives compensation as the Advisor to the GuideMark and GuidePath Funds, which are utilized with certain Solution Types on the Platform. Community Inspiration Award AssetMark makes cash payments to Financial Advisory Firms who solicit clients for AssetMark. Each such solicitor firm enters into a written agreement with AssetMark which specifies the terms of the relationship. The solicitor is required to provide each prospective client with a copy of AssetMark’s Referral Disclosure in addition to its Disclosures Regarding Compensation. The Platform Fee paid by the Financial Advisory Firm to AssetMark for related accounts of any Client in the Platform are negotiable, as are Platform Fees paid by any Financial Advisory Firm, subject to approval. OTHER RELATIONSHIPS AND COMPENSATION In order to promote community involvement, AssetMark created the Community Inspiration Award to honor selected Financial Advisors across the United States who have inspired others by supporting charitable organizations in their communities. AssetMark will make a cash donation, subject to the published rules governing the program, to the Financial Advisor’s nominated charity in accordance with the following: i) the charitable organization is not a Client or prospective Client of the Financial Advisor, ii) the Financial Advisor cannot hold an officer position on the charitable organization’s board or direct funds at the charitable organization, and iii) the charitable organization must not have the ability to contribute funds or services to a candidate for public office or to a Political Action Committee. There is no direct compensation paid to an honored Financial Advisor. However, the Financial Advisor has an incentive to place, or retain Client assets on the Platform as a result of AssetMark’s contribution to their supported charitable organization. Under the Referral Model, AssetMark receives Client referrals through representatives of broker-dealer firms and investment adviser firms (these firms are referred to in this brochure as “Financial Advisory Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 13 of 15 Direct and Indirect support for Financial Advisors Marketing Support for Financial Advisory Firms Certain Financial Advisory Firms enter into marketing arrangements with AssetMark whereby the Firms receive compensation and/or allowances in amounts based either upon a percentage of the value of new or existing Account assets of Clients referred to AssetMark by Financial Advisors, the addition of new Financial Advisors making use of the Platform, or a flat dollar amount. These arrangements provide the communication of AssetMark‘s service capabilities to Financial Advisors and their Clients in various venues, including participating in meetings, conferences and workshops. AssetMark also provides certain Financial Advisory Firms or their representatives with organizational consulting, education, training and marketing support. These arrangements create a financial incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. Negotiated Fees AssetMark sponsors annual conferences for participating Financial Advisory Firms and/or Financial Advisors designed to facilitate and promote the success of the Financial Advisory Firm and/or Financial Advisor and/or AssetMark advisory services. AssetMark offers Portfolio Strategists, Investment Managers and Investment Management Firms, who are also Sub-Advisors for the GuideMark and GuidePath Funds, the opportunity to contribute to the costs of AssetMark’s annual conferences and be identified as a sponsor. AssetMark covers travel-related expenses for certain Financial Advisors to attend AssetMark’s annual conferences, quarterly meetings, or to conduct due diligence visits. In addition, and outside of the Business Development Allowance, AssetMark contributes to the costs incurred by certain Financial Advisors in connection with conferences or other Client events conducted by the Financial Advisor or the Financial Advisory Firm. AssetMark also solicits research from Financial Advisors regarding new products or services that AssetMark is considering for Clients. In exchange for this feedback and guidance, AssetMark can offer an incentive to the Financial Advisor for their attendance at, or participation in, for example, an online survey or an in-person focus-group. These programs create financial incentives for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. AssetMark will, in its discretion, negotiate the AssetMark Fee for clients of certain Financial Advisors. Certain Financial Advisors with higher aggregate levels of assets on the Platform are eligible for negotiated fees which are passed through to the client. The Financial Advisor does not earn additional compensation as a result of these negotiated fees. Discounted Fees for Financial Advisors Pilot and Early Release Programs AssetMark can invite certain Financial Advisor Firms to participate in pilot or early release programs designed to solicit feedback on new product or service offerings. In exchange for participation in these programs, AssetMark may provide certain incentives to the Financial Advisor Firms such as fee waivers, or other incentives. Strategist Fees Financial Advisors can receive discounted pricing or complimentary subscriptions from third-party service providers or from AssetMark or its affiliates for services such as business consulting, practice management, technology, financial planning tools and marketing- related tools and services because of their participation in the Platform. In certain cases, AssetMark receives a portion of the subscription fees paid by Financial Advisors to such third-party service providers. Discounted pricing and complimentary subscriptions can be subsidized by AssetMark. These arrangements create a financial incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. Loans by AssetMark to Financial Advisory Firms In circumstances where a Financial Advisory Firm uses a Portfolio Strategist to assist in the management of a Client’s account, AssetMark will pay a strategist fee on a selected basis to the Financial Advisory Firm for use and monitoring of the model portfolio recommended by the Portfolio Strategist. This strategist fee creates a conflict of interest because the Financial Advisory Firm has an incentive to use the model portfolios produced by a Portfolio Strategist in order to keep receiving the fee, compared to other arrangements that might be less expensive or more appropriate for the Client Transitions Program for Financial Advisory Firms AssetMark and its affiliates have made loans on a selected basis to some Financial Advisory Firms, and will continue to do so in certain circumstances. These financing arrangements result in additional revenue to AssetMark (primarily interest earned on those loans) and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has borrowed money from AssetMark and that still has a loan balance outstanding will have an incentive to continue using AssetMark’s products and services for its Clients even when AssetMark’s services can be more expensive or less appropriate for the Client. Certain financing arrangements are structured to create long- term obligations by those Financial Advisory Firms that can be costly or difficult for those firms to terminate and certain of those arrangements may give AssetMark the right to convert the debt obligation into equity in the Financial Advisory Firm, giving AssetMark certain additional rights. Therefore, these loans can create an on-going conflict of interest for Financial Advisory Firms between their own financial interests tied to those financing arrangements and the interests of their Clients. Payment for testimonials/endorsements AssetMark and its affiliates may enter into business arrangements designed to assist Financial Advisory Firms with succession planning, and will continue to do so. These financing arrangements result in additional revenue to AssetMark and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has agreed to share a portion of their Firm’s revenue with AssetMark and will have an incentive to continue using AssetMark’s products and services for its Clients even when AssetMark’s services can be more expensive or less appropriate for the Client. Therefore, these business arrangements can create a conflict of interest for Financial Advisory Firms between their own financial interests and the interests of their Clients. Financial Advisors may provide video, audio or documented statements endorsing AssetMark, and AssetMark may compensate the Financial Advisors for these. Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 14 of 15 ASSETMARK CASH PAYMENTS TO THIRD PARTIES CLIENT REPORTS AssetMark makes cash payments to third parties (“Referring Firms”) for referrals (“Referral Fees”) of Financial Advisory Firms (“Referred Financial Advisory Firms”) that enter into Platform arrangements (“Referral Arrangements”). In certain cases, Referral Fees shall be discounted in the event that a Referring Firm receives compensation from a qualified custodian (as defined in Item 9 below under Custodial Relationships) in connection with the referral of a Referred Financial Advisory Firm. Each Referring Firm enters into a written agreement with AssetMark and discloses in writing to each prospective Referred Financial Advisory Firm the existence of the Referral Arrangement. Referral Arrangements will not increase the fees payable by Clients of Referred Financial Advisory Firms under the client agreements. The Custodian selected by the Client shall send periodic account statements detailing the Client’s individual Account(s), including portfolio holdings and market prices, all transactions (such as trades, cash contributions and withdrawals, in kind transfers of securities, interest and dividend or capital gains payments) for each individual Client Account, and fee deductions. Additionally, Clients can inquire about their current holdings and the value of their Accounts on a daily basis by electronic or web-based access. The Custodian may also send a Transaction Acknowledgement to the Client for all cash contributions, withdrawals and in kind transfers as they occur. Although the standard form of IMSA provides that the receipt of individual transaction confirmations is waived by the Client, a Client may elect, by written request to AssetMark or AssetMark Trust, to receive a confirmation of each security transaction and such confirmations will thereafter be provided. ITEM 15 – CUSTODY The Custodians will mail a letter of acknowledgement confirming the establishment of an Account and receipt of assets, separately to the Account’s address of record. Clients are strongly encouraged to review all statements, acknowledgements and correspondence sent by the Custodian. A Quarterly Performance Review (“QPR”) may also be generated for clients on the Platform. The QPR shows current allocations of the client’s selected models as well as performance Information. ITEM 16 – INVESTMENT DISCRETION AssetMark accepts discretionary authority to manage the assets in the client’s accounts under the Referral platform. AssetMark also accepts discretionary authority when a proprietary strategy is selected for the Client’s account portfolio strategist on the client’s account based on the client selecting a proprietary strategy. We observe investment limitations and restrictions when notified of such by the Client. ITEM 17 – VOTING CLIENT SECURITIES AssetMark does not provide custodial services to its clients. AssetMark is determined to have custody of client funds in accordance with the SEC’s Custody Rule given the affiliation between AssetMark and AssetMark Trust, the qualified custodian of the Advisor’s clients’ assets. Given this determination, AssetMark will engage an independent public accountant to conduct an annual, independent surprise audit of client funds and securities. Client assets are held with banks, financial institutions or registered broker-dealers (“Platform Custodians”) or “Custodians”) that are qualified custodians under Advisers Act Rule 206(4)–2. Clients will receive custodian account statements directly from their selected Platform Custodian at least quarterly. Clients are urged to carefully review those statements and compare the custodial records to the quarterly performance reports that are available to them. The Client agrees to review all Account Statements, trade confirmations and other notices and confirmations of information and promptly notify AssetMark of any errors within 10 days. AssetMark shall not be liable for any losses due to errors that remain unreported for more than 10 days after receipt of mailed Account Statements, trade confirmations and other notices and confirmations of information or the electronic posting of such documents. The information in our reports varies from custodial statements based on accounting procedures, reporting dates or valuation methodologies of certain securities. Custodial fees are also outlined in the respective custodial agreement executed between the Client and the custodian. Clients may obtain a copy of AssetMark’s complete proxy voting policies and procedures upon request. Clients may also obtain information from AssetMark about how AssetMark voted any proxies on behalf of their account(s). Each Disclosure Brochure reflects the custodians available for each platform. Among others, AssetMark provides access to the following Platform Custodians: A copy of our proxy voting policies and procedures and/or information regarding the votes cast by AssetMark with regard to a client’s securities is available upon request mailed to: • AssetMark Trust, an Arizona trust company and affiliate of AssetMark, 3200 North Central Avenue, Seventh Floor, Phoenix, Arizona 85012. Its mailing address is P.O. Box 80007, Phoenix, Arizona 85060. • Charles Schwab & Co., Inc. (“Schwab”). 7801 Mesquite Bend Drive, Ste. 112, Irving, TX 75063 AssetMark, Inc. Attention: Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 • Fidelity Brokerage Services, LLC (“Fidelity”). 200 Seaport Boulevard, Boston, MA 02210. • Pershing Advisor Solutions (“PAS”). One Pershing Plaza, Jersey City, NJ 07399 The Client designates the applicable Discretionary Manager as its agent to vote proxies on securities in the Account and make all elections in connection with any mergers, acquisitions and tender offers, or similar occurrences that affect the assets in the Account. Client acknowledges that as a result of this voting designation it is also designating the Discretionary Manager as its agent to receive proxies, proxy solicitation materials, annual reports provided in connection with proxy solicitations and other materials provided in connection Form ADV–Part 2A Disclosure BrochureThis must remain with the Client Page 15 of 15 APPENDIX 1 INFORMATION Attached to this Form ADV Part 2A are Disclosure Brochures for the following programs. • Referral Disclosure Brochure – Appendix 1 • Platform Disclosure Brochure – Appendix 1 with the above actions relating to the assets in the Account. However, the Client retains the right to vote proxies and may do so by notifying AssetMark in writing of the desire to vote future proxies. Additionally, this designation of the Discretionary Manager to vote proxies and the Client’s right to vote proxies may not apply to securities that may have been loaned pursuant to a securities lending arrangement despite efforts by AssetMark to retrieve loaned securities for purposes of voting material matters. • AssetMark Retirement Services Disclosure Brochure - Part 2A • AssetMark Bank and Trust Company Platform Disclosure Brochure – Appendix 1 • Efficient Edge Advisory Service – Appendix 1 • Efficient Edge Advisory Service (RetireReady) – Appendix 1 If shares of the Proprietary/Affiliated Funds are held in an Account for which AssetMark acts as Discretionary Manager, AssetMark will vote 100% of the shares over which it has voting authority according to instructions it receives from its Clients, which are the Fund’s beneficial shareholders. AssetMark will vote shares with respect to which is does not receive executed proxies in the same proportion as those shares for which it does receive executed proxies. This is known as “mirror voting” or “echo voting.” Mutual Fund, ETFs, and other Accounts Under the Referral Model, the Client waives the right to vote proxies if the Account is invested in a Mutual Fund or ETF Investment Solution, unless a third party custodian is used, in which case, the client retains the right to vote proxies. This waiver can be rescinded at any time by written notice to AssetMark. The Client retains the right to vote proxies if the Account is an Administrative/Non-Managed Account, including a General Securities Account or Cash Alternative Account. The Proxy Voting Policy is described in detail in the “Referral and Platform Disclosure Brochures.” Class Actions and similar actions In all instances the Client shall make any and all elections with regard to participation in class actions, notices regarding bankruptcies and similar elections. If the Client chooses AssetMark Trust as its Custodian, pursuant to the Custody Agreement, unless they opt out, they authorize AssetMark Trust to act on their behalf and as their agent and contract with a third party for Class Action Services. AssetMark Trust has contracted with Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to provide Class Action Services to AssetMark Trust custodial clients. ITEM 18 – FINANCIAL INFORMATION In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition in this Item. AssetMark has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has never been the subject of a bankruptcy proceeding. Form ADV–Part 2A Disclosure BrochureThis must remain with the Client

EFFECTIVE MARCH 26, 2025 AssetMark Retirement Services Disclosure Brochure Form ADV – Part 2A SEC File Number − 801 56323 IA Firm CRD Number - 109018 ITEM 1 – COVER PAGE This AssetMark Disclosure Brochure provides information about the qualifications and business practices of AssetMark, Inc. (“AssetMark”). If you have any questions about the contents of this Brochure, please contact AssetMark using the above information. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. AssetMark, Inc. is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. AssetMark, Inc. Advisor Compliance 1655 Grant Street, 10th Floor Concord, CA 94520-2445 800-664-5345 assetmark.com Additional information about AssetMark is also available on the SEC’s website at www.adviserinfo.sec.gov. R237_AMRSSvcDsclBrc_2025_03  Page ii ITEM 2 – MATERIAL CHANGES This section provides a summary of material changes that were made to this brochure since the last update. It includes changes to AssetMark’s Retirement Platform and is intended to help Clients determine if they want to review this brochure in its entirety, or contact their Financial Advisor with questions about the changes. AssetMark may make interim updates to this brochure throughout the year. However, you will receive notice of any material changes, which must also be filed with the SEC. To request a copy of the most recent disclosure brochure, write to: ASSETMARK, INC. ATTENTION: ADVISER COMPLIANCE 1655 GRANT STREET, 10TH FLOOR CONCORD, CA 94520 800-664-5345 ASSETMARK.COM ADVISORCOMPLIANCE@ASSETMARK.COM There have been no material changes since the last Form ADV Part 2A update in September 2024. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 1 of 10 ITEM 3 – TABLE OF CONTENTS ITEM 1 COVER PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i ITEM 2 MATERIAL CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii ITEM 3 TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ITEM 4 ADVISORY BUSINESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 ITEM 5 FEES AND COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 7 TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ITEM 9 DISCIPLINARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING . . . . 6 ITEM 12 BROKERAGE PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ITEM 13 REVIEW OF ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ITEM 15 CUSTODY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 ITEM 16 INVESTMENT DISCRETION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 ITEM 17 VOTING CLIENT SECURITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 ITEM 18 FINANCIAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 2 of 10 ITEM 4 – ADVISORY BUSINESS I. IRC 401(k) and IRS 413(e) Retirement Advisory Services DESCRIPTION OF THE COMPANY This Disclosure Brochure describes the advisory services offered by AssetMark, Inc. (“AssetMark”) through its AssetMark Retirement Services (“AMRS”) division to defined contribution retirement plans qualified under Internal Revenue Code (“IRC”) Section 401(k) and to IRC Section 403(b) Client Plans (“Client” or “Client Plans”). ASSETMARK AND ITS OWNERSHIP STRUCTURE AssetMark provides advisory services to defined contribution retirement plans intended to be qualified under Internal Revenue Code of 1986 (“IRC”) Section 401(a) that maintain individual accounts (“Accounts”) for their Participants (generally IRC 401(k) plans). AssetMark also provides advisory services to employers that have been admitted to a pooled employer plan (the “PEP”) that has been established under IRC Section 413(e)and Section 3(43) of Employee Retirement Income Security Act of 1974, as amended, (“ERISA”) and is administered by a registered pooled plan provider (the “Pooled Plan Provider”) within the meaning of Section 3(44) of ERISA and Section 413(e) (3) of the IRC. The Pooled Plan Provider is independent of and not affiliated with AssetMark. AssetMark is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since 1999 providing various investment advisory and consulting services to other advisors and investment Clients. AssetMark and AssetMark Trust Company (“AssetMark Trust”) are wholly owned subsidiaries of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc. is an independent, U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. AssetMark acknowledges that it is providing investment advice to the Client Plan and is a “fiduciary” (within the meaning of section 3(21) of the Employee Retirement Income Security Act of 1974), and accepts appointment as an “investment manager” (within the meaning of Section 3(38) of ERISA) with discretion, in all instances, to the extent that a Client Plan is subject to ERISA and to the extent it provides: i. investment advisory services to Client Plan assets, and ii. in the case of employers admitted to the PEP, to the extent it provides investment advisory services to the Client with respect to the assets in the PEP, that are attributable to employees of the Client. AssetMark Wealth Solutions includes AssetMark’s Asset Management (“AAM”), Due Diligence, Investment Consulting, and other portfolio, wealth, and practice solutions. AAM is responsible for AssetMark’s proprietary investment strategies. If the Client and the Financial Advisor choose a Solution Type (or “Solutions,” described below) managed by AAM, AssetMark is responsible for the management of that Solution Type for the Client’s Account (described below). AssetMark also serves as the investment adviser for the GuideMark Funds and GuidePath Funds (each a “Fund” and collectively the “Proprietary Funds”) available in certain Solution Types on the Platform: 1) GuideMark Funds (no-load sub-advised mutual funds) 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund) AssetMark develops and maintains Investment Alternatives for use by the Client Plans’ Participants and beneficiaries. These Investment Alternatives include individual mutual funds, collective investment trusts (“CITs”) and/or exchange traded funds (“ETFs”) (collectively, “Individual Funds”) and Managed Accounts Solutions (“Solutions”, as described below, see Investment Alternatives). AssetMark provides the investment advisory services in accordance with any reasonable investment restrictions specified by the Client Plan and accepted by AssetMark. AssetMark is responsible for the selection and management of subadvisors for each of the GuideMark Funds. However, the Client and the Financial Advisor, and not AssetMark, are responsible for selecting the Solution Type that uses Proprietary Funds. AssetMark is not registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor, based on its determination that it will rely on certain exemptions from registration provided by the Commodity Exchange Act (“CEA”) and the rules thereunder. The CFTC has not passed upon the availability of these exemptions to AssetMark. AssetMark currently acts as a registered “commodity pool operator” (“CPO”) with respect to the GuidePath Managed Futures Strategy Fund and its wholly owned controlled foreign corporation, the GuidePath Managed Futures Strategy Cayman Fund. AssetMark is registered as a CPO under the CEA and the rules of the CFTC. DESCRIPTION OF THE RETIREMENT ADVISORY SERVICES AssetMark provides various investment advisory services pursuant to Investment Management Services Agreements (“IMSAs”) or Client Services Agreements (“CSAs”) (“Client Agreements”), as described below. AssetMark provides the Solutions through the maintenance of “Asset Allocation Models,” which specify the percentage of specific securities to be held by each Account. AssetMark has contracted with investment management firms (“Portfolio Strategists”) to provide Asset Allocation Models comprised of recommended portfolio allocations. Portfolio Strategists do not provide discretionary investment management services to Accounts. A Client may specify the initial Investment Alternatives to be provided by the Plan to Plan Participants. AssetMark has the authority to replace Investment Alternatives at its discretion. AssetMark has the authority to select, remove and replace securities, including mutual fund, CIT and ETF shares, and other investments, as Investment Alternatives, in Client Plan Accounts, and with regard to the Solution, to determine the portion of assets in the Managed Account that shall be allocated to each fund share, security, investment or asset class and to change such allocations. AssetMark has the authority to remove an Individual Fund or Solution as an Investment Alternative, including but not limited to a Qualified Default Investment Alternative (“QDIA”) and, at its discretion, direct, or not, that Client Plan assets invested in the removed Investment Alternative be moved to another (existing or new) replacement Investment Alternative. AssetMark can also act as a Portfolio Strategist for AssetMark‘s proprietary Investment Alternatives offered to the Client Plans. Information about specific AssetMark Retirement Services Disclosure BrochureThis must remain with the Client  Page 3 of 10 Screened Portfolios (Values Based Portfolios) Investment Alternatives offered to the Client Plans is included in the AssetMark Retirement Services Quarterly Performance Review that can be obtained from the client’s financial advisor. AssetMark does not provide Plan Participants and beneficiaries individualized investment advice. AssetMark does not know the individual investment objectives of Plan Participants and beneficiaries and AssetMark has no responsibility for determining whether any Investment Alternative is suitable for any particular Plan Participant or Client Plan. AssetMark is responsible for determining whether the Investment Alternatives are generally suitable to be investments for Client Plans. AssetMark offers portfolios screened for various values-based considerations (“Screened Portfolios”). Screened Portfolio allocations are typically constructed from mutual funds, but also include Managed Accounts Solutions, individual securities, closed-end funds and exchange traded funds. Mutual funds utilized in Screened Portfolios are selected from a more limited menu of mutual funds than non-screened allocations offered by AssetMark. As a result, risk characteristics and returns of Screened Portfolios could vary significantly from non-screened portfolios. Minimum account sizes for applicable services apply and are subject to negotiation. II. IRC 403(b) Advisory Services AssetMark’s Retirement Services division does not participate in a Wrap Fee program. SERVICES NO LONGER OFFERED AssetMark continues to provide other advisory services which are no longer offered to new Clients. Clients with these services may contact AssetMark for more information. ASSETS UNDER MANAGEMENT Pursuant to Client Agreements, AssetMark provides advisory services to plans intended to be qualified under IRC Section 403(b) that maintain individual accounts (“Accounts”) for their Participants. Pursuant to the Client Agreements, AssetMark acknowledges that it is providing investment advice to the Client Account and is a “fiduciary” (within the meaning of section 3(21) of ERISA) and accepts appointment as an “investment manager” (within the meaning of Section 3(38) of ERISA) with discretion for ERISA, in all instances, to the extent a Plan is subject to ERISA and to the extent it provides investment advisory services to Client Plan assets pursuant to the Client Agreements. As of December 31, 2024, AssetMark had $1.6 billion in assets under management under the Retirement Services division programs. Fidelity 403(b) Portfolios ITEM 5 – FEES AND COMPENSATION The fees described here are for advisory services provided by AssetMark. If a Client engages AssetMark to provide investment advisory services, Client agrees to pay an Investment Advisory Fee based upon a percentage of all assets in the account(s). The Investment Advisory Fee payable under the Client Agreement is comprised of: • A Financial Advisor Fee, which shall compensate the Financial Advisor for its services under the Client Agreement. • A Platform Fee, which shall compensate AssetMark for its services under the Client Agreement. AssetMark provides asset allocation services to participants of 403(b) plans where Fidelity Institutional Wealth Services (“Fidelity”) is an authorized provider under the Participant’s plan. AssetMark provides asset allocation services to participants based upon investment choices made available through the Participants’ plans or through Brokerage Link, if available. Mutual fund options for the Fidelity 403(b) portfolios generally do not include all mutual funds offered by Fidelity, and in most cases, are limited to only certain Fidelity family mutual funds. As a result, risk characteristics and returns of Fidelity 403(b) portfolios could vary significantly from non-Fidelity 403(b) portfolios. AssetMark provides investment advisory services in accordance with any reasonable investment restrictions specified by the Clients’ Plans and accepted by AssetMark. Minimum account size is $50,000 and is subject to negotiation. TIAA CREF – 403(b) Portfolios (closed to new plans) Pursuant to the Client Agreements, Investment Advisory Fees are billed quarterly in advance or in arrears based upon the previous quarter-end values. Fees will be deducted from account assets unless another payment method is otherwise agreed upon in writing by both AssetMark and Client. The initial fee is billed in arrears based on the quarter end market value of the account after the account opening and is pro-rated to the end of the quarter. Should a Client Plan terminate prior to the end of a quarter, a prorated refund will be paid to the Client if fees were assessed in advance. Fee rates are subject to negotiation. AssetMark provides asset allocation services to participants of 403(b) plans where TIAA CREF is an authorized provider under the Participant’s plan. AssetMark provides asset allocation services to participants based upon investment choices made available through the Client Plan. Mutual fund options for the TIAA CREF portfolios typically include all (or almost all) mutual funds offered by TIAA CREF. AssetMark provides investment advisory services in accordance with any reasonable investment restrictions specified by the Clients’ Plans and accepted by AssetMark. Minimum account size is $50,000 and subject to negotiation. All standard account fees are cumulative, tiered and determined based upon investment vehicles utilized, and can be structured on a laddered basis when specified. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client  Page 4 of 10 RETIREMENT SERVICES AND POOLED EMPLOYER PLAN ANNUAL FEES PORTFOLIO ASSETS MAXIMUM RETIREMENT SERVICES PLATFORM FEE MAXIMUM FINANCIAL ADVISOR FEE MAXIMUM TOTAL ACCOUNT FEE 0.30% 1.35% 1.65% $0 - $2,500,000 0.25% 1.35% 1.60% $2,500,000 - $5,000,000 0.20% 1.35% 1.55% $5,000,000 - $10,000,000 NEGOTIABLE NEGOTIABLE NEGOTIABLE $10,000,000 + For the Pooled Employer Plan, advisory fee rates are specified in each participating employer’s CSA or IMSA, however, the tiers applicable to the fee percentages for a participating employer are based on the aggregate total of all participating PEP assets, rather than the assets attributable to the employees of the participating employer. There is no minimum account size. FIDELITY 403(B) PORTFOLIOS ANNUAL FEES PORTFOLIO ASSETS MAXIMUM RETIREMENT SERVICES PLATFORM FEE MAXIMUM FINANCIAL ADVISOR FEE MAXIMUM TOTAL ACCOUNT FEE 0.40% 1.60% 2.00% $0 - $1,000,000 0.35% 1.40% 1.75% $1,000,001 - $3,000,000 0.30% 1.35% 1.65% $3,000,001 + TIAA-CREF 403(B) PORTFOLIOS ANNUAL FEES PORTFOLIO ASSETS MAXIMUM RETIREMENT SERVICES PLATFORM FEE MAXIMUM FINANCIAL ADVISOR FEE MAXIMUM TOTAL ACCOUNT FEE 0.50% 1.50% 2.00% $0 - $1,000,000 0.40% 1.35% 1.75% $1,000,001 - $3,000,000 0.35% 1.35% 1.70% $3,000,001 + Screened Portfolios (Values Based Portfolios) Fees charged by custodians, including, but not limited to, customary brokerage and transaction fees and commissions, odd lot differentials, transfer taxes, transfer fees, exchange fees, termination fees and any other charges imposed by law with regard to Client assets will be deducted from Client portfolio assets. All custody fee details are presented in each Custodian’s fee schedule and separate custody agreement. Typically, mutual fund transactions are effected on a no commission basis. As described in Description of the Retirement Advisory Services, Screened Portfolios are offered under 401(k) and 403(b) advisory services. When Screened Portfolios are used for 403(b) advisory services in conjunction with the Asset Builder service, the minimum fee is $225 and the remainder of the Asset Builder fee schedule applies. When Screened Portfolios are utilized for any other advisory service, the applicable minimums and maximums apply. RECORDKEEPING AND THIRD-PARTY ADMINISTRATION FEES Other When shareholder servicing fees are generated by Client Plan assets, these fees are offset against the account fee payable by the Client Plan. Solutions transactions are effected through Mid-Atlantic Trust Company and Matrix Trust Company, each a custodian. Clients that have engaged AssetMark’s affiliate, AssetMark Services, Inc., to provide recordkeeping and/or third-party administration services to a Plan will be charged fees (“Recordkeeping Fees”) for such services. Clients that permit Plan Participants to make investments through a self-directed account must make arrangements with AssetMark Services, Inc. for the payment of the portion of Recordkeeping Fees attributable to those Participants, which may include debiting the self-directed account. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 5 of 10 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 2. Philosophy – a philosophy that is clearly defined and articulated well. Understanding the foundations to the philosophy and how it has adapted over time is critical. 3. Process – a consistent application of the investment process. Demonstrating how investment decisions were made in multiple market environments and tying the decisions back to the philosophy. Side-by-side management refers to managing accounts that pay performance fees (fees based on a share of capital gains on or capital appreciation of Account assets) while at the same time managing accounts that do not pay performance fees. AssetMark does not charge performance-based fees. 4. Portfolio Construction – rigor in the risk oversight in building the portfolio. A clear discipline and process that shows how risk management is considered in the investment process. ITEM 7 – TYPES OF CLIENTS 5. Performance – The proof statement and purposefully last. The team’s evaluation of the other P’s builds up their expectations of how the strategy should perform. The actual results are used to confirm expectations and to demonstrate how the manager adds value over time. This Disclosure Brochure describes the advisory services offered by AssetMark through its Retirement Services division to IRC Section 401(k) plans, Clients that are employers that have been admitted to a pooled employer plan (“PEP”) that has been established under IRC Section 413(e), and IRC 403(b) plans. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS INVESTMENT ALTERNATIVES For new searches, all findings are reported to the Due Diligence Investment Committee in addition to being reviewed by the Investment Oversight Committee (“IOC”). Once selected for the Platform, the Due Diligence team collects information and can conduct quarterly reviews via conference calls or in person to discuss, among other things, performance, changes to their investment process and philosophy and any material organizational changes at the firm. For ongoing monitoring all findings are reported to the Due Diligence Investment Committee on a quarterly basis, or sooner based on the significance of the findings. In the event of significant news occurring within a quarter, the Due Diligence team is in immediate contact with the Strategist to fully understand the impact of the news. If a change in status is warranted, an interim investment committee meeting will be held and relevant action taken. VALUES BASED PORTFOLIOS AssetMark develops and maintains Investment Alternatives for use by Client Plans’ Participants and beneficiaries. These Investment Alternatives include Individual Funds representing different asset classes, including large-cap equities, small-cap equities, international equities, bonds, and alternative investments, as well as Managed including risk-based portfolios, target-date Accounts Solutions, portfolios, and socially-responsible and faith-based portfolios (see additional information on Values Based Portfolios below). AssetMark provides the Managed Accounts Solutions through the maintenance of “Asset Allocation Models,” which specify the percentage of specific securities to be held by each Account. AssetMark has contracted with Portfolio Strategists to provide Asset Allocation Models comprised of recommended portfolio allocations, and also acts as a Portfolio Investment Alternatives. Strategist for AssetMark‘s proprietary Portfolio Strategists do not provide discretionary investment management services to Accounts. A Client may specify the initial Investment Alternatives to be provided by a Plan to Plan Participants. SELECTION AND DUE DILIGENCE PROCESS FOR PORTFOLIO STRATEGISTS To satisfy exposure to each asset class for socially-responsible portfolios, AssetMark selects from a pool of managers who offer dedicated socially oriented solutions and specifically employ socially responsible factors as a part of their asset selection process. Factors considered for socially-responsible portfolios include both highly desired characteristics (e.g. companies who are good corporate citizens, companies which promote environmentally friendly and minimally disruptive products and use processes which are not damaging to the natural environment), as well as exclusions which are predicated on material business involvement (e.g. companies meaningfully involved in activities related to tobacco products, alcoholic beverages, gambling devices and activities and any corporation who creates, produces, or maintains weapons of war). Each Portfolio Strategist completes a detailed questionnaire (“DDQ”) about their investment process, performance and reporting and risk management, in addition to covering business organization, compliance and ethics, operational framework, and client support. The DDQ is reviewed by AssetMark Due Diligence with compliance and ethics sections also being reviewed by the compliance group. An external third party is used for operational due diligence review. Our due diligence process is deep and thorough and focuses on five key P’s; People, Philosophy, Process, Portfolio Construction and Performance. Consistency in the first four explains performance so the Due Diligence Team spends most of its time understanding the qualitative and quantitative aspects of a Portfolio Strategist and strategy and uses performance as the confirmation of its understanding. The Due Diligence Team seeks the following in the five key P’s: 1. People – stable and tenured teams that have experience managing To satisfy exposure to each asset class for faith-based portfolios, AssetMark selects from a pool of managers who offer dedicated faith- based solutions and specifically employ faith-based factors as a part of their asset selection process. Factors considered for faith based portfolios include both highly desired characteristics (e.g. companies who are good corporate citizens, companies which promote environmentally friendly and minimally disruptive products and use processes which are not damaging to the natural environment), as well as exclusions which are predicated on material business involvement (e.g. companies associated with the production, manufacturing, or distribution of products which are illegal in the United States of America, abortion products and services, pornography, companies meaningfully involved in tobacco products, alcoholic beverages, gambling devices and activities, and embryonic stem cell research). through different market environments. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 6 of 10 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Mutual funds utilized in Personal Values Portfolios are selected from a more limited menu of mutual funds than “traditional” allocations. As a result, and though not expected, risk characteristics and performance returns of Personal Value Portfolios could vary significantly from our traditional Portfolios. Personal Values Portfolios can also be limited to certain investment types and securities and therefore, may not be fully diversified. You may wish to discuss these limitations with your Financial Advisor. Minimum Account sizes for applicable service levels apply and are subject to negotiation. AssetMark is direct subsidiary of AssetMark Financial Holdings, Inc., an independent U.S.-owned private company owned by GTCR, a private equity firm based in Chicago, Illinois. The following companies are under common control with AssetMark. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Their industry activities are described in further detail below: INVESTMENT RISK • Atria Investments, Inc. (d/b/a “Adhesion Wealth Advisor Solutions”) • AssetMark Brokerage, LLC • AssetMark Services, Inc. • AssetMark Trust Company Clients should understand that all investments involve risk (the amount of which vary significantly), that investment performance can never be predicted or guaranteed and that the value of their Accounts will fluctuate due to market conditions and other factors. Any restrictions or screens applicable to the account can adversely affect the performance of your Account. ITEM 9 – DISCIPLINARY INFORMATION Adhesion Wealth Adhesion Wealth is an investment adviser registered with the U.S. Securities and Exchange Commission, currently providing sub- advisory services to other registered investment advisers, either directly or through a third party sponsored program. AssetMark Brokerage, LLC AssetMark Brokerage, LLC (“AssetMark Brokerage”) is a broker-dealer registered with the U.S. Securities and Exchange Commission and is a member of the Financial Industry Regulatory Authority (“FINRA”). AssetMark Services, Inc. AssetMark Services, Inc. provides recordkeeping and administrative services to retirement plans. AssetMark Trust Company AssetMark Trust is an Arizona chartered trust company that serves as the custodian for certain Accounts on the AssetMark Platform. AssetMark also has indirect affiliations with companies under GTCR. AssetMark does not consider such affiliations to create a material conflict of interest for AssetMark or its Clients. Although not affiliated when AssetMark Trust contracted with the Program Administrator for services, AssetMark Trust and the Program Administrator, as described below in the FDIC-Insured Cash Program, are now under common ownership. On September 26, 2023, the SEC issued an Order Instituting Administrative Cease-and-Desist Proceedings against AssetMark. The SEC alleged that, from at least September 2016 through January 2021, AssetMark failed to fully disclose that AssetMark and affiliate AssetMark Trust together set the amount of the payment that AssetMark Trust would retain as compensation from the payment received by the banks that participated in the FDIC-Insured Cash Deposit Program (“ICD Program”) (the “ICD Program Fee”), which, in turn, determined the amount that would be distributed as interest by the banks to clients. The SEC alleged that AssetMark had failed to fully disclose the associated conflicts of interest related to its role in setting the ICD Program Fee. The SEC also alleged that AssetMark, from at least January 2016 through August 2019, did not fully disclose the associated conflicts of interest related to AssetMark’s receipt of custodial support payments from certain no-transaction fee (“NTF”) mutual funds. These failures constituted breaches of AssetMark’s fiduciary duty to advisory clients. The SEC alleged that AssetMark violated Section 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 promulgated thereunder. AssetMark consented to the Order without admitting or denying the SEC’s findings. Some employees of AssetMark are also shared with affiliated entities. This presents potential conflicts around the sharing of client’s personal information, trading practices, and supervision. To mitigate these conflicts, the Company has policies in place to supervise and monitor the activities of these shared employees. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING On August 25, 2016, the SEC announced a settlement with AssetMark in an order containing findings, which AssetMark neither admitted nor denied, that AssetMark violated Section 206(4) of the Advisers Act and Rule 206(4)-1(a)(5) by allowing its staff, from July 2012 through October 2013, to circulate to prospective Clients who were considering an F-Squared managed account service offered by AssetMark, performance advertisements created by F-Squared relating to a different separately managed account service not offered by AssetMark and that misleadingly described that different service’s performance between 2001 and 2008, and that AssetMark violated Section 204(a) of the Advisers Act and Rule 204-2(a)(16) by failing to maintain records substantiating the performance in the advertisements created by F-Squared. There are no disciplinary items to report for the management of AssetMark. AssetMark has adopted a Code of Ethics (the “Code”) that is intended to comply with the provisions of Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”), which requires each registered investment adviser to adopt a code of ethics setting forth standards of conduct and requiring compliance with federal securities laws. Additionally, the Code is designed to comply with Section 204A of the Advisers Act, which requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by any person associated with such investment adviser. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 7 of 10 Client Plan Accounts may be monitored for excessive and other forms of abusive trading and may be subject to administrative procedures and/or restrictions developed by the funds in which the Accounts are invested or by such funds’ service providers and implemented by the funds or their service providers at the direction of funds. These policies may take the form of redemption fees and/or purchase block or other trade restrictions. AssetMark makes no representation regarding policies and procedures of the funds included as Investment Alternatives. For further information on redemption fees or trade restrictions, including whether one will be applicable to an individual Investment Alternative for the Plan, please consult the individual fund prospectuses or other Investment Alternative disclosure material. The Code requires that all “Supervised Persons” (including officers and certain affiliated persons and employees of AssetMark) in carrying out the operations of AssetMark, adhere to certain standards of business conduct. Specifically, the Code requires that these persons: (i) comply with all applicable laws, rules and regulations, (ii) avoid any conflict of interest with regard to AssetMark and its Clients, (iii) avoid serving their personal interests ahead of the interests of AssetMark and its Clients, (iv) avoid taking inappropriate advantage of their position with AssetMark or benefiting personally from any investment decision made, (v) avoid misusing corporate assets, (vi) conduct all of their personal securities transactions in compliance with the Code, and (vii) maintain, as appropriate, the confidentiality of information regarding AssetMark’s operations. 403b – Pursuant to a separate agreement, each individual Participant Account’s Custodian will provide custodial account and brokerage services to the Client. On Asset Allocation Models, for contributions, rebalancing, and liquidation needs, AssetMark calculates the value of purchases and sells based on the current model allocation percentages. The account Custodian shall be responsible for all trading and AssetMark shall not be responsible for the selection of brokers and dealers and the execution of transactions for the Accounts. AssetMark makes no representation regarding, and shall not be responsible for, any trading expenses, including any redemption fees associated with the Accounts or Investment Alternatives. RESEARCH AND SOFT DOLLAR PRACTICES AssetMark does not utilize soft dollars. The Code contains a number of prohibitions and restrictions on personal securities transactions and trading practices that are designed to protect the interests of AssetMark and its Clients. First, the Code prohibits trading practices that have the potential to harm AssetMark and/or its Clients, including excessive trading or market timing activities in any account that AssetMark manages, trading on the basis of material non-public information, and trading in any “Reportable Security” when they have knowledge the security is being purchased or sold, or is being considered for purchase or sale by the Accounts managed by AssetMark or any AssetMark-advised mutual funds. Second, the Code mandates the pre-clearance of certain personal securities transactions, including transactions in securities sold in initial public offerings or private placements. The Code also requires the pre-clearance of Reportable Security transactions for certain Access Persons (Access Persons is a segment of the Supervised Persons group that have access to AssetMark information). Finally, the Code requires Access Persons to submit, and the Chief Compliance Officer (the “CCO”) to review, initial and annual holdings, and quarterly transaction reports. AssetMark utilizes various institutional platform services provided by Fidelity, Mid Atlantic Trust Company, TIAA CREF and Matrix Trust Company, which provide capabilities that AssetMark may use in managing and administering Client Plan Accounts custodied at those firms. Specifically, these services: (i) provide access to Client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple Client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from Clients’ accounts; and (v) assist with back-office functions, recordkeeping and Client reporting. AssetMark utilizes StarCompliance to provide enhanced tracking of certain employee transactions and gives AssetMark the ability to analyze those employee trades against certain parameters and transactions in its managed Accounts or any AssetMark-advised funds. Access Persons also utilize this system to annually certify their receipt of, and compliance with, the Code and pre-clear their Reportable Security transactions, if they are required to do so by the Code. All Supervised Persons under the Code are responsible for reporting any violations of the Code to the CCO. The Code directs the CCO to submit reports to the Board of Trustees of any AssetMark-advised mutual funds regarding compliance with the Code, and to impose sanctions on violators, as warranted. Fidelity, Mid Atlantic Trust Company, TIAA CREF and Matrix Trust Company also offer other services including, but not limited to, performance reporting, financial planning, contact management systems, third party research, publications, access to educational conferences, roundtables and webinars, practice management resources, access to consultants and other third-party service providers who provide a wide array of business related services and technology with whom AssetMark contracts directly. AssetMark will provide a copy of the Code to any Client or prospective Client upon request. Although AssetMark may receive Clients from referrals made by broker-dealers, it does not recommend or select any broker-dealer based upon any Client referrals from such broker-dealers. Custodians provide brokerage services to Clients. ITEM 12 – BROKERAGE PRACTICES DIRECTED BROKERAGE AssetMark Retirement Services does not allow directed brokerage. 401K – Pursuant to a separate agreement, the Retirement Services Plan’s Custodian will provide custodial account and brokerage services to the Client. The Plan’s Custodian and/or other service provider to the Plan other than AssetMark shall be responsible for all trading, including the application of any asset allocation models to the Accounts by purchasing and/or selling securities for the Accounts. AssetMark shall not effect transactions in securities for Accounts and shall not be responsible for the selection of brokers and dealers and the execution of transactions for the Accounts. AssetMark makes no representation regarding, and shall not be responsible for, any trading expenses, including any redemption fees associated with the Accounts or Investment Alternatives. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 8 of 10 ITEM 13 – REVIEW OF ACCOUNTS Client of the Financial Advisor, ii) the Financial Advisor cannot hold an officer position on the charitable organization’s board or direct funds at the charitable organization, and iii) the charitable organization must not have the ability to contribute funds or services to a candidate for public office or to a Political Action Committee. There is no direct compensation paid to an honored Financial Advisor. However, the Financial Advisor has an incentive to place, or retain Client assets on the Platform as a result of AssetMark’s contribution to their supported charitable organization. AssetMark does not assign Client Plans directly to specific individuals for investment supervision, and there is no single individual or team within the organization that can be identified as being solely responsible for implementing a full set of review criteria on any one Client Plan. Instead, AssetMark offers a Platform of Investment Alternatives to its Client Plans. At the model level, three groups are responsible for ensuring that the investment models to which Client Plans are linked are consistent with the guidelines and investment Strategy selected by the Client Plan. AssetMark Asset Management (“AAM”) creates and maintains the proprietary investment alternatives available. The Due Diligence team reviews the model recommendations provided by the Portfolio Strategists. The Trade Operations Group monitors account adherence to models provided by Strategists and adherence to models created and maintained by AAM. Clients that are invested in solutions or assets outside of the AMRS Investment Alternatives should refer to their Financial Advisors to discuss and assess their current financial situation, investment needs and future requirements to implement and monitor investment portfolios designed to meet the Client’s financial needs. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Financial Advisory Firms receive fees for their services and compensation from AssetMark for referrals of Clients, as described above under Financial Advisor Fee. Therefore, they have a financial incentive to recommend the AssetMark program over other programs or services, which creates a conflict of interest on the part of the Financial Advisory Firms. Direct and Indirect Support for Financial Advisors AssetMark sponsors annual conferences for participating Financial Advisory Firms and/or Financial Advisors designed to facilitate and promote the success of the Financial Advisory Firm and/or Financial Advisor and/or AssetMark advisory services. AssetMark offers Portfolio Strategists, Investment Managers and Investment Management Firms, who in some cases also are Sub-Advisors for the GuideMark and GuidePath Funds, the opportunity to contribute to the costs of AssetMark’s annual conferences and be identified as a sponsor. AssetMark covers travel-related expenses for certain Financial Advisors to attend AssetMark’s annual conferences, quarterly meetings or to conduct due diligence visits. In addition to, and outside of the Advisor Benefits Program, AssetMark contributes to the costs incurred by Financial Advisors in connection with conferences or other Client events conducted by the Financial Advisor or the Financial Advisory Firm. AssetMark also solicits research from Financial Advisors regarding new products or services that AssetMark is considering for Clients. In exchange for this feedback and guidance, AssetMark can offer an incentive to the Financial Advisor for their attendance at, or participation in, for example, an online survey or an in-person focus-group. These programs create financial incentives for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. In addition to the compensation payable under the Client Agreement, AssetMark enters into other arrangements with certain Financial Advisory Firms and/or Financial Advisors as described below. Such arrangements will not increase the fees payable under the Client Agreement by the Client. However, Client’s should review and understand that these arrangements can be deemed to cause a conflict of interest because they provide Financial Advisory Firms and Financial Advisors with incentives to place and retain Client assets on the AssetMark program. Discounted Fees for Financial Advisors Financial Advisors can receive discounted pricing or complimentary subscriptions from third-party service providers or from AssetMark or its affiliates for services such as business consulting, practice management, technology, financial planning tools and marketing- related tools and services because of their participation in the Platform. In certain cases, AssetMark receives a portion of the subscription fees paid by Financial Advisors to such third-party service providers. Discounted pricing and complimentary subscriptions can be subsidized by AssetMark. These arrangements create a financial incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. Advisor Benefits Program for Financial Advisors Under AssetMark’s Advisor Benefits Program, Financial Advisors have the option to utilize AssetMark’s advisor-directed tools, templates and best practices, or to engage with AssetMark to receive business and investment consulting, and/or, education and guidance for implementing a growth plan for their businesses. Certain Financial Advisors can receive an allowance or “growth support” for reimbursement of qualified expenses incurred by the Financial Advisor based on their participation in AssetMark sponsored events, marketing initiatives, or use of technology resources and tools. Financial Advisors can also receive benefits by reaching certain levels, or tiers, on the AssetMark Platform. This program creates a financial incentive for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. Loans by AssetMark to Financial Advisory Firms AssetMark and its affiliates have made loans on a selected basis to some Financial Advisory Firms, and will continue to do so. These financing arrangements result in additional revenue to AssetMark (primarily interest earned on those loans) and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has borrowed money from AssetMark and that still has a loan balance outstanding will have an incentive to continue using AssetMark’s products and services for its Clients even when AssetMark’s services can be more expensive or less appropriate for the Client. Therefore, these loans can create a conflict of interest for Financial Advisory Firms between their own financial interests and the interests of their Clients. Payment for testimonials/endorsements Financial Advisors may provide video, audio or documented statements endorsing AssetMark, and AssetMark may compensate the Financial Advisors for these. Community Inspiration Award In order to promote community involvement, AssetMark created the Community Inspiration Award to honor selected Financial Advisors across the United States who have inspired others by supporting charitable organizations in their communities. AssetMark will make a cash donation, subject to the published rules governing the program, to the Financial Advisor’s nominated charity in accordance with the following: i) the charitable organization is not a Client or prospective AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 9 of 10 A reasonable amount of time is needed to process requests and for transactions, and account assets may continue to be impacted by market exposure until each request is complete. Time periods experienced for previous requests may not be available and should not be relied upon. Negotiated Fees AssetMark is permitted, in its discretion, to negotiate the Platform Fee for Clients of certain Financial Advisors. Certain Financial Advisors with higher aggregate levels of assets on the Platform are eligible for negotiated fees, which are passed through to the Client. The Financial Advisor does not earn additional compensation as a result of these negotiated fees. These arrangements create an incentive for Financial Advisory Firms and their representatives to recommend that Clients invest assets through the AssetMark Platform. AssetMark makes available periodic account statements in the form of a Quarterly Performance Review Report. Clients are urged to carefully review these statements and reports, and compare any statements or reports provided by AssetMark with the statements provided by the Custodian to ensure account transactions, including fee deductions, are accurate. Client shall immediately report any errors, and AssetMark shall not be liable for losses from errors that remain unreported for more than 10 days. Pilot and Early Release Programs AssetMark can invite certain Financial Advisor Firms to participate in pilot or early release programs designed to solicit feedback on new product or service offerings. In exchange for participation in these programs, AssetMark may provide certain incentives to the Financial Advisor Firms such as fee waivers, or other incentives. ITEM 16 – INVESTMENT DISCRETION Strategist Fees In circumstances where a Financial Advisory Firm uses a Portfolio Strategist to assist in the management of a Client’s account, AssetMark will pay a strategist fee on a selected basis to the Financial Advisory Firm for use and monitoring of the model portfolio recommended by the Portfolio Strategist. This strategist fee creates a conflict of interest because the Financial Advisory Firm has an incentive to use the model portfolios produced by a Portfolio Strategist in order to keep receiving the fee, compared to other arrangements that might be less expensive or more appropriate for the Client. Transitions Program for Financial Advisory Firms AssetMark and its affiliates may enter into business arrangements designed to assist Financial Advisory Firms with succession planning, and will continue to do so. These financing arrangements result in additional revenue to AssetMark and they create certain conflicts of interest for Financial Advisory Firms. A Financial Advisory Firm that has agreed to share a portion of their Firm’s revenue with AssetMark will have an incentive to continue using AssetMark’s products and services for its Clients even when AssetMark’s services can be more expensive or less appropriate for the Client. Therefore, these business arrangements can create a conflict of interest for Financial Advisory Firms between their own financial interests and the interests of their Clients. AssetMark provides the Solutions through the maintenance of “Asset Allocation Models,” which specify the percentage of specific securities to be held by each Account. AssetMark has contracted with investment management firms (“Portfolio Strategists”) to provide to AssetMark Asset Allocation Models of recommended portfolio allocations which AssetMark makes available as Investment Alternatives to Clients, unless circumstances indicate that modified allocations or investments are appropriate. The Portfolio Strategists do not provide discretionary investment management services to Accounts. The Client may specify the initial Portfolio Strategist for the Account. AssetMark has the authority to replace the Portfolio Strategist at its discretion. AssetMark has the authority to select, remove and replace securities, including mutual fund and ETF shares, and other investments, as Investment Alternatives, in Client Plan Accounts, and with regard to the Managed Accounts Solutions, to determine the portion of assets in the Solution that shall be allocated to each fund share, security, investment or asset class and to change such allocations. AssetMark has the authority to remove an Individual Fund or Managed Account Solution as an Investment Alternative, including but not limited to a Qualified Default Investment Alternative (“QDIA”) and, at its discretion, direct, or not, that Client Plan assets invested in the removed Investment Alternative be moved to another (existing or new) replacement Investment Alternative. AssetMark can also act as a Portfolio Strategist for AssetMark‘s proprietary Investment Alternatives offered to the Client Plans. ITEM 15 – CUSTODY ITEM 17 – VOTING CLIENT SECURITIES A. AssetMark will not vote proxies for accounts receiving services through the Retirement Services Division. B. Client will receive their proxies or other solicitations directly the custodian and AssetMark will not assist with from voting responsibilities. In all instances the Client shall make any and all elections with regard to participation in class actions, notices regarding bankruptcies and similar elections. AssetMark does not provide custodial services to its Clients. The Client Plan shall establish a relationship with an “Administrator,” for the provision of participant recordkeeping and plan administrative services, and a relationship with a qualified “Custodian,” to hold custody of Client Plan assets and provide related services. Although AssetMark does not recommend any Administrator, Custodian or other service provider, it is anticipated that EPIC Retirement Plan Services,PCS Retirement, LLC, July Business Services, LLC or Ascensus will act as Administrator and Mid Atlantic Trust Company, Matrix Trust Company or Fidelity (403(b) Plans only) will act as Custodian, unless Client Plan establishes relationships with other parties that have established the systems links needed for AssetMark to provide the advisory services contemplated by this Agreement. Clients receive monthly or quarterly account statements from their Custodian showing account activity for that period, as well as all positions held in the account at period end. Client may also receive confirmations of transactions that occur within the account. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client Page 10 of 10 ITEM 18 – FINANCIAL INFORMATION In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition in this Item. AssetMark has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has never been the subject of a bankruptcy proceeding. AssetMark Retirement Services Disclosure BrochureThis must remain with the Client