MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED

Advice Access BROCHURE Please retain for your records. Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 (800) 637-7455 (Main) (866) 731-3127 (Program) www.ml.com (Main) www.benefits.ml.com(Program) This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“Merrill” or “MLPF&S”) relating to Advice Access, an online investment advisory program. If you have any questions about the contents of this Brochure, please contact us at (866) 731-3127. Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about MLPF&S also is available on the SEC’s website at www.adviserinfo.sec.gov. The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency, are not a deposit or other obligation of or guaranteed by MLPF&S, Bank of America Corporation (“BofA Corp.”) or any of its affiliates; and are subject to investment risks, including possible loss of principal. March 21, 2025 Workplace Benefits is the institutional retirement and benefits business of Bank of America Corporation (“BofA Corp.”) operating under the name “Bank of America.” Investment advisory and brokerage services are provided by wholly owned non-bank affiliates of BofA Corp., including Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as "MLPF&S" or "Merrill"), a dually registered broker-dealer and investment adviser and Member SIPC. Banking activities may be performed by wholly owned banking affiliates of BofA Corp., including Bank of America, N.A., Member FDIC. Investment products: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value  Advice Access Brochure MATERIAL CHANGES On March 22, 2024, MLPF&S filed its last annual update for its Advice Access brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated the “Disciplinary Information” section to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and- desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our Financial Advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. Please refer to CLIENT REFERRALS AND OTHER COMPENSATION – Third-Party Firm Office Access, Gifts And Entertainment. MATERIAL CHANGES MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes • We updated the “Disciplinary Information” section to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” i  Advice Access Brochure TABLE OF CONTENTS MATERIAL CHANGES .......................................................................................................................................................................... I ADVISORY BUSINESS ......................................................................................................................................................................... 1 ADVICE ACCESS Summary Description of Services Investment Advisory Agreement IMPLEMENTATION OPTIONS PersonalManager PersonalManager as the Plan’s Qualified Default Investment Alternative (QDIA) Separation from Service(fiduciary) Portfolio Rebalancing One-Time Implementation Electronic Accessibility Requirement FINANCIAL EXPERT RECOMMENDATIONS Necessary Data Recommendations Made Other Merrill Advisory Services ..................................................................................................................................................................................... ..................................................................................................................................................... ...................................................................................................................................................... ................................................................................................................................................................ ............................................................................................................................................................................. .......................................................................... ................................................................................................................................................... ....................................................................................................................................................................... ............................................................................................................................................................... ................................................................................................................................................ ................................................................................................................................................................................ ........................................................................................................................................................................... ................................................................................................................................................................................. .................................................................................................................................................................. ........................................................................................................................................................ ............................................................................................................................................................. ASSETS UNDER MANAGEMENT 1 1 2 2 2 2 3 3 4 4 4 5 5 5 6 6 FEES AND COMPENSATION ............................................................................................................................................................... 6 PERSONALMANAGER FEES CALCULATION OF THE PERSONALMANAGER FEE Plan Sponsor: Participant: PAYMENT OF PERSONALMANAGER FEE Plan Sponsors Participants ................................................................................................................................................................... .................................................................................................................................. .................................................................................................................................................................................... ....................................................................................................................................................................................... ............................................................................................................................................... ................................................................................................................................................................................... ...................................................................................................................................................................................... .................................................................................................................................................................. .......................................................................... .......................................................................................................................................................................... OTHER FEES AND EXPENSES COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS SOURCES OF REVENUE 6 7 7 7 7 7 7 8 8 8 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................................................................................................... 8 TYPES OF CLIENTS ............................................................................................................................................................................. 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................................................................ 8 ................................................................................................................................................................... INVESTMENT PHILOSOPHY FINANCIAL EXPERT’S GOVERNANCE KEY DATA SOURCES KEY ASSUMPTIONS RISK OF LOSS AND STRATEGY RISK General Risks Associated with Investments Strategy Risk Hypothetical Nature of Forecasts Financial Expert’s Advice and Investment Recommendations ................................................................................................................................................... ............................................................................................................................................................................. ............................................................................................................................................................................. ...................................................................................................................................................... .................................................................................................................................... ................................................................................................................................................................................... ................................................................................................................................................... . ...................................................................................................... ....................................................................................................................................................................... ................................................................................................................... ........................................................................................................................................ 9 10 10 10 11 11 12 13 13 14 14 15 EMPLOYER SECURITIES MATERIAL RISKS FOR PARTICULAR TYPES OF SECURITIES INFORMATION AND CYBERSECURITY RISKS DISCIPLINARY INFORMATION ......................................................................................................................................................... 16 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................................................................................... 17 ii  Advice Access Brochure CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .......................................... 18 ......................................................................................................................... .................................................................................................................................................................................. .............................................................................................................................................................. ................................................................................................................... ...................................................................................................... CONFLICTS OF INTEREST AND INFORMATION WALLS CODE OF ETHICS PRIVACY/DATA PROTECTION PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS INVESTMENTS IN SECURITIES BY MERRILL AND OUR PERSONNEL 18 19 19 19 21 BROKERAGE PRACTICES .................................................................................................................................................................. 22 REVIEW OF ACCOUNTS ................................................................................................................................................................... 22 ONGOING MONITORING OF PORTFOLIO MODELS .............................................................................................................................. 22 CLIENT REFERRALS AND OTHER COMPENSATION ........................................................................................................................... 23 ........................................................................................................................................ 23 RELATIONSHIPS WITH THIRD-PARTY FIRMS PARTICIPATION AND SPONSORSHIP BY THIRD-PARTY FIRMS FOR MERRILL CONFERENCES, MANAGER MEETINGS AND CHARITABLE EVENTS THIRD-PARTY FIRM OFFICE ACCESS, GIFTS AND ENTERTAINMENT ................................................................................................................................................................................................ ..................................................................................................... 23 24 CUSTODY ........................................................................................................................................................................................ 25 INVESTMENT DISCRETION .............................................................................................................................................................. 25 VOTING CLIENT SECURITIES ............................................................................................................................................................ 25 FINANCIAL INFORMATION .............................................................................................................................................................. 25 GLOSSARY ....................................................................................................................................................................................... 25 All capitalized terms used in the Brochure are defined in the body of this Brochure and/or in the Glossary. iii  Advice Access Brochure This Brochure relates to the Advice Access program (the “Program”) offered by Merrill, Pierce, Fenner & Smith Incorporated (referred to in this Brochure as “Merrill”, “MLPF&S”, “we”, “our” or “us”). For purposes of this Brochure, “participant”, “their”, or “his or her” refers to the Plan participants and “Plan refers to the participant-directed defined contribution plan maintained by the Plan Sponsor, or as applicable, the designee or other named fiduciaries of the Plan Sponsor (“Plan Sponsor”) utilizing Merrill’s record keeping platform and enumerated in the Advice Access Agreement. Employer refers to the employer of the participant. Advice Access is an online investment advisory program available to participant-directed defined contribution Plans that utilize Merrill for recordkeeping services. Effective April 1, 2023, no new enrollment of Plans will be accepted into the Advice Access program. All capitalized terms are defined in the body of this Brochure and/or in the Glossary, which can be found at the end of this Brochure. ADVISORY BUSINESS Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a global financial services firm that offers a broad range of brokerage, investment advisory, retail and other services. Merrill is registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer and has been registered as an investment adviser since 1978. Investment advisory and brokerage services are separate and distinct, and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences. It is important to understand the differences, particularly when determining which service or services to select. ADVICE ACCESS When providing services in this Program we acknowledge in the Advice Access Agreement our status as an investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”) and a fiduciary under section 3(21)(A)(ii) of ERISA with respect to providing the investment advisory services of Advice Access. Summary Description of Services Plan Sponsors that make Advice Access available to Plan participants enter into an investment advisory agreement with us (“Advice Access Agreement”). Advice Access will recommend an asset allocation and specific investments for the participant’s Plan account, a contribution rate in the Plan, a contribution rate outside the Plan (if needed), and a retirement age that targets a 70% or higher likelihood of generating annual retirement income to meet or exceed their Annual Retirement Income Goal. Advice Access considers participants’ current investments held within the Plan, salary, savings rate, and their likelihood of achieving a specified annual retirement income. Advice Access will also recommend whether contributions should be made in the form of pre-tax contributions, Roth after-tax contributions, or after-tax contributions, depending on Plan availability and based upon a participant’s current effective tax rate and their estimated effective tax rate in retirement. After reviewing the recommendations provided by Advice Access, the participant can either reject the recommendations or implement them using the following enrollment options: • PersonalManager • Portfolio Rebalancing • One-Time Implementation A more detailed description of the Program enrollment options is provided elsewhere in this Brochure, along with other material information about Merrill. 1 AA2A 03-25  Advice Access Brochure Participants may modify certain variables within the client profile page of Benefits OnLine and can obtain navigational support by contacting the Retirement & Benefits Contact Center. When a participant enrolls in the program, Advice Access will only provide advice and recommendations on the participant’s account record kept by Merrill and not any external assets or accounts. The recommendations provided by Advice Access will take into account any restrictions or limitations you may wish to impose on the sale of certain securities or current holdings within your Plan account (“Restricted Assets”). The Plan Sponsor may also require certain employer securities to be treated as Restricted Assets. If a Plan Sponsor allows a participant to maintain a self-directed brokerage account within the Plan, assets in that account will similarly be considered Restricted Assets. Restricted Assets will be considered for purposes of a participant’s overall asset allocation. However, Merrill does not provide any advice or recommendations with respect to Restricted Assets, and they will not be included in PersonalManager, Portfolio Rebalancing or One- Time Implementation services offered through Advice Access. Advice Access also provides a “Retirement Income Strategy” which is a recommended breakdown of a participant’s retirement income (for example, 401(k) accounts, Social Security, pensions and additional retirement accounts) during retirement. The Retirement Income Strategy considers the optimal annual drawdown sequence of each source based on the relative tax efficiency, meaning it will make a recommendation on how much and when to withdraw funds from certain sources to maximize portfolio longevity and meet the “Achievable Retirement Income” proposed. Before utilizing this Program, please review this Brochure carefully and log on to Benefits OnLine or contact the Merrill call center if you have any questions. Investment Advisory Agreement The scope of any investment advisory relationship we have with the Plan Sponsor is defined in the Advice Access Agreement signed by the Plan Sponsor with respect to the Program. Through Advice Access, Merrill acts as the Plan’s investment adviser only for the Plan covered by Advice Access, and not for any other assets or accounts (including any other employee benefit Plans), unless otherwise separately agreed to by us in writing. Our advisory relationship with the participant begins when they enroll in PersonalManager, Preliminary discussions or illustrations before accepting the terms and conditions of Advice Access are not intended as investment advice and should not be relied upon as such. IMPLEMENTATION OPTIONS PersonalManager PersonalManager is the discretionary managed account feature of Advice Access that takes into account the participant’s personal information described above and will invest the participant’s Plan account into the recommended asset allocation. Approximately every 90 days on the anniversary of the participant’s day of birth, and approximately every 90 days thereafter Advice Access will review the participant’s account for refreshed information. Upon review, PersonalManager will update the participant’s investment recommendation (referred to as “Reallocation”). Simultaneous to the reallocation of a participant’s assets PersonalManager will also rebalance the participant’s account to adjust for investment gains and losses across the asset classes (referred to as “Rebalancing”). Should there be other factors that impact the rebalance, rebalancing will occur once those factors are resolved. The participant may discontinue PersonalManager at any time. PersonalManager as the Plan’s Qualified Default Investment Alternative (QDIA) A default Investment alternative is the investment chosen by the plan fiduciary into which a Plan participants’ or employer contributions will be invested if the participant does not make an affirmative investment election. ERISA provides plan fiduciaries with certain protection from liability for assets invested in a “qualified default investment alternative” (“QDIA”) on behalf of participants who have not made an affirmative investment election. 2 AA2A 03-25  Advice Access Brochure A Plan Sponsor can select PersonalManager as the Plan’s default investment. As new contributions are received, participants will automatically be enrolled into PersonalManager and both their existing assets and future contributions will be invested according to the recommendations. Participants can affirmatively elect to discontinue PersonalManager at any time. Advice Access will use relevant Plan participant data, including current annual compensation and other indicative data that is supplied directly by the Plan Sponsor to implement personalized investment recommendations for the participant. If the Plan Sponsor fails to provide the necessary compensation and indicative data, the participant will not be enrolled in PersonalManager; instead, the participant’s investments will be invested in a cash equivalent fund indefinitely until the data is received. For Plans enrolled in Fiduciary Advisory Services (FAS) and using discretionary services, Plan Sponsors may not select PersonalManager as the Plan’s QDIA. Separation from Service (fiduciary) If a participant is: (1) enrolled in PersonalManager, (2) subsequently separates from service from the employer, and (3) has an account balance greater than $25.00, the participant will need to update their personal profile information, current employment status, and annual income amount in order to continue to receive a personalized investment allocation through PersonalManager. If the participant does not provide us with updated employment and income information, Advice Access will no longer be able to provide the participant a personalized investment allocation. In such cases, Advice Access will continue to rebalance the participant’s account on a quarterly basis to the last asset allocation that was recommended to the participant prior to their separation from service. Advice Access will continue to rebalance the participant’s account for the four scheduled quarterly rebalances following their date of termination or until the participant updates their personal profile information. If the participant updates their profile information, PersonalManager will resume discretionary management of the participant’s account by considering their entire profile. If the participant has not updated their information by the fifth quarterly rebalance they will no longer be enrolled in PersonalManager and Advice Access will reallocate the participant’s account balance into a diversified multi- asset portfolio. Upon termination from Personal Manager, their account will no longer be reallocated or rebalanced. If a participant is: (1) enrolled in PersonalManager or Portfolio Rebalancing (discussed below), (2) subsequently separates from service from their employer, and (3) has an account balance less than $25.01, they will no longer be enrolled in PersonalManager and their accounts will no longer be reallocated or rebalanced. The participant’s account balance will be placed in a diversified multi-asset portfolio. Portfolio Rebalancing A non-discretionary enrollment option that allows participants to implement the specific asset allocation and investment recommendations provided by Advice Access with respect to their account. Future contributions will be allocated to the investments according to the investment recommendations, using the allocation percentages Advice Access recommends. Approximately every 90 days from the anniversary of a participant’s day of birth and every 90 days thereafter, the investments in the participant’s account will be rebalanced to the initial recommended allocation. Should there be other factors that impact the rebalance, rebalancing will occur once those factors are resolved. There will be no periodic review of the participant’s information, nor will there be a reallocation of the participant’s assets into a different investment allocation if new data is supplied. It is the participant’s responsibility to periodically revisit Advice Access and determine whether the last investment allocation recommended by Advice Access remains appropriate based upon their current information. Participants can discontinue Portfolio Rebalancing at any time or elect another implementation option. Neither Merrill nor the Financial Expert shall have any ongoing fiduciary or other responsibility for the asset allocations and investments after the initial recommendation has been provided by Advice Access. Participants may also use Portfolio Rebalancing to implement asset allocation and investment selections they have constructed through the “Create Your Own Strategy” feature of Advice Access. These portfolios are not provided by Advice Access, but rather are developed by the participant. Participants may elect this 3 AA2A 03-25  Advice Access Brochure option for ongoing periodic rebalancing of their investment selections. Neither Merrill nor the Financial Expert shall have any fiduciary or other responsibility for asset allocations and investments the participant selects that have not been provided by Advice Access. If a Plan Sponsor adopting Advice Access chooses to discontinue the offering of another asset allocation or model portfolio option, the participants who do not discontinue the asset allocation or portfolio model option on their own volition after receiving advance notice of the elimination of the option will be treated as follows: Any participant with a 100% investment allocation in any portfolio models for both existing funds and future Plan contributions will automatically be transferred out of the portfolio model into the underlying funds that make up said model. The participant will be automatically enrolled into Portfolio Rebalancing through the “Create Your Own Strategy” feature of Advice Access. Such participants’ assets will be periodically rebalanced pursuant to Advice Access Portfolio Rebalancing. Unlike the previous portfolio models, participant allocation percentages among the funds will not be subject to modifications by the Plan Sponsor. As such, neither Merrill nor the Financial Expert shall have any fiduciary or other responsibility for the asset allocations and investments established through this process. Any participant with an investment allocation in the portfolio model for existing funds or future Plan contributions that is less than 100% will automatically be transferred out of the portfolio model into the underlying funds that make up the portfolio model, but they will not be automatically enrolled into the Portfolio Rebalancing option of Advice Access. As such, they will receive no further rebalancing unless they subsequently affirmatively elect to participate in Advice Access. One-Time Implementation A non-discretionary enrollment option that allows participants to implement the specific asset allocation and investment recommendations provided by Advice Access with respect to their account. Future contributions will also be allocated to the investments according to the investment recommendations, using the allocation percentages Advice Access recommends. However, under this option, the participant’s account will neither be automatically reallocated or rebalanced. There will be no periodic review of the participant’s information, nor will there be a reallocation of the participant’s assets into a different investment allocation if new data is supplied. It is the participant’s responsibility to periodically revisit Advice Access and determine whether the last investment allocation implemented by the participant remains appropriate based upon current information, and to rebalance the account. Participants can also use the One-Time Implementation option to implement asset allocation and investment selections they have constructed through the “Create Your Own Strategy” feature of Advice Access. Neither Merrill nor the Financial Expert shall have any fiduciary or other responsibility for asset allocations and investments the participant selects that have not been provided by Advice Access. Electronic Accessibility Requirement Online: Plan participants may use Advice Access by providing relevant information, receiving the recommendations and implementing such recommendations on the Benefits OnLine website, www.benefits.ml.com. Service Representatives: Plan participants will also have access to a Retirement & Benefits Contact Center Representative (“Service Representative”) through a Merrill call center. These Service Representatives are able to provide information about Advice Access and assist with navigational support. Service Representatives will not provide any investment recommendations or advice regarding the participant’s Plan retirement assets or the appropriateness of PersonalManager. FINANCIAL EXPERT 4 We have selected a Financial Expert as defined under the Department of Labor’s Advisory Opinion 2001-09A (the “Financial Expert”) that is responsible for constructing strategic asset class models and fund specific portfolios using the investment options determined by each Plan Sponsor. The Financial Expert has not been, and will not be, involved AA2A 03-25  Advice Access Brochure in any other relationship with us that would compromise the Financial Expert’s independence. We may provide the Financial Expert certain objective information required for the development of the portfolio models, such as fund returns, fact sheets, and other relevant materials. The Financial Expert may consider these materials and may also consider the materials of others in developing the portfolio models and recommendations. Ultimately, it is the Financial Expert who retains sole control and discretion for the development and maintenance of the portfolio models. Morningstar Investment Management LLC is the current Financial Expert utilized by Advice Access. We may replace the Financial Expert at our sole discretion and will provide notification to the Plan participants and Plan Sponsors. Additional information about Morningstar Investment Management LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. RECOMMENDATIONS Necessary Data While the Advice Access program helps participants evaluate their goals, the appropriateness of the advice provided is dependent on the personal information we receive from you and your Plan Sponsor. While we strive to provide the most accurate and timely economic forecast and financial information, we depend on you to provide the most accurate assessment of your financial status and goals. We will collect relevant personal and financial data about you (and, if applicable, your spouse or partner) that may include your age, retirement income goal, state of residence, retirement account balance, projected or actual social security amount, any outstanding loans from your retirement Plan, balances of any other investment accounts intended for retirement, expected pensions, and balances in company stock. This information is collected in order to personalize the advice you receive. In creating your strategy, the more information you provide to us, the more personalized the investment solution we are able to deliver. We collect information your Plan Sponsor is able to provide to us and ask you to provide any additional data that wasn’t available from your Plan Sponsor. Through our website, Benefit OnLine, you will be presented with an initial strategy as a starting point. You can model many scenarios by changing your retirement age, desired retirement income, social security start age, and savings rate. We will update your retirement strategy in real time to reflect any change you make. We also encourage you to provide additional retirement account information such as assets you hold outside your retirement Plan account or benefits for you or your spouse/partner in order to further personalize the recommendations. While we do not provide advice or guidance on external assets, we will take those into consideration when determining the investment strategy for your retirement Plan account assets. The Financial Expert provides other data used by Advice Access to generate the advice, including but not limited to, marginal tax rates, life expectancies, simulated asset class returns, and inflation data. Recommendations Made The forecasted retirement income, retirement age, and likelihood of reaching retirement goals will include assumptions that the savings rate(s) and sources of savings may vary from the initial recommendations. However, the total savings percentage of annual salary per year is assumed to be unchanged. Total savings is the combination of 401(k) savings, taxable savings outside of the Plan and any additional savings that were entered by the participant such as IRA contributions. Factors that impact the expected contribution amounts include: 1) salary changes, 2) inflation, 3) changes to IRS 401(k) contribution limits, 4) participant age and catch up contribution eligibility (see “Methods of Analysis, Investment Strategies and Risk of Loss” section below for further information, including information with respect to important assumptions and limitations used as part of the recommendation). Advice Access may recommend that a participant contribute to a taxable savings account outside of the Plan. The investment and savings recommendations made by Advice Access will not be implemented in this taxable savings account. It is important that the participant make the recommended annual contributions to such account and have it designated for retirement. If the participant does not plan to fund the taxable savings account according to the recommendations, they should update their profile with Advice Access to indicate that they will not make these contributions. 5 AA2A 03-25  Advice Access Brochure Federal tax laws may limit the contribution rates in the Plan of some participants who are defined as “Highly Compensated Employees,” by the Internal Revenue Code. A majority of Plans utilizing Advice Access have implemented controls that will not allow Highly Compensated Employees to over contribute to the Plan. However, some Plans do not utilize these controls, which may cause Highly Compensated Employees to receive refunds of excess contributions. Participants defined as Highly Compensated Employees should adjust their contribution rate in the Plan to avoid such refunds. Advice Access will provide each participant with a probability analysis demonstrating the likelihood that the participant will meet or exceed their specified Annual Retirement Income Goal with respect to their current investment and savings selection, in comparison to the investment selection and the asset allocation provided by Advice Access. (See section entitled Hypothetical Nature of Forecasts for more information about the hypothetical nature of probability analyses.) Other Merrill Advisory Services In addition to Advice Access, Merrill offers a wide variety of advisory services. These include, but are not limited to, the following: Merrill Lynch Investment Advisory Program, Merrill Lynch Fiduciary Advisory Services Program, Merrill Lynch Institutional Investment Consulting Program, Merrill Guided Investing, Merrill Guided Investing with Advisor, Merrill Edge Advisory Account, Merrill Personal Retirement Strategy and Merrill Lynch Strategic Portfolio Advisor® Service. We also offer impersonal investment advice (general advice not tailored to the specific needs of any individual) in the form of publications or research. More information about these programs and services is contained in the applicable Merrill brochure (or MLPF&S Form ADV, Part 2A) and is available upon request or through the SEC’s website at www.adviserinfo.sec.gov/. ASSETS UNDER MANAGEMENT As of December 31, 2024, Merrill had assets under management of $1,511.09 billion, of which $388.43 billion was managed on a discretionary basis and $1,122.66 billion was managed on a non-discretionary basis. This amount does not include financial planning services. FEES AND COMPENSATION We are responsible for paying the Financial Expert. The total compensation to be paid to the Financial Expert by Merrill for Advice Access and other services will not exceed 5% of the Financial Expert’s total gross income on an annual basis. The fee paid will not be affected by investments made in accordance with any portfolio model in the service. PERSONALMANAGER FEES An advisory fee is charged for Plan assets enrolled in the PersonalManager service (“PersonalManager Fee”). The maximum annual PersonalManager Fee is .25% of the assets enrolled in PersonalManager whether such fee is an asset-based fee or a fixed dollar amount. All PersonalManager Fees are payable in arrears. The PersonalManager Fee is not applicable to any Restricted Assets, as described in the Glossary, whether restricted by the participant, the Plan Sponsor or held in a self-directed brokerage account. The PersonalManager Fee is negotiated between Merrill and the Plan Sponsor depending on a number of factors that are not limited to plan size, recordkeeping fees and breadth of client relationship when they enter into the Advice Access Agreement. The extent to which we negotiate the Personal Manager Fee is solely within our discretion. The PersonalManager Fee may be paid by the Plan Sponsor or by the participant as determined by the Plan Sponsor. If the Plan Sponsor has elected to pay the PersonalManager Fee, it may agree upon an asset-based fee or a fixed dollar amount fee per participant enrolled in PersonalManager. For Plan Sponsors, the PersonalManager Fee will be charged on a calendar quarter basis in arrears. If the participant is paying the PersonalManager Fee, fees will be asset-based, and will be calculated and charged at the same time the rebalance occurs, which will be approximately every 90 days, based upon the participant’s date of birth. 6 AA2A 03-25  Advice Access Brochure CALCULATION OF THE PERSONALMANAGER FEE Plan Sponsor: Asset Based Fee: The fee is calculated using an average of the prior 3 month-end balances for the calendar quarter for assets that are not Restricted Assets and are enrolled in PersonalManager. The Plan Sponsor shall be invoiced each calendar quarter in arrears in an amount equal to one-fourth of the annual PersonalManager Fee multiplied by the average total amount of participant assets enrolled in PersonalManager for the quarter. The average total amount of plan assets enrolled in PersonalManager, for the quarter shall be calculated by taking the eligible Participant assets enrolled in PersonalManager on the last business day of each calendar month, divided by three. Participants will need to be enrolled in PersonalManager during at least one month in the quarter in order for a billing to occur for that quarter. In months where there are no assets, zero will be used for that month in the quarterly average. Fixed Dollar Amount Fee: Annual fixed dollar amount fees at the plan level are billed in quarterly calendar increments, in arrears. The Plan Sponsor shall be invoiced in an amount equal to one-fourth of the annual per participant PersonalManager Managed Fee for each participant enrolled in PersonalManager on the last calendar day of the calendar quarter. The quarterly fee shall not exceed one-fourth of 0.25% multiplied by total participant plan assets enrolled in PersonalManager. Participants will need to be enrolled in PersonalManager in order for a billing to occur. Participant: Asset-Based Fee: Fees shall be paid in arrears and will be deducted from your Plan assets at approximately the same time as your scheduled rebalancing. Scheduled rebalancing occurs approximately every 90 days and is based on your date of birth. The PersonalManager Fee is calculated on the business day prior to your scheduled rebalancing and shall be equal to one-fourth of the annual PersonalManager Fee multiplied by your plan assets enrolled in PersonalManager on the day the fee is calculated. Initial billing at your first scheduled rebalancing shall be based upon the number of days you have been enrolled in PersonalManager. If you are not enrolled in PersonalManager for at least 30 calendar days before your first scheduled rebalancing, the rebalancing of your account will be deferred until the next scheduled rebalancing and you will not be charged for the short period of less than 30 calendar days. If you have been enrolled in PersonalManager for at least 30 days but less than 90 days before your first scheduled rebalancing, the amount of the PersonalManager Fee will be pro-rated to reflect the number of days in the period you were enrolled. Billing Upon Termination of PersonalManager Plan Sponsors and participants will not incur additional PersonalManager fees after terminating from PersonalManager. The last full quarter a participant is enrolled in PersonalManager will be their final billing. Any partial quarters before the termination date will not be billed. PAYMENT OF PERSONALMANAGER FEE Plan Sponsors For fee arrangements where the Plan Sponsor is paying the PersonalManager Fee, Merrill will provide the Plan Sponsor with an invoice at the end of the calendar quarter for the amount due. Participants For fee arrangements where the Participant is responsible for paying the PersonalManager Fee, the fee will be deducted from the Plan account at approximately the same time as the quarterly rebalance. If there is insufficient cash in the Plan account to cover the fee, a pro-rata sale of securities will occur during the quarterly rebalance to satisfy the remainder of the fee. 7 AA2A 03-25  Advice Access Brochure OTHER FEES AND EXPENSES The PersonalManager Fee only covers the PersonalManager service described in this Brochure. The internal fees and expenses of the funds in the Plan menu used in the Program are not covered by the PersonalManager Fee. COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS Apart from the services provided through Advice Access, you may also use other products or services available from or through us or our affiliates, and in such case we or our affiliate will earn additional compensation. Financial Advisors offering these services will receive compensation in connection with your use of those services. This creates a conflict of interest because we and our Financial Advisors have an incentive to recommend products and services based on the compensation received, rather than a client’s need. Where there is a difference in fees and commissions for some products or services, and the remuneration and profitability to us and our Financial Advisors resulting from transactions on behalf of, or management of, certain accounts is greater than the remuneration and profitability resulting from other advisory accounts, products or services, this creates a conflict of interest due to the financial incentives created. (See section entitled Participation or Interest in Client Transactions and Personal Trading for more information about the receipt of compensation for the sale of securities and other investment products.) Financial Advisors do not receive compensation for Advice Access. We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways, including the disclosure of conflicts in this Brochure. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for each client based upon the client’s investment objectives, risk tolerance and financial situation and needs. In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest – both those arising between and among client accounts as well as between accounts and our business. The investment advice delivered through PersonalManager is based on the menu of investment options made available by a Plan Sponsor through its Plan. These investment options typically include various mutual funds. Plan participants may be able to purchase the same mutual funds for their non-Plan assets. However, they generally will not be able to purchase Plan investments through other brokers or financial institutions, unless permitted by the Plan. SOURCES OF REVENUE As a broker-dealer, Merrill offers a wide variety of securities and brokerage services. Our principal sources of income are derived from our business as a broker-dealer. Less than 1% of our revenue is expected to be generated from PersonalManager fees on an annual basis. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Neither Merrill nor our employees receive performance-based fees for the services provided in Advice Access. TYPES OF CLIENTS Advice Access is an online investment advisory program for participant-directed defined contribution plans that utilize Merrill for recordkeeping services. Effective April 1, 2023, no new enrollment of Plans will be accepted into the Advice Access program. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Advice Access uses technology provided and maintained by the Financial Expert. This technology analyzes historic and current returns, volatility, cross-correlations and uses “Monte Carlo simulations,” among other techniques, to develop individualized recommendations. The technology also uses historic pricing data for mutual funds, individual securities and broad asset categories, as well as current market data and information. All calculations and asset allocation, specific investment, contribution rate and retirement age recommendations are created by 8 AA2A 03-25  Advice Access Brochure the Financial Expert’s technology and are isolated from the Plan participant’s interaction with us. Thus, we cannot change the recommendations or calculations generated by Advice Access. INVESTMENT PHILOSOPHY The Financial Expert’s investment philosophy is driven by the investment principles that are promoted throughout their organization. The principles are intended to guide their thinking, behavior and decision making. These principles also reflect and align with the history and foundation of the Financial Expert and are described below. Investors First /Personalized. The Financial Expert’s primary objective is to help participants achieve a sustainable retirement income: defined as a 70% or greater probability of replacing 90% of the participant’s projected salary at their retirement age, and in each subsequent year of retirement by furnishing the participant with a personalized strategy that includes: • Estimate how much the participant will need to save in total to sustain a certain lifestyle through the duration of retirement • Determine how much to set aside each pay period to achieve the participant’s retirement goals, including the ideal contribution rate based on the participant’s specific situation and goals • Build a personalized investment portfolio that helps to ensure that the participant is taking on the right amount of investment risk based on his or her specific needs and financial situation • Manage the participant’s investment portfolio to help ensure it still meets his/her needs and revise the portfolio as needs change (available through PersonalManager) • Help the participant take advantage of the employer match if applicable • Provide guidance on when the participant should retire based on their retirement objectives and the amount they have already saved for retirement Independent Minded. The advice and recommendations the Financial Expert makes are based on their methodologies, models, analysis, and assessment/forecasts of the capital markets. Long-term/Goals-Based. The Financial Expert recognizes that a prudent strategy must be built in relation to specific goals, including long-term retirement goals. Advice Access helps the participant define those goals and develop a strategy aimed at reaching them. Valuation-Driven/Forward-Looking. Rather than relying only on historical data (which may not have any relevance to future conditions), the Financial Expert incorporates forward-looking estimates for assumptions about investment returns and performance behavior. The Financial Expert’s recommended asset allocations, savings rates, spending rates, retirement age, projections of future wealth and income, reflect their forecast of the capital markets. Fundamental/Research-Driven. The Financial Expert is a leading producer of independent, thought leadership on a variety of investment management and financial planning topics, all of which drive their methodologies, models, and advice. Cost Minimization/Diversification Maximization. While no investment strategy can ensure a profit or protect against a loss, diversifying a participant’s investments is a bedrock principle to seek the long-term safety of capital. The Financial Expert’s proprietary approach diversifies the participant across asset classes, investment sectors, styles, and investment options. Holistic. The Financial Expert takes a holistic total wealth approach in which they attempt to estimate the value and asset allocation of a person’s human capital or nonfinancial assets based on the participant’s age, gender, income, savings rate, and future Social Security estimate. The recommendation for the participant’s financial capital helps bring the participant’s total wealth close to an age-appropriate, diversified asset allocation. 9 AA2A 03-25  Advice Access Brochure FINANCIAL EXPERT’S GOVERNANCE The Financial Expert has a variety of governance oversight structures. These include a Governance Committee, a Global Investment Policy Committee, and regional or business-specific governance bodies, including the Morningstar Retirement Investment Committee and the Americas Investment Committee. The Morningstar Retirement Investment Policy Committee is dedicated to overseeing the Financial Expert’s advice and managed accounts methodologies embedded in Advice Access. Members of the Morningstar Retirement Investment Policy Committee may include officers, chief investment officers, senior leaders, executives, and /or investment professionals and portfolio managers of Morningstar Investment Management LLC or its affiliates. The regional or business specific governance bodies of the Global Investment Committee sub-committees and investment teams focus on specific investment capabilities such as valuation models driven by the Financial Expert’s capital markets research, asset allocation methodologies, investment selection, portfolio construction and portfolio risk analytics. Additionally, the Financial Expert’s parent company maintains a compliance team that monitors the Financial Expert. KEY DATA SOURCES Advice Access updates and personalizes the advice for you based on three key data sources: 1) information provided by your employer, 2) information from external data sources obtained by the Financial Expert, and 3) information provided by you. 1. Information provided by your employer. Examples include: • Your income • Your current 401(k) saving rate • Applicable Plan provisions such as company match and/or profit sharing rules • Your current 401(k) account balance • Your age • Your gender • Your state of residence 2. Federal and state taxes Information from external data sources used by the Financial Expert. Examples include: • Social Security retirement benefits • • A salary and savings rate curve or schedule based on how typical salaries evolve 3. Information provided by you. Examples of information that influence the advice include: • Changes to your personal situation, such as the addition of a spouse or partner • Information on other financial assets /accounts and how they are invested • Financial expenditures such as a wedding, a second home or a child’s college tuition • Other sources of income such as pensions, supplemental employment income or life insurance payments KEY ASSUMPTIONS Advice Access makes assumptions about certain pieces of information that have a significant impact on the strategy created for you. These assumptions relate to inflation rates, retirement income goals, federal/state/capital gains/other taxes and your risk capacity, social security amounts (if you are not yet retired), and salary growth. Social Security Retirement Benefits. Advice Access can incorporate Social Security retirement benefits for you and if applicable, your spouse/partner, using an estimate based on your current salary or a number you input from your Social Security Administration statement. Social Security retirement benefits are inflated using a 10 AA2A 03-25  Advice Access Brochure simulated cost- of-living allowance designed to replicate the actual Social Security Administration (“SSA”) formulas and are applied at the maximum benefit age as defined by the SSA. Advice Access accounts for reduction in payments while working in retirement, increases in benefits for the spouse 50% rule and increased benefits for the surviving spouse 100% rule. The program assumes you complete all applications required to collect the maximum benefit. Advice Access also takes Social Security into consideration while analyzing income replacement. Advice Access defaults to the age at which you will receive full benefits from the SSA, but you can adjust the benefit amount and start age if desired, however, the start age must be between 62 and 70. Salary Growth. To estimate future salary, Advice Access uses a salary growth curve based on academic research rather than assuming a single, fixed growth rate. This curve takes into account the fact that salaries tend to grow most rapidly for young employees, peak around age 51, and then slightly decline later in life. Retirement Age. Advice Access assumes a default retirement age of 65. You have the option to change this to a different retirement age. Estimated Tax. Advice Access estimates federal and state income, and capital gains taxes based on marginal tax rate calculations. Tax data is updated annually based on U.S. Internal Revenue Code (IRC) and similar state tax data. Advice Access uses income data for you, as well as for your spouse/partner, if applicable, to estimate federal and state tax exposure. Tax exposure is appropriately reduced for pretax deferrals, tax-deferred capital gains, and yield and distribution of Roth proceeds. Based on the information we know about you, we provide an estimate of tax exposure, but may not include all tax considerations. The recommendations provided by Advice Access are made without taking into consideration potential tax consequences and does not provide tax advice. Potential tax consequences may exist. We encourage you to consult with a tax professional about these and other tax consequences. Inflation Assumptions. When projecting the growth of various income sources and expenses, the Financial Expert uses a variety of different inflation rates. These rates are reviewed and updated annually by their research team. Different inflation rates are used for different projections and major expenses. The Financial Expert believes that their multifaceted approach to calculating inflation results in more realistic and more accurate projections compared with using one set rate. IRS Limitations and Application of Penalties. Advice Access incorporates all IRS contribution limits, eligibility requirements, and withdrawal penalties into the retirement strategies. Brokerage Account. Some Plans allow participants to maintain a brokerage account within the Plan. If your Plan allows this option, you will be responsible for managing and monitoring those assets. Advice Access does not manage brokerage account assets; however, if you provide Advice Access with detailed information on the holdings within the brokerage account, the methodology will consider these holdings in developing an appropriate investment strategy for your other retirement Plan account assets. If you do not provide detailed information, our methodology will assume that the balance in the brokerage account is 45% stocks and 55% fixed income. RISK OF LOSS AND STRATEGY RISK General Risks Associated with Investments All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed and the value of your assets will fluctuate due to market conditions and other factors. Investments made and the actions taken respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Portfolios that consist of equity securities (such as stocks) will be more or less volatile and carry more risks 11 AA2A 03-25  Advice Access Brochure than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. You should review the offering materials and other disclosure available for each relevant investment security or transaction, including any prospectuses and other offering material produced by issuers and sponsors of investment products, to get an appreciation of its associated risks and fees. You are assuming the risks involved with investing in securities and other investment products, and you could lose all or a portion of the amount you hold in the Program. For a discussion of conflicts of interest with the use of certain investments and securities, please review the information in this section and in “Compensation, Conflicts of Interest and Material Relationships.” Strategy Risk You should remember that investments in securities involve market risk, risk of loss, and other risks, and will not always be profitable. We do not guarantee that the intended objectives of our recommendations will result in achieving your retirement income goal. We cannot guarantee that negative returns can or will be avoided in any of our recommendations. We do not represent or guarantee that our investment recommendations can or will predict future results, will successfully identify market highs or lows, or will result in a profit or protect clients from loss. An investment’s future performance may differ substantially from its historical performance, which is no indication of future performance. A security’s investment return and an investor’s principal value will fluctuate so that, when redeemed, an investor’s shares may be worth more or less than their original cost. We are unable to predict or forecast market fluctuations or other uncertainties that may affect the value of any investment. The Advice Access investment strategy is intended to provide you with an investment portfolio that is diversified across various asset classes and appropriate based on your facts and circumstances. Asset allocation and diversification are investment strategies which spread assets across various investment types for long-term investing. However, as with all investment strategies, these strategies do not ensure a profit and do not guarantee against losses. Capital market assumptions are forecasts which involve known and unknown risks, uncertainties, and other factors which may cause the actual results to differ materially and/or substantially from any future results, performance, or achievements expressed or implied by those projections for any reason. Past performance does not guarantee future results. 12 AA2A 03-25  Advice Access Brochure Income projections used in Advice Access are based on hypothetical performance data and do not represent actual or guaranteed results. Projections may vary over time and with each use of our service. Hypothetical Nature of Forecasts Advice Access uses a probabilistic approach to determine the likelihood that Plan participants may be able to achieve their stated goals and/or to identify a range of potential retirement income outcomes that could be realized. Plan participants should carefully review the explanation of the methodology used, including key assumptions and limitations, which is provided herein. It is important to note that projections or other information shown in Advice Access regarding the likelihood of various investment outcomes are hypothetical in nature, do not reflect actual investment results and are not guarantees of future results. The projections or other information may vary with each use and over time. Financial Expert’s Advice and Investment Recommendations. There are several key investment and planning methodologies behind the personalized recommendations provided from the Financial Expert. • Financial Expert’s Lifetime Holistic Total Wealth Approach – Information from the recordkeeping system as well as additional information provided by the participant enables the Financial Expert to create a relatively complete picture of a participant’s financial assets as well as their human capital. Human capital is a powerful but hidden nonfinancial asset that provides the participant with an ongoing paycheck, enables them to save for retirement, generates a future Social Security benefit, and in some cases, with a defined benefit pension. From a total wealth perspective, on a relative basis, most younger investors have a lot of human capital and relatively little financial capital. The investment-like properties of human capital are often viewed as bond- like in that they provide relatively steady cash flows. Human capital provides the investor with the capacity to take on risk by allowing financial assets saved for retirement to stay saved and grow over time. As one ages the relative composition of their total wealth evolves and at retirement, total wealth is often dominated by financial capital and the risk-taking capacity that human capital provided is diminished. The Financial Expert attempts to monitor the participant’s total wealth, and as the composition of the participant’s total wealth evolves, the Financial Expert automatically adjusts the recommended asset allocation. • Diversified Asset Allocations – Complementary to the Financial Expert’s total wealth approach, their team of investment professionals and asset allocation experts create diversified asset allocation targets that attempt to maximize expected return for a given level of risk. Additionally, the detailed intra-equity asset allocation and detailed intra-fixed income asset allocations that collectively form the total asset allocation are personalized based on the participant years-to- retirement. In general, looking beyond the total equity vs total fixed income split that typical slowly glides from being equity-centric to fixed income centric across the typical participant’s lifetime, the detailed equity allocation and detail fixed income allocations are return-seeking for younger investors and risk-mitigating for those nearing retirement. • Investment-Specific Portfolios -- On an ongoing basis, the Financial Expert monitors the available investments in each participant’s primary retirement Plan with the ultimate goal of building and updating the fund specific portfolio. The investment option evaluation and monitoring process includes: Incorporating any changes in fund fees Informing your company if we believe the investment options are inadequate • Assigning the different investment options to peer groups • Analyzing the funds using a multi-factor model • Estimating the various risk exposures • • Ranking potential substitute funds • Estimating the forward-looking performance of the funds • Analyzing any new funds that are added to the retirement Plan • 13 AA2A 03-25  Advice Access Brochure Based on the ongoing monitoring of the available investment options, using an advanced automated portfolio construction optimization system, the Financial Expert builds and updates a fund specific portfolio. The system helps ensure that the fund specific portfolio meets numerous quality controls established by the Financial Expert. • Wealth and Income Projections – Not all financial calculators or Monte Carlo simulators are equal. In order to help participants plan for the future, including how much to save, when to retire, how much to spend in retirement, etc., one must estimate how wealth accumulates and how quickly it will be depleted. The Financial Expert believes that it is important to model that: asset class returns don’t follow a classic bell-shaped curve, the location of the market cycle impacts future returns, gender impacts life expectancy, the impact of federal and state taxes can be significant, it is important to account for required minimum withdraws, and that the sequencing of withdraws from different account types matter. The Financial Expert has gone to great lengths to accurately model the wide range of possible future outcomes, so that projections driving their advice are as accurate as possible and tailored to the participant’s unique circumstances. The Financial Expert works to keep each participant in an appropriate asset allocation and associated fund specific portfolio. This is done by periodically monitoring what the Financial Expert calls “total wealth” and by monitoring the Plan’s investment options and updating the fund specific portfolio accordingly. The Financial Expert reviews and updates their building block asset allocation targets annually, while the fund specific implementation of those targets with the Plan’s investment options are updated quarterly. If the Financial Expert finds that a Plan Sponsor’s menu of investment options is inadequate to create diversified fund specific portfolios, it will notify the Plan Sponsor. Also, for certain investments the Financial Expert may require additional information on the investment in order to properly understand it and to use it within portfolios. The Plan Sponsor must rectify any Plan menu deficiencies within the timeframe established by the Financial Expert to continue to receive Advice Access. The Financial Expert will also update capital market assumptions periodically and will adjust asset class targets at the Plan level. Merrill reviews the changes to determine reasonability but does not make any changes to the adjustments. EMPLOYER SECURITIES Advice Access technology will recommend that any positions in Employer securities in a participant’s account be sold, unless the Plan Sponsor or participant restricts the sale of all or a part of the Employer securities. Advice Access will consider positions in individual and Employer securities restricted by the Employer or participant for sale when making asset allocation and specific investment recommendations. Merrill and the Financial Expert do not assume any responsibility, fiduciary or otherwise, for Employer securities held by the participant that are restricted by the Plan Sponsor or the participant. MATERIAL RISKS FOR PARTICULAR TYPES OF SECURITIES The Financial Expert constructs portfolio models appropriate for the Plan and participants that will be used by the Advice Access technology. The portfolio models will be based on the menu of investment options selected by each Plan Sponsor. These investment options typically include various mutual funds, but may include Collective Investment Funds (CIFs), Money Market, and Stable Value funds. Information about the risks associated with each mutual fund is available in the relevant prospectus or other disclosure document for each mutual fund. Merrill does not recommend specific investments for the Plan’s investment menu through Advice Access. Mutual Funds. Mutual funds are sold by prospectus. To determine whether a particular investment is an appropriate investment for you, carefully consider the important information on the investment objectives, risks, charges and expenses. Please read the prospectus carefully before you invest. Mutual funds charge various fees and expenses, which will reduce the actual returns of your investment. Collective Investment Funds. A Collective Investment Fund is not available for direct investment by individual shareholders. Unlike a mutual fund, an investor gains access to a collective investment fund through a retirement Plan, such as a 401(k) Plan. Additionally, regulation of mutual funds and Collective Investment Funds varies. For instance, the mutual fund industry is regulated by the Securities and Exchange Commission (SEC), and mutual funds are subject to the Investment Company Act and the rules adopted thereunder, which provide important 14 AA2A 03-25  Advice Access Brochure protections to fund shareholders. For example, mutual funds are sold by prospectus, are subject to limitations on leverage and extensive regulatory reporting requirements and are governed by independent boards of trustees. In contrast, Collective Investment Funds are not regulated by the SEC or subject to the Investment Company Act; instead, their investment managers and the CIFs are subject to less stringent guidelines and are overseen by the U.S. Office of the Comptroller of the Currency or by a state banking authority. Stable Value Funds. The objective of most stable value funds is to provide safety of principal and an investment return that is generally higher than a money market return, while providing participants the ability to withdraw their assets for ordinary transactions at book rather than market value. However, the ability to withdraw stable value assets at book value has limitations based on the insurance contracts that wrap the underlying assets. In addition, most stable value funds require a hold period before assets can be withdrawn from the fund by the Plan Sponsor at book value and may refuse to honor book value withdrawals after communications from a Plan Sponsor or Plan fiduciaries that it determines caused participants' withdrawals. Additionally, the Plan is often restricted from offering investment alternatives that are viewed as competitive with the stable value offering. Finally, stable value funds are subject to counterparty risk of the insurers that provide the fund's book value liquidity. Money Market Funds. Money market funds invest in government and treasury securities (“Government Money Market Funds”), as well as money market funds that invest in corporate commercial paper (“Prime Money Market Funds”). A Government Money Market Fund seeks to preserve the value of your investment at $1.00 per share. However, there is no guaranty it will do so. The sponsors of these funds have no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to these funds at any time. A Prime Money Market Fund does not seek to maintain a stable per share net asset value, and the securities held by the fund are subject to the risk that issuers and/or counterparties will fail to make payments when due or default completely. You could lose money by investing in a Prime Money Market Fund. Because the share price of these funds will fluctuate, when you sell your shares they may be worth more or less than what you originally paid for them. All money market funds may impose a fee upon the sale of your shares or may temporarily suspend your ability to sell shares if a fund’s liquidity falls below required minimums because of market conditions or other factors. Neither Government Money Market Funds nor Prime Money Market Funds are insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Money market funds are sold by prospectus. Please read the prospectus carefully before you invest. Your Financial Advisor can provide a copy of the prospectus. INFORMATION AND CYBERSECURITY RISKS With the increased use of technologies to conduct business, all companies including Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks. Accordingly, BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, the Funds and Fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to 15 AA2A 03-25  Advice Access Brochure and recovering from cybersecurity threats and cybersecurity incidents suffered by BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents as well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment, there can be no assurance that we or our service providers, will not suffer losses relating to cyber- attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory, operational and ESG reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. DISCIPLINARY INFORMATION The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill Lynch’s Form ADV at adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, 16 AA2A 03-25  Advice Access Brochure consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’s remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Merrill, an indirect wholly-owned subsidiary of BofA Corp. is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through its affiliate, BofA Securities, Inc. (“BofAS”), it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. Merrill also acts as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield 17 AA2A 03-25  Advice Access Brochure bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As a registered investment adviser, Merrill completes a Form ADV which it publicly files with the SEC (available at http://www.adviserinfo.sec.gov). For purposes of Form ADV Part 2, certain Merrill management persons are registered as registered representatives or associated persons of Merrill. In the future, certain Merrill personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of Merrill to the extent necessary or appropriate to perform their job responsibilities. BofA Corp. through its subsidiaries and affiliates, including us, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning; asset management and investment advisory and related record- keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research including global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act and information can be found in its publicly available filings with the SEC. From time to time, a shareholder of BofA Corp. may acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Plan assets, such as buying or selling securities issued by the shareholder or its Affiliates, may be limited. We address these conflicts through disclosure in this Brochure. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for clients based upon their investment objectives, risk tolerance and financial situation and needs. In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest – both those arising between and among client’s accounts as well as between client accounts and our business. We selected an independent Financial Expert to avoid conflicts of interest. The Financial Expert has not been, and will not be, involved in any other relationship with us that would compromise the Financial Expert’s independence. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CONFLICTS OF INTEREST AND INFORMATION WALLS Merrill and its parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflicts arising from such a situation. For example, information walls prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within the BofA Corp. organization possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which provides guidelines for the business practices and personal conduct all associates and board members are expected to adopt and uphold. 18 AA2A 03-25  Advice Access Brochure Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., BofAS, and Merrill evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. CODE OF ETHICS We have adopted an Investment Adviser Code of Ethics (“Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services under the various investment advisory program for which they are a registered investment adviser. The Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that we follow in conducting our business with integrity and professionalism. The Code of Ethics covers: • Requirements relating to employees complying with all applicable securities and related laws and regulations • Reporting and/or clearance of employee personal trading • Prevention of misuse of material nonpublic information and • The obligation to report possible violations of the Code of Ethics to management or other appropriate personnel Covered personnel must certify to the receipt of the Code of Ethics. We will provide a copy of the Code of Ethics to any Plan Sponsor or Plan participant upon request. We also have imposed policy restrictions on all personnel regarding transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions, as well as those of all our employees. PRIVACY/DATA PROTECTION We will not disclose to the Plan Sponsor, or any other person, any “personal information” obtained directly from any Plan participant. Personal information includes any information that can specifically identify an individual, such as name, address, social security number, etc. Personal information does not include information about any Plan participant that the Employer already knows or is entitled to know in connection with the administration of the Plan. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS As a result of our affiliates’ involvement in multiple business activities, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization, including that our employees may have interests unrelated to the interests of Advice Access clients (see further discussion below). This discussion does not seek to identify all actual or potential conflicts. Information about certain additional conflicts is described throughout this Brochure and in many of the contracts and offering documents that govern the specific products and services we offer. Investment options made available to participants through a Plan will from time to time include mutual funds or products from which Merrill or its affiliates receive fees or compensation in addition to the fees for this service described above. This additional revenue can be in the form of sub-accounting or processing fees (fees for transaction and account processing functions), service fees, and/or distribution fees. We only make available mutual funds, money market funds (each, a “fund”) that pay us to provide 19 AA2A 03-25  Advice Access Brochure the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges, dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under agreements with each of these funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services (either directly or through a subsidiary) to the holders of these funds maintaining shares in an account as well as in other Merrill securities accounts and receive the agreed-upon sub-accounting services fee. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. We have a conflict of interest in selecting certain fund products (or share classes) for inclusion as part of our product offering available to participants. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of our product menu but whose principal underwriters, agents or sponsors do not agree to pay a fee that we determine is appropriate for its services will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the fees paid to us for these services varies among funds and, in certain instances, between share classes of individual funds, This results in a conflict of interest because it creates an incentive for us to recommend that you invest in funds and share classes that pay higher fees. We will receive higher sub- accounting fee payments from fund families that have higher fund assets held in our client’s accounts because the service fee calculation is based off of the level of the asset holdings. Additionally, we benefit financially because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. We address these conflicts of interest in the following ways, which include disclosing the nature of our sub- accounting service arrangements. We also determine the compensation paid to our personnel on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our personnel do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we and our Affiliates select funds that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Advice Access, from time to time, will recommend changes to Plan participants’ account holdings and any implementation of these recommendations will result in transactions in participants’ accounts. To the extent that such implementation involves products that result in payments to us or our affiliates we or our affiliates benefit. Similarly, investment options made available to participants may change. To the extent that we provide Plan Sponsors with information about existing or substitute investments, we may provide information regarding mutual funds and other investments, from which Merrill or our affiliates receive these additional forms of revenue. However, any decision to change or substitute Plan investment options will be made by each Plan Sponsor, rather than us or any of our affiliates. As a broker-dealer effecting transactions as part of the program, we or an affiliate may act as agent or as principal for our own account, as permitted by applicable law. Similarly, we or an affiliate may, in transactions involving such clients' securities, act as agent while also representing another client on the other side of the transaction. In addition, we or our affiliates may have a position in, or enter purchase or sale orders for, securities recommended to clients in the normal course of our business as a broker-dealer. We and/or our affiliates may profit from these positions or transactions in securities. We, through our Financial Advisors, may suggest or recommend that participants use Merrill securities accounts, execution and custody or other services, or such services of an affiliate in connection with their non-Plan assets. Similarly, Financial Advisors, who also handle participants’ securities accounts, may suggest or recommend that participants purchase our products or products of an affiliate. Where Merrill’s or our affiliate’s services are used or products are purchased by participants for their non-Plan assets, we and our affiliates will receive fees and compensation. Financial Advisors may, as permitted by applicable 20 AA2A 03-25  Advice Access Brochure law, receive compensation (the amount of which varies) in connection with these products and services. Compensation received in connection with participants’ purchase or sale of stocks, bonds, mutual funds, other securities or insurance products through us or our affiliates may include commissions, spreads, markups and markdowns, and distribution or other fees. We also benefit from the possession or use of any free credit balances in participants’ accounts, subject to the restrictions imposed by Rule 15c3-3 under the Exchange Act. With respect to participants’ non-Plan assets, we, acting in our broker-dealer capacity, may recommend that participants invest in a variety of limited partnerships, investment vehicles such as hedge funds and other investment funds, for which certain of our affiliates act as general partners. The investments of the limited partnerships and other entities may vary but include, without limitation, real estate, futures, hedge funds and other alternative investments. INVESTMENTS IN SECURITIES BY MERRILL AND OUR PERSONNEL Merrill provides a variety of advisory and brokerage services to others and these services may involve Merrill recommending a transaction in securities that are investment options selected by the Plan Sponsor. From time to time in the course of those duties, confidential information may be acquired that cannot be divulged or acted upon for advisory or other clients. Similarly, recommendations made in other services or programs may be contrary to the recommendations to participants using these services. For example, Merrill may recommend that an investment advisory client in another program buy shares of a particular mutual fund and at the same time replace those shares with shares of other investment options in a participant’s account. We and our affiliates have investment banking or other relationships with certain publicly traded companies; these relationships, from time to time, compel us to forego trading in the securities of these companies. In the course of investment banking and other activities, our affiliates acquire confidential or material nonpublic information that prevents us or our affiliates, for a period of time, from purchasing or selling particular securities for your account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. In addition, potential conflicts of interest also exist when Merrill maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon Merrill or its Affiliates by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude the inclusion of particular securities or financial instruments in a client’s Portfolios where Merrill or its Advisors provide discretionary management services, even if the securities or financial instruments would otherwise meet the investment objectives of such portfolio. Merrill and its Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs (“In-Scope Funds”) by Merrill, its Affiliates and those of their clients that have granted discretion to Merrill, its Affiliates and/or Merrill Advisors (“discretionary clients”) to avoid potential restrictions on the ability of Merrill and its Affiliates to engage in principal trading and other transactions with In-Scope Funds. A portion of the aggregate ownership limit is attributed to our Affiliates. When Merrill and its Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to Merrill or its Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because Merrill’s and its Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest for Merrill in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. 21 AA2A 03-25  Advice Access Brochure We or one of our affiliates may have a position in or enter into "proprietary" transactions in securities purchased or sold for clients. We or our affiliates benefit from such securities positions or transactions. We address these conflicts through disclosure in this Brochure. BROKERAGE PRACTICES Transactions in connection with Advice Access are effected by Merrill or an affiliate. The Plan Sponsor has authorized us as agent to use our (or an affiliate’s) own execution services to purchase, exchange and redeem fund shares and other investment options available under the Plan and to take any other necessary action relating to transactions in Plan participant accounts, including the completion and settlement of transactions. Mutual fund orders may be combined with other mutual fund purchases and sales across our platform for purposes of submitting consolidated purchase or redemption requests to the relevant transfer agent for each fund. We purchase and redeem all fund shares for the program account at net asset value without the imposition of any front-end or contingent deferred sales charges. REVIEW OF ACCOUNTS ONGOING MONITORING OF PORTFOLIO MODELS It is your responsibility to ensure that the information you provide to us is complete and accurate. When you provide accurate and complete information, we are better able to make appropriate recommendations in this Program. It is also your responsibility to notify us if any information you have provided to us is inaccurate, becomes inaccurate or is incomplete. We will send you periodic updates that contain information about your account which include account statements. The Financial Expert works to keep the participants’ strategic targets on track by monitoring the portfolio allocations for manager style drift. The Financial Expert will review the asset-level portfolio models annually and the underlying investment allocations quarterly. The Plan Sponsor must approve and implement any recommended changes within the time-frame established by the Financial Expert to continue to receive Advice Access. The Financial Expert will also update capital market assumptions periodically and will adjust asset class targets at the Plan level. Merrill reviews the changes to determine reasonability but does not make any changes to the adjustments. Appropriate testing occurs to ensure the accuracy of the model code implemented in production for each application environment. Model software is subject to documented change control procedures, so that developers and users do not have the ability to change code without appropriate review, audit trails and validation, where required. A documented log of all model changes is maintained, so that the cumulative effect of incremental changes can be observed and appropriately controlled. Model change logs include changes to the choice / version / configuration of models in production systems. Operational procedures are developed to ensure the production implementation of the model is appropriate, well controlled and produces accurate model results. User access to relevant systems is reviewed periodically in accordance with Merrill policy to ensure users do not have entitlements incompatible with their job responsibilities. A set of criteria is used by the Financial Expert to evaluate the Plan’s investments used in the portfolios on an ongoing basis. The criteria are applied to each of these investments quarterly. If this process shows that investments have drifted in investment style, then the Financial Expert will adjust the investment allocations appropriately. If the Financial Expert determines that the investment no longer meets the objectives of one or more of the portfolios, the Financial Expert will notify Merrill to request an appropriate replacement investment from the Plan Sponsor. The Plan Sponsor must implement suggested changes to the investment menu to continue to receive Advice Access. As noted above, the Plan Sponsor will determine and be responsible for the appropriateness of the investments available under the Plan. 22 AA2A 03-25  Advice Access Brochure CLIENT REFERRALS AND OTHER COMPENSATION RELATIONSHIPS WITH THIRD-PARTY FIRMS We and our Affiliates have business relationships with investment managers, including Style Managers, Fund managers, distributors and sponsors, and insurance companies and other product providers (“Third-Party Firms”). We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third- Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for Third-Party Firm. Any compensation paid to us or our Affiliates by the fund manager or sponsor or any of their Affiliates is additional compensation to us for services we and our Affiliates provide to them. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third- Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Financial Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our Financial Advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our Financial Advisors provide. PARTICIPATION AND SPONSORSHIP BY THIRD-PARTY FIRMS FOR MERRILL CONFERENCES, MANAGER MEETINGS AND CHARITABLE EVENTS Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (Conferences) for invited Merrill financial professionals. These financial professionals include Financial Advisors and members of their team, employees who work for a Merrill branch, market or division to support the Financial Advisors (Field Management Employees) and employees who cover product, Chief Investment Office and home office support functions (Non-Field Employees). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third-Party Firms participate (Client Events). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending Financial Advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with a number of Conferences and Client Events in the amount of approximately $21 million. Certain Third-Party Firms periodically host or participate in meetings (Manager Meetings) where they provide certain Financial Advisors, Field Management Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending Financial Advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third- Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provided monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of 23 AA2A 03-25  Advice Access Brochure charitable events and causes that we requested or initiated with the Third-Party Manager in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives for Financial Advisors to recommend products of participating Third-Party Firms. They give those Financial Advisors participating in Conferences, Client Meetings, Manager Meetings and charitable events with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third- Party Firms over others. There is also a conflict of interest for Field Management Employees to approve those recommendations and for non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our Financial Advisors to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Management Employees to approve their Financial Advisors’ recommendations of products and services of those participating Third-Party Firms. Furthermore, we do not incentivize Non-Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. Third-Party Firms that elect to act as sponsors of national Conferences and Client Events reimburse Merrill on an equitable basis for the eligible costs of the particular Conference they sponsor. Third-Party Firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs for Conference and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. THIRD-PARTY FIRM OFFICE ACCESS, GIFTS AND ENTERTAINMENT Representatives of Third-Party Firms will, from time to time, meet and work with our Financial Advisors, Field Employees and Non-Field Employees, in one on one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third-Party Firms from providing or paying for, and our Financial Advisors, Field Employees and Non-Field Employees, from receiving gifts and entertainment other than as permitted by and subject to the limits established under Merrill internal policies. In general, our Financial Advisors, Field Management Employees and Non-Field Employees may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting Third-Party Firm representatives access to our financial professionals and paying for meals presents a conflict of interest. Providing Financial Advisors with gifts, meals and or entertainment access presents a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. It can also create incentives for Field Management Employees to approve recommendations of a Financial Advisor, where required. Furthermore, providing gifts, meals or and entertainment access to Non-Field Employees creates incentives to approve the investment products of the Third-Party Firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts, meals, and entertainment access from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts, meals or and entertainment access on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non- cash compensation from Third-Party Firms. PROVISION OF DIVERSIFIED FINANCIAL SERVICES BY US AND OTHER AFFILIATES From time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to 24 AA2A 03-25  Advice Access Brochure NMS Rule 606 reports we file with the SEC. participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships are publicly available in Regulation CUSTODY Plan assets for which Merrill serves as record-keeper generally are custodied with BANA as Trustee and held with Merrill; please refer to the applicable documentation for information regarding Merrill’s responsibilities as a custodian. However, Plan Sponsors can also enter into separate custody agreements to hold Plan participant funds and securities with other qualified custodians that are not affiliated with Merrill. Any such separate agreement with an unaffiliated custodian may contain authorizations for transferring assets held with that custodian that are broader than those granted to us in agreements in connection with the Advice Access services, and the unaffiliated custodian’s monitoring, if any, of assets held with it is governed by that separate agreement. It is important to note that our rights and authority to transfer Plan assets held with an unaffiliated custodian are limited to those set forth in agreements in connection with the Advice Access services, regardless of any separate agreements or arrangements a Plan Sponsor or Plan participant may have or enter into with any such custodian. We disclaim any broader rights that may be contained in that separate agreement. In our capacity as record-keeper and, as holder of assets (as applicable), Merrill provides Plan participants with written participant quarterly benefit statements. Plan participants should review their statements carefully. To the extent you receive account statements from other qualified custodians, please compare the account statements you receive from the qualified custodian with those you receive from us. INVESTMENT DISCRETION Plan participants may enroll in the discretionary investment management feature of Advice Access, PersonalManager, to implement the specific asset allocation and investment recommendations provided by Advice Access with respect to their Plan accounts. VOTING CLIENT SECURITIES Merrill does not accept authority to vote client securities held in the participant’s Plan accounts enrolled in Advice Access. Depending on the terms of the Plan Sponsor’s Plan document and its related trust, either the Plan fiduciary may vote proxies relating to securities in the participant’s Plan accounts or the proxies may be passed through to the Plan participant to vote the proxies. Merrill does not provide advice with respect to a particular proxy solicitation. Merrill will not render any advice or take any action with respect to securities or other property currently or formerly held in Plan accounts that become the subject of any legal proceedings, including bankruptcies and class actions. FINANCIAL INFORMATION Not applicable. GLOSSARY “Advice Access Agreement” means the agreement between Plan participants’ Plan Sponsor and Merrill, as it may be amended from time to time. “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Annual Retirement Income Goal” means a participant’s annual after-tax retirement income goal, which Advice Access assumes to be 90% of the participant’s current pre-retirement after-tax income increased for inflation during retirement, unless the participant provides an alternate amount. 25 AA2A 03-25  Advice Access Brochure “AWC” means a FINRA Letter of Acceptance, Waiver and Consent. “BofA Corp.” means Bank of America Corporation. “Benefits OnLine” means the internet website provided by Merrill to an Employer and their Plan participants as part of the record-keeping services Merrill Lynch provides to an Employer’s Plan. “Brochure” means the Merrill program brochure relating to Advice Access, as amended or updated from time to time. “Code of Ethics” means Merrill’s Investment Adviser Code of Ethics. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “FAS” means the Merrill Lynch Fiduciary Advisory Services Program. “Financial Advisor” means a Merrill Financial Advisor or other applicable financial professional. “Financial Expert” means the Financial Expert, appointed by Merrill that is responsible for constructing strategic asset class level portfolio models in Advice Access. “FINRA” means the Financial Industry Regulatory Authority, Inc. “Investment Company Act” means the Investment Company Act of 1940, as amended. “IRS” means the Internal Revenue Service. “Merrill,” “MLPF&S,” “we” or “us” means Merrill Lynch, Pierce, Fenner & Smith Incorporated. “PersonalManager®” means the discretionary investment management feature of Advice Access. “PersonalManager Fee” means the quarterly fee for the service. “Plan” means the defined contribution Plan sponsored by the participant’s employer. “Portfolio Rebalancing” means a service in which Plan participants enroll to implement asset allocation and investment recommendations or selections. “Reallocation” means the automatic placement of a participant’s account into a different portfolio model by PersonalManager, if applicable, after review of the participant’s information and the specific investment allocation percentages that comprise the portfolio model. “Rebalancing” means the periodic rebalancing of the participant’s account by PersonalManager to the participant’s current asset allocation to adjust for investment gains and losses across the asset classes. “Restricted Assets” means certain securities or holdings that a Plan Sponsor or participant has restricted or limited the sale of within the PersonalManager service, and assets included in any self-directed brokerage account the participant maintains in the Plan. “SEC” means the U.S. Securities and Exchange Commission. “Securities Act” means the Securities Act of 1933, as amended. “Service Representative” means a Retirement & Benefits Contact Center Representative at a designated Merrill call center to which Plan participants will have access. Unless otherwise noted, registered service marks and service marks are the property of BofA Corp. © 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated. Printed in the U.S.A. 26 AA2A 03-25 

MERRILL GUIDED INVESTING merrilledge.com/guided-investing WRAP FEE PROGRAM BROCHURE Please retain for your records Managed Account Advisors LLC 101 Hudson Street Jersey City, NJ 07302 201.557.0504 Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 888.637.3343 (Main) 888.654.6837 (Program) www.merrilledge.com This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and Managed Account Advisors LLC (“MAA”) relating to Merrill Guided Investing (the “Program”), an online investment advisory program. Information about the Program, including a copy of this Brochure, can be accessed at merrilledge.com/guided- investing. Additional information about MAA and MLPF&S also is available on the SEC’s website at adviserinfo.sec. gov. If you have any questions about the contents of this Brochure, please contact us at 877.444.0916. Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. , MAA or Bank of America Corporation ( BofA Corp.) or any of their affiliates and are subject to investment The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (FDIC) or any other government agency, are not a deposit or other obligation of or guaranteed by MLPF&S risks, including possible loss of principal. March 21, 2025 Merrill Edge, available through Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”), consists of Merrill Edge Advisory Center (investment guidance) and self-directed online investing. MLPF&S is a registered broker-dealer, Member SIPC and a wholly owned subsidiary of Bank of America Corporation. Investment products: Are Not FDIC Insured May Lose Value Are Not Bank Guaranteed Are Not Insured by Any Federal Government Agency Are Not Deposits Are Not a Condition to Any Banking Service or Activity © 2025 Bank of America Corporation. All rights reserved. To learn about Bank of America’s environmental goals and initiatives, go to bankofamerica.com/environment. Leaf icon is a registered trademark of Bank of America Corporation. MGI-2A 032125  ITEM 2. MATERIAL CHANGES On March 22, 2024, MLPF&S and MAA together filed their last annual update to its Merrill Guided Investing program brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. It also sets forth changes as well as enhancements made in this annual update as well as those made since the 2024 annual update, which were previously communicated. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated Item 9 “Additional Information” at the heading “Disciplinary Information” to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our financial advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Item 9 Compensation, Conflicts of Interest and Material Relationships—Third-Party Firm Business Relationships and Support.” • We have updated our disclosures throughout the Brochure to make other enhancements. MATERIAL CHANGES AND ENHANCEMENTS MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: August 23, 2024 Brochure Update Material Changes and Enhancements • We have modified and added disclosures to describe the optional tax efficient management overlay services from MAA (“TEM Overlay Services”) that a client can now elect for a taxable Account with a Growth-Focused Goal enrolled in the Program. In particular, we updated disclosures in Items 4 and 6 to include descriptions of the optional TEM Overlay Services and the particular risks and limitations associated with the TEM Overlay Services, if elected. October 18, 2024 Brochure Update Material Changes and Enhancements • We updated “Item 9 Additional Information” at the heading “Disciplinary Information” to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” • We have updated our disclosures throughout the Brochure to make other enhancements. Merrill Guided Investing Brochure | 2 MGI-2A 032125 Item 3. Table of Contents About Us and the Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Item 4. Services, Fees and Compensation . . . . . . . . . . . . . . . . . . . . 5 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Electronic Accessibility Requirement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Investment Advice Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Establishing Your Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Investment Advice Services for Accounts Selecting the Growth-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Recommending a Target Asset Allocation for the Growth-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Recommending a Strategy for the Growth-Focused Goal Type . . . . . . . 7 Investment Advice Services for Accounts Selecting the Income-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Recommending a Target Asset Allocation for the Income-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Recommending a Strategy for the Income-Focused Goal Type . . . . . . . 9 Effect of Withdrawal Changes and Withdrawals on an Income-Focused Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Annual Review of Withdrawal Amount. . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Investment and Trading Authority; MAA’s Role . . . . . . . . . . . . . . . . . . . . 10 Reasonable Investment Restrictions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Available Strategies, Profiles and Prospectus Delivery. . . . . . . . . . . . . 11 Program Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Treatment of Cash Balances in your Account . . . . . . . . . . . . . . . . . . . . . 12 Brokerage, Banking-Related and Custodial Arrangements and Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Brokerage Trading Services Generally . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Rules for Cash Accounts and Margin Transactions . . . . . . . . . . . . . . . . 13 Cash Sweep Program and Other Banking-Related Services . . . . . . . . . 13 Custodial Arrangements and Services . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Account Features . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Proxy Voting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Trade Confirmation Statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Electronic Delivery Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Optional Account Services for Growth-Focused Goals . . . . . . . . . . . . . 14 MAA Tax Efficient Management Overlay Services. . . . . . . . . . . . . . . . . 14 Automatic Withdrawal Service for Growth-Focused Goals . . . . . . . . . . 15 The Program Fee and Other Charges. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 The Program Fee Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Calculation and Payment of the Program Fee. . . . . . . . . . . . . . . . . . . . . 16 Deduction of the Program Fee from Your Account . . . . . . . . . . . . . . . . 16 Determination of how the Program Fee is Charged . . . . . . . . . . . . . . . 16 Fees and Expenses Not Covered by the Program Fee . . . . . . . . . . . . . . 16 Item 5. Account Requirements and Types of Clients . . . . . . . . . 22 Item 6. Portfolio Manager Selection and Evaluation . . . . . . . . . 22 Review and Selection of Strategies and Funds Available in the Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 CIO Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Strategy Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Available Information Regarding Strategies and Funds . . . . . . . . . . . . 23 Advisory Services Provided by Merrill and Certain Affiliates . . . . . . . 24 Tailored Investment Advice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Performance-Based Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Methods of Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Investment Strategies and Risk of Loss . . . . . . . . . . . . . . . . . . . . . . . . . . 24 General Risks of Investing Through the Program. . . . . . . . . . . . . . . . . . 24 Particular Risks Regarding the Income-Focused Goal . . . . . . . . . . . . . . 25 Particular Risks Regarding the TEM Overlay Services. . . . . . . . . . . . . . 25 Use of Strategies Where Merrill Is the Manager . . . . . . . . . . . . . . . . . . 25 Information and Cybersecurity Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 ESG themed Strategies or Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 ETF Investing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Mutual Funds and Non-traditional Funds . . . . . . . . . . . . . . . . . . . . . . . . 28 Securities-based Lending with your Account . . . . . . . . . . . . . . . . . . . . . 28 Voting Client Securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Item 7. Client Information Provided to Portfolio Managers . . 28 Item 8. Client Contact with Portfolio Managers. . . . . . . . . . . . . . 29 Item 9. Additional Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Disciplinary Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Other Financial Industry Activities and Affiliations . . . . . . . . . . . . . . . . 29 Conflicts of Interest and Information Walls. . . . . . . . . . . . . . . . . . . . . . . 30 Code of Ethics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Compensation, Conflicts of Interest and Material Relationships . . . . 30 Compensation and Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Account and Program Choice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Variable Compensation by Product and Service . . . . . . . . . . . . . . . . . . . 31 Compensation Received by Us for Sub-accounting Services . . . . . . . . 32 Mutual Fund Arrangements and Compensation . . . . . . . . . . . . . . . . . . . 32 Cash Sweep Program Compensation Received by Us and Our Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Offering of Investments or Programs Managed by Us or Our Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Other Compensation Received by Us and Our Affiliates. . . . . . . . . . . . 33 Third-Party Firm Business Relationships and Support . . . . . . . . . . . . . 33 Provision of Diversified Financial Services by Us and our Affiliates . . 34 Participation or Interest in Client Transactions and Conflicts of Interest. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Cash Balances and Cash Sweep Program . . . . . . . . . . . . . . . . . . . . . . . . 35 Participation in Affiliate Lending Programs and Margin . . . . . . . . . . . . 35 Activity by Merrill, Affiliates and Personnel . . . . . . . . . . . . . . . . . . . . . . 35 Trade Execution. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Covered Entities under the Volcker Rule . . . . . . . . . . . . . . . . . . . . . . . . . 36 Account Reviews and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Referrals and Other Arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Financial Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Ability to Obtain Certain Services Separately and for Different Fees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Funding and Operation of Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Establishing an Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Funding Your Account. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Withdrawal Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Required Withdrawals for Income-Focused Goals . . . . . . . . . . . . . . . . . 19 Changing Your Strategy.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Termination of Enrollment in the Program . . . . . . . . . . . . . . . . . . . . . . . 19 Cash Balances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Legal Matters and Related Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Your Responsibilities for Account Operation and Management. . . . . . 20 Tax Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 General Tax Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Special Risks and Limitations associated with the TEM Overlay Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 All capitalized terms used in the Brochure are defined in the body of this Brochure or in the Glossary. Merrill Guided Investing Brochure | 3 MGI-2A 032125  About Us and the Program Both Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and its Affiliate, Managed Account Advisors LLC (“MAA”), offer investment advisory services under the Merrill Guided Investing Program (“Program”) as discussed in this Form ADV Brochure (“Brochure”). Both MLPF&S and MAA are registered with the U.S. Securities and Exchange Commission (“SEC”) as investment advisers and MLPF&S is registered as a broker dealer. Both Merrill and MAA provide services under the Program in their capacity as a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Our parent company, Bank of America Corporation (“BofA Corp.”), through Bank of America, N.A. (“BANA”) and other of its Affiliates, provides integrated investment services and is a leading banking institution for consumers, corporations and institutions. When we use the terms “Merrill,” “we,” “our” or “us” in this Brochure, we are generally referring to MLPF&S. We also use the terms “Merrill,” “we,” “our” or “us” to apply to both MLPF&S and MAA for those aspects and services of the Program that MLPF&S and MAA perform jointly. We also indicate where certain services are provided by MAA in its separate capacity. Our Services as an Investment Adviser and Relationship with You under the Program. The Program is designed to help you pursue your investing goals by providing you with investment advice, guidance and access to advisory services and investment solutions and other services as described in this Brochure (“Services” or “Program Services”) delivered through the Program’s interactive website at merrilledge.com/guided-investing (the “Program Website”). By accessing the Program Website, you work with our interactive profiling and goal setting process (the “Online Profiling Process”) to establish your goal and objective and select an aligned investment strategy available in the Program and receive the other services described in this Brochure. Generally, the Program is designed for clients who are • Comfortable with online access. • Want to receive the Program Services, including target asset allocation and other monitoring as described in this Brochure. • Are comfortable with the investment choice of a limited set of managed investment strategies complementary to their investment profile. • Are willing to pay an asset-based fee for investment solutions through managed investment strategies. The Program is generally not for clients who have more complex needs, desire access to a larger offering of investment solutions and strategies or have a preference for frequent in-person interactions with a dedicated financial advisor. To obtain the Program Services, you must first electronically enter into a written agreement with us (the “Agreement”). The Agreement defines the scope of the investment advisory relationship with you and sets forth our obligations to you for the Merrill account that you enroll in the Program (“Account”). In the Agreement, we agree to act as your investment adviser and agent to provide the Services described in this Brochure and you grant to us the investment discretion and trading authority necessary to deliver the Services you select and agree to the terms and conditions of the Program. After you are enrolled in the Program, you may be able to select or change certain Services with instructions to us; however, in certain circumstances we may ask you to sign a separate Agreement or complete additional documentation. This Brochure describes the advisory services that we provide, the fees you will pay, our role and that of our personnel, our other business activities and financial industry affiliations and the economic and other benefits and arrangements we have that create conflicts of interest in certain situations. We will provide disclosure documents called the Form ADV Part 2B-Brochure Supplements for Merrill investment professionals who provide portfolio management services for the investment strategies we offer in your Program enrollment materials. If you inform us that you wish to terminate an Account’s enrollment in the Program, we will end that investment advisory relationship with respect to that Account and will cause that account to be converted to, and designated as, a Merrill brokerage account. Termination of your Agreement will end the investment advisory relationship of any Account enrolled in the Program and any such Accounts will be converted to a brokerage account. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in our Client Relationship Summary on Form CRS (“Form CRS”) and in our Summary of Programs and Services, both of which are available at merrilledge. com/relationships or upon request. In addition, these documents provide a summary of the other available investment advisory programs we offer. Certain aspects of these investment advisory programs are similar to the Services available in the Program. Please refer to Item 4 at the section “Ability to Obtain Certain Services Separately and for Different Fees.” Under the Program, we are a fiduciary to you. Merrill and MAA each have certain fiduciary obligations in providing the Program Services. As a fiduciary, we will act in your best interest and will endeavor to provide you material facts and information relating to the Program Services. The Brochure is a key element in meeting this disclosure obligation. The fiduciary standards we aim to follow are established under the Advisers Act and, where applicable, state laws. In addition, for Retirement Accounts, we provide Program Services as a “fiduciary” under Section 3(21) of the Employee Retirement Income Security Act of 1974 (“ERISA”) and under the Internal Revenue Code of 1986 (the “Code”). For Retirement Accounts subject to ERISA that are discretionary managed accounts, we provide the relevant Program Services as an “investment manager” under Section 3(38) of ERISA. Merrill Guided Investing Brochure | 4 MGI-2A 032125Merrill Guided InvestingWrap Fee Program Brochure Item 4. Services, Fees and Compensation General The Program is designed to help you pursue your investing goals by providing you with the Program Services through the Program Website, including investment advice, guidance and access to a select set of managed investment strategies (“Strategies”) delivered through the Program’s Website. Before investing through the Program, please read the description of our Services and the other information in this Brochure. You may contact us at 877.444.0916 if you have any questions. Electronic Accessibility Requirement The Program provides you with the Services described in this Brochure electronically through use of the Program Website. Through an online experience, you will be asked to provide us with certain information, consider and (if acceptable) select a recommendation from us. You will also be provided with information and periodically contacted about the ongoing management of your Account through the same online experience. You should carefully consider whether your participation in the Program is appropriate for your investment needs and goals. You must log in to the Program Website to access important documents, ensure your information is accurate and up to date and complete periodic reviews. You can communicate with us through the Program Website or by telephone at 877.444.0916. You will be required to sign the Agreement and other agreements necessary to participate in the Program electronically. These agreements and other disclosures and notices will be delivered to you in electronic format only, by posting the information on the Program Website where you access your Account, through email or other electronic means. We will not send you paper versions of documents as part of the Program unless required by applicable law or in our sole discretion. In order to access the Program Website, you will be required to establish or link your online credentials (“User ID”). You are solely responsible for user activity that occurs in your Account and the information provided to us through the Program Website. You are also responsible for maintaining the security and confidentiality of your Account access information. You must notify us immediately if you believe your Account has been accessed in an unauthorized manner or the security and confidentiality of your access information have been compromised. For accounts with more than one owner, each additional account owner who wishes to have access to the Program Website will need to create their own User ID and password. While each additional owner is not required to create a User ID to enroll in the Program, if you elect not to create a User ID, only the account owner who originally enrolled the account into the Program will have access to the Program Website. You will have access to Program documents, notices and disclosures by logging on to the Program Website. You will also be notified via the email address you provided to us when documents are available for viewing in the “Statements and Documents” section of the Program Website. You must provide us with a valid email address as a requirement to enroll in the Program. You are required to immediately notify us of any changes to your email address by updating your information via the Program Website or by calling us at 877.444.0916. Failure to provide accurate contact information could result in termination from the Program. If we are notified that the email address you provided is invalid, we will attempt to contact you by other means to request a valid email address. If you do not provide a valid email address, your enrollment in the Program may be terminated. In addition, if, at any time while you are enrolled in the Program, you do not have access to a device with the necessary hardware and software or are unwilling to sign electronically or to accept electronic delivery of all Program documents and communications, you will not be able to continue to be enrolled in the Program and you should contact us at the number above to understand your options. For additional details related to electronic communications, please refer to the eCommunications Disclosure in the enrollment documents for the Account available on the Program Website. Investment Advice Services Establishing Your Account. The Program Website will help you establish an Account for the assets that you identify. Eligible Account types are a taxable (or non-retirement) account and a Retirement Account, which is an individual retirement account within the meaning of Section 408(a) of the Code, a simplified employee pension within the meaning of Section 408(k) of the Code, a simple retirement account within the meaning of Section 408(p) of the Code, and a Roth IRA within the meaning of Section 408A of the Code. An Account is eligible to enroll in the Program, receive the Program Services and access the Strategies available in the Program. The Program Website contains an Online Profiling Process that will help you establish a goal and select a recommended target asset allocation and an investment strategy described below for your Account. Through this process, you will be asked to provide us with certain information about your objectives and goal for your Account. Each Account will be tied to a single investing goal type that you select and name. Through the Program Website, we request certain information and ask questions to gather information about you, including important financial and personal information that will be used as the basis for our investment recommendations. It is your responsibility to ensure that the information you provide to us is complete and accurate. When you provide accurate and complete information, we will be better able to make suitable recommendations for your Account assets. It is also your responsibility to notify us if any information you have provided to us about you is inaccurate or becomes inaccurate. If there are multiple owners on this Account, the information you provide should reflect the views and circumstances of all owners on the Account. If you are the fiduciary of this Account for the benefit of the account owner or account holder (e.g., the trustee for a trust or custodian for an UTMA), please keep in mind that these assets will be invested for the benefit of such account owner or account holder. If you feel any of the questions are unclear or you do not understand why the information is being sought, please contact us at 877.444.0916. Be careful when inputting your answers or information. If you enter inaccurate information, the resulting recommendation might not be right for you. The Program incorporates only the financial information you provide, and our investment recommendations are limited to and based only on certain information you provide through the Program Website. We will not independently verify the information you provide through the Program Website and we will not consider other information obtained in connection with another account or relationship with Merrill or its Affiliates other than as described in this Brochure and the Agreement. If you believe there is additional financial information that should be considered to inform the investment recommendations made through the Program, please contact us at 877.444.0916. Merrill Guided Investing Brochure | 5 MGI-2A 032125 You may select between two investing goal types: the Growth-Focused goal type and the Income-Focused goal type. The Growth Focused goal type is designed for general investing, retirement investing and other types of investing goals seeking to grow assets through investing over time for current income and growth (“Growth-Focused Goal”). The Income-Focused goal type is designed for a retirement investing goal seeking to use assets while investing over a defined time period for income (“Income-Focused Goal”). The goal type that you select along with other information about you will help determine the recommended target asset allocation and investment strategies available to you for your particular goal. As part of establishing the Account with an investing goal, we will recommend an allocation of your assets across one or more asset classes (“Target Asset Allocation”) for your goal and a Strategy designed to align to that Target Asset Allocation and the specific needs of your Account. We make available in the Program a select set of Strategies that are managed by us that consist of diversified portfolios of exchange-traded funds (“ETFs”), mutual funds and a cash allocation that are designed to meet a particular Target Asset Allocation and objective. The Account’s cash allocation can be in various amounts for one or more investment and/or operational purposes at the same or different times as described throughout this Brochure. Once your Account is established, we will monitor the assets in your Account for alignment with the Strategy’s allocation as part of our advice and guidance. If appropriate, we will make recommendations regarding changes to your Account, including changes to the Strategy you selected. Investment Advice Services for Accounts Selecting the Growth-Focused Goal Type The Growth-Focused Goal type includes the general investing goal and investing for specific types of goals such as travel, home and education that seek to grow assets through investing over time for current income and growth. The Growth-Focused Goal type also includes investing for retirement for a person who is five or more years away from retiring and who does not intend to use the assets to pay for retirement expenses in the near term. If you’ve already retired and one or more of these scenarios applies, this goal could be appropriate for you if: • You intend to fund most of your retirement expenses through other sources such as Social Security, pension, wages or other savings. • You don’t expect to use most of the assets during retirement. • Your goal is to build your assets. • You expect to leave most of these assets to your heirs rather than spend the funds in retirement. Recommending a Target Asset Allocation for the Growth-Focused Goal Type. As part of establishing the Account, we will recommend a Target Asset Allocation for the Growth-Focused Goal and a Strategy designed to align to that Target Asset Allocation and the specific needs of your Account. We make available a select set of Strategies that are managed by us that consists of diversified portfolios of ETFs, mutual funds and a cash allocation that are designed for a particular Target Asset Allocation that balance the goals of achieving current income and growth (“Total Return-Focused Strategies”). Once your Account is established, we will monitor the assets in your Account for alignment with the Strategy’s allocation as part of our advice and guidance. If appropriate, we will make recommendations regarding changes to your Account, including changes to the Strategy you selected. Setting the Risk Tolerance and Time Horizon. The Strategy you select will be based on responses and information you provide for your goal, including the risk tolerance for the Account assets (i.e., your willingness and ability to incur financial loss for the assets in your Account in exchange for greater potential returns) and the time horizon (determined by how long you expect to invest to seek to achieve your goal). For a retirement investing goal, the time horizon is based on a combination of your stated retirement age and how long you intend to use the assets in your Account after retirement. The risk tolerance options are low, medium, or high, as described below: • A “low” risk tolerance means your primary concern is preserving your capital. Inflation-adjusted returns may be very low or negative balanced by high liquidity and reduced risk of principal loss. • A “medium” risk tolerance means you’re willing to accept some principal loss while pursuing a higher possible total return. Diversification and asset allocation helps to reduce this level of risk. • A “high” risk tolerance means you’re willing to accept the risk of possible loss of principal because you think that overall portfolio results may provide above average returns. These investors may hold concentrated positions and trade frequently. Results may vary widely from one year to the next in the pursuit of longer-term goals. Option to Set a Goal Target. You also have the option, at your election, through the Online Profiling Process or the Program Website, to state a target goal dollar amount (the “Goal Target”) for the goal aligned with your Account. If you provide a Goal Target, this information will be used in addition to your other information (such as your risk tolerance and time horizon) to recommend the Target Asset Allocation and the aligned Strategy. Depending on the amount of the Goal Target, the recommended Target Asset Allocation and Strategy may be different than the one recommended when no Goal Target is provided. The identification of a Goal Target does not constitute a guarantee by us of the future value of the Account or any specific level of performance or rate of return for the Account or any Target Asset Allocation or Strategy that we recommend or undertake on your behalf. There is no guarantee that you will achieve your Goal Target. The recommendations provided for each Account are intended to align and are limited to the specific investing goal for that Account. Additional investing goals will require that you set up additional Accounts. If stating a Goal Target, you have the option to align certain other assets not held in your Account (“External Assets”) to your Goal Target for the Account. You can link External Assets maintained in accounts with us or our Affiliates that we determine to be eligible in our sole discretion (“Linked accounts”). You can also enter information about External Assets maintained in accounts at a firm that is not our Affiliate that we determine to be eligible in our sole discretion (“External accounts”). Not all accounts with External Assets are appropriate for you to align to your Goal Target for the Account. Please see the Program Website for additional information. If you choose to align External Assets to an Account’s Goal Target, we will provide advice and manage your Account based, in part, on information available or provided for the dollar value balance and asset allocation of these External Assets. Aligning External Assets to your Account’s goal and Goal Target may produce a different Target Asset Allocation recommendation than if they had not been so aligned. The composition of the External Assets, market volatility and conditions and changes that you may make to your External Asset holdings will have an impact on reaching your Goal Target. We are not an investment adviser with respect to External Assets and do not advise you on External Assets. For Linked accounts, we will periodically review the dollar value balance and asset allocation. For External accounts, it is your responsibility to keep the External Asset information you align to a Goal Target updated. It is important for you initially and on an ongoing basis to update the dollar value balance and Merrill Guided Investing Brochure | 6 MGI-2A 032125 to classify the External Assets into the appropriate asset class. If the External Asset information is not accurate and complete, the recommended Target Asset Allocation and Strategy for your Account will be affected. In certain circumstances, you will be contacted to consider how changes to External Asset information might impact the Strategy for your Account. Target Asset Allocation Categories. In general, the Target Asset Allocation categories are: • Conservative: primary focus is on portfolio stability and preservation of capital with the achievement of low or negative investment returns in exchange for reduced risk of loss of principal and liquidity. • Moderately Conservative: primary focus is to achieve a modest level of portfolio appreciation with minimal principal loss and volatility. • Moderate: primary emphasis is to strike a balance between portfolio stability and portfolio appreciation with the assumption of moderate level of risk and level of volatility and principal loss. • Moderately Aggressive: primary emphasis is on achieving portfolio appreciation over time with the assumption of a fair amount of risk, and high level of volatility and risk of principal loss. • Aggressive: primary emphasis is on achieving above-average portfolio appreciation over time with the assumption of substantial risk and a significant level of portfolio volatility. Each of these categories have associated asset class allocation ranges. The associated allocation ranges and our method of monitoring activity may change from time to time and without prior notice to you. Our more conservative Target Asset Allocations typically recommend a greater percentage of your assets be allocated to fixed-income and cash asset classes, rather than to the equity asset class. Our more aggressive Target Asset Allocations typically recommend a greater percentage of your assets be allocated to the equity asset class, rather than to fixed-income and cash asset classes. You should consider carefully the recommended Target Asset Allocation for your Account. We will use your Target Asset Allocation, along with certain other information provided by you through the Online Profiling Process, to assist in recommending a Strategy for your Account. Any changes to your risk tolerance or time horizon or, if applicable, Goal Target and any aligned External Assets may lead to a different recommended Target Asset Allocation and therefore potential changes to the Strategy recommended for your Account. It is your responsibility to ensure that the information you provide to us through the Online Profiling Process is complete and accurate so that we will be better able to make appropriate recommendations for you and your Account assets. As part of the Program Services, we use wealth management planning tools that provide hypothetical projections of possible investment outcomes for the asset classes included in the recommended Target Asset Allocation based on certain information you provide as part of the Online Profiling Process and through the Program Website for the Account (an “Allocation Profile”). Hypothetical projections and analyses do not reflect or project actual investment performance of your Account, the TEM Overlay Services (if elected) and the Strategy you select or the underlying securities in the Strategy and are not guarantees of future results. Any hypothetical projections presented through the Program Website make use of probabilistic modeling, a statistical modeling technique in which a set of future outcomes are forecasted based on the variability or randomness associated with historical occurrences. For an Account without a Goal Target, the projections presented illustrate possible investment outcomes determined by the use of probabilistic modeling based on our forward-looking return assumptions for the asset classes included in the recommended Target Asset Allocation and based on certain information you provided as part of the Online Profiling Process and through the Program Website for an Allocation Profile. For more information about how these projections are calculated, how the information you provide is used, the assumptions used and limitations of these projections, please consult the “Hypothetical Projections Tool” document available on the Program Website. As part of the Program Services, we also use a wealth management tool to provide you with the ability to track your progress to your Goal Target, if desired. No representation is made that the Strategy will achieve the Goal Target and the actual returns for your Account could be significantly higher or lower than the Goal Target. For the purposes of these projections, any External Assets in Linked accounts will have the asset allocation determined by us based upon our asset class designation of the Linked account holdings. External Assets in External accounts will have the asset allocation provided by you through the Program Website and, if you do not provide this information, we will assume these External Assets have the same asset allocation as the Target Asset Allocation for your Account. You should consider these limitations carefully as you review the projections and illustrations for progress to your Goal Target and you should not rely on that information when making an investment decision. For more information about how the projections are calculated, how the information (including information about External Assets) you provide is used, the assumptions used and limitations of the projections, please consult the “Goal Target Funding Status Analysis” document available on the Program Website. Recommending a Strategy for the Growth-Focused Goal Type. After recommending a Target Asset Allocation for your Account with a Growth-Focused Goal Type, we, through the Online Profiling Process will recommend to you one or more Strategies available in the Program. Our advice is based on the information you have provided to us for that Account and is limited by the stated and agreed-upon: (1) size of your investment; (2) Account Target Asset Allocation; (3) Account Strategy; (4) other applicable factors such as the type of Account you establish; and (5) Account investment restrictions, if any, that are accepted as provided in the section “Reasonable Investment Restrictions” below. If you wish to proceed, you will select the recommended Strategy to have implemented in your Account based on the results of the Online Profiling Process. If you wish to utilize multiple Strategies for your investment assets in the Program, you will be required to open a separate Account for each Strategy. Total Return-Focused Strategies. We make available a select set of Strategies managed by us that consists of diversified portfolios of ETFs, mutual funds and a cash allocation that are designed for a particular Target Asset Allocation that balance the goals of seeking current income and growth (“Total Return- Focused Strategies”). The Total Return-Focused Strategies available for the Growth-Focused Goal types are model portfolios of primarily ETFs (but can include mutual funds) and cash and/or cash alternatives (referred to as a cash allocation). The ETFs and mutual funds that are included in a Strategy are referred to as “constituent Funds.” These model portfolios are constructed by MLPF&S through its Chief Investment Office (the “CIO”) and seek to achieve one or more investment styles or disciplines. The Strategies range from “Conservative” to “Aggressive” and include asset allocations to the asset classes of equity, fixed income and cash. The CIO chooses the constituent Funds for the equity and fixed income asset class exposures and determines the overall asset class allocations of a Strategy Merrill Guided Investing Brochure | 7 MGI-2A 032125 to balance the goals of achieving current income and growth. The CIO also selects constituent Funds that can be converted to cash without experiencing a significant loss due to the lack of a ready market or incurring significant costs or penalties. For exposure to the cash asset class, the CIO determines whether to hold cash as a cash balance (which is then swept in accordance with the Account’s cash sweep option), and/or to invest in money market mutual funds (“money market funds”). If no action is taken by the CIO to select a money market fund, cash balances will automatically be swept under the Accounts’ cash sweep option. The cash allocation in a Strategy is for operational and implementation and/or investment purposes as directed by the CIO. The cash allocation will be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations, rebalancings, market conditions and the CIO’s cash management approach and market view and concerns. For more information, see “Item 4 Treatment of Cash Balances in your Account” and “Item 4 Funding and Operation of Accounts-Cash Balances.” Certain Strategies have an investment approach that incorporates two model portfolios from the CIO which are designed to support Accounts at different asset levels. Each Strategy’s model portfolios are designed to align to the relevant Target Asset Allocation and provide similar diverse market exposure. Accounts with higher asset values (generally starting at $5,000 or as otherwise reflected in the applicable Strategy Profile) are allocated among a range of constituent Funds and a cash allocation using CIO’s tactical asset allocation model portfolio (“Tactical Asset Allocation”) for a Strategy. Accounts with lower asset values are allocated among generally a smaller range of constituent Funds and a cash allocation using CIO’s strategic asset allocation model portfolio (“Strategic Asset Allocation”) for a Strategy. Any change from one Strategy to another Strategy will require your consent because you retain authority to select and implement any changes between Strategies. In our discretion, we rebalance an Account to transition between the Strategy’s two model portfolios as its asset value changes over time. As we describe in detail below in “Item 4 Investment and Trading Authority; MAA’s Role,” we will have full trading authority to implement the Strategy selected, including rebalancing to transition an Account between the Strategy’s two model portfolios as the Account’s asset value changes over time. The availability of Strategies in the Program is subject to change. You can review materials available on the Program Website. The Program Report (also referred to as a Portfolio Summary) that we will deliver to you through the Program Website upon enrollment will indicate the Strategy in which you are invested. We may reference this Strategy or use the term “Managed Strategy” as a caption name or reference in the Program Report. Any changes to a different Strategy for your Account will result in an updated Program Summary that will be made available to you through the Program Website. Investment Advice Services for Accounts Selecting the Income-Focused Goal Type As part of establishing the Account, you can select the Income-Focused Goal type for either a taxable Account or a Retirement Account. The Income- Focused Goal type is for a retirement investing goal that seeks to use assets while investing over a defined time period for income and is designed for retirees or those retiring in fewer than five years. In addition, if one or more of these scenarios applies, this goal type could be appropriate for you if: • You expect to use the assets for retirement expenses for up to 25 years. • You expect to use most of the assets to generate a steady income during retirement. As part of establishing the Account, we will recommend a Target Asset Allocation for the Income-Focused Goal and a Strategy designed to align to that Target Asset Allocation and the specific needs of your Account. We make available a select set of Strategies that consists of ETFs and a cash allocation and that are designed for a particular income-focused Target Asset Allocation seeking to obtain a continuing stream of income from investments and that changes over time, and for recurring Account withdrawals through a stated end year (“Income-Focused Strategies”). Once your Account is established, we will monitor the assets in your Account for alignment with the Strategy’s allocation as part of our advice and guidance. If appropriate, we will make recommendations regarding changes to your Account, including changes to the Strategy you selected. Recommending a Target Asset Allocation for the Income-Focused Goal Type. The Strategy you select will be based on responses and information you provide for your goal, including the risk tolerance for the Account assets (i.e., your willingness and ability to incur financial loss for the assets in your Account in exchange for greater potential returns) and the time horizon (determined by when you would like to start receiving income and for how long you would like to receive income). The risk tolerance options are low, medium, or high, as described below: • A “low” risk tolerance means that you are not willing or able to take much risk for your income needs. You’d like a higher initial income and are willing to accept minimal risk to have lower potential increases to future income and a remaining balance. • A “medium” risk tolerance means that you are willing and able to take a moderate level of risk for your income needs. You’d like a modest initial income and are willing to accept some risk to have more potential for increases to future income and a remaining balance. • A “high” risk tolerance means that you are willing and able to take a higher level of risk for your income needs. You’d like a lower initial income and are willing to accept more risk to have greater potential increases to future income and a remaining balance. The time horizon begins with the age you reach in the year of Account enrollment in the Strategy and, if different, includes the age you reach in the year you want to start to take recurring withdrawals from the Account and ends in the year of your last withdrawal from the Account. At the end of the time horizon, your Account is expected to have no or a relatively low remaining asset balance. Your investment returns and the withdrawal amounts received over the course of your Account’s time horizon are subject to changes due to general economic conditions, general market fluctuations, and the risks inherent in securities markets. There is no guarantee that sufficient income will be achieved to provide adequate income through your stated end year or throughout retirement. The recommendations provided for each Account are intended to align and are limited to the specific Income-Focused Goal for that Account. Additional Income-Focused Goals will require that you set up additional Accounts. In general, the Target Asset Allocation categories which are designed to seek to obtain a continuing stream of income from investments are: • Stable Income: a low risk tolerance and target allocation generally to the fixed income asset class. • Balanced Income: a medium risk tolerance and target allocations of a mix of fixed income and equity asset classes that will change over time. • Income and Growth: a high risk tolerance and target allocations of a mix of fixed income and equity asset classes that will change over time. Merrill Guided Investing Brochure | 8 MGI-2A 032125 Each of these categories have associated asset class allocation ranges. The associated allocation ranges and our method of monitoring activity may change from time to time and without prior notice to you. Our more conservative Target Asset Allocation typically recommend all or most of your assets be allocated to the fixed-income asset class rather than to the equity asset class. Our more aggressive Target Asset Allocation typically recommend a greater percentage of your assets be allocated to the equity asset class rather than to fixed-income asset class. You should consider carefully the recommended Target Asset Allocation for your Account. We will use your Target Asset Allocation, along with certain other information provided by you through the Online Profiling Process, to assist in recommending a Strategy for your Account. Any changes to your risk tolerance or time horizon may lead to a different recommended Target Asset Allocation and therefore potential changes to the Strategy recommended for your Account. It is your responsibility to ensure that the information you provide to us through the Online Profiling Process is complete and accurate so that we will be better able to make appropriate recommendations for you and your Account assets. As part of the Program Services, we use wealth management planning tools that provide hypothetical projections of investment and income amounts for the asset classes included in the recommended Target Asset Allocation based on your Allocation Profile. Hypothetical projections do not reflect or project actual investment performance of your Account, the investment performance of any assets held by you outside the Account (e.g., Social Security), the Strategy you select or the underlying securities in the Strategy and is not a guarantee of future results, including future income. The hypothetical projections present possible income-focused investment outcomes determined by the use of probabilistic modeling based on our forward-looking return assumptions for an Allocation Profile. For more information about how these projections are calculated, how the information you provide is used, the assumptions used and limitations of these projections, please consult the “Hypothetical Income Projections Tool” document available on the Program Website. Recommending a Strategy for the Income-Focused Goal Type. After recommending a Target Asset Allocation for your Account with an Income- Focused Goal Type, we, through the Online Profiling Process will recommend to you one or more Strategies available in the Program. Our advice is based on the information you have provided to us for that Account and is limited by the stated and agreed-upon factors as follows: (1) size of your investment; (2) Account Target Asset Allocation; (3) Account Strategy; (4) other applicable factors such as the type of Account you establish; and (5) Account investment restrictions, if any, that are accepted as provided in “Reasonable Investment Restrictions” below. If you wish to proceed, you will select the recommended Strategy to have implemented in your Account based on the results of the Online Profiling Process. If you wish to utilize multiple Strategies for your investment assets in the Program, you will be required to open a separate Account for each Strategy. Income-Focused Strategies. We make available a select set of Strategies that are designed for a particular income-focused Target Asset Allocation seeking to obtain a continuing stream of income from investments and that changes over time and for recurring Account withdrawals through a stated end year (“Income-Focused Strategies”). The Income-Focused Strategies available for Income-Focused Goal types are model portfolios constructed by MLPF&S, through its CIO that consist of constituent Funds (primarily ETFs but can include mutual funds) and cash and/or cash alternatives (referred to as a cash allocation). The Income-Focused Strategies range from “Stable Income” to “Income and Growth.” The availability of Strategies in the Program is subject to change. You can review materials for the Income-Focused Strategies on the Program Website. The Program Report that we make available to you through the Program Website will indicate the Strategy in which you are invested. We may reference this Strategy or use the term “Managed Strategy” as a caption name or reference in the Program Report. Any changes to a different Strategy for your Account will result in our providing you an updated Program Report through the Program Website. The Income-Focused Strategies include investment allocations by the CIO to one or both of the fixed income and equity asset classes and a cash allocation. The CIO chooses the constituent Funds for one or both of the equity and fixed income asset class exposures and determines the overall allocations of an Income-Focused Strategy that aim to obtain your hypothetical projected income. The CIO also selects constituent Funds that can be converted to cash without experiencing a significant loss due to the lack of a ready market or incurring significant costs or penalties. The Strategy’s cash allocation is primarily designed to support anticipated withdrawals in a particular year based on your Account instructions for a fixed time period of up to 25 years that begins in your designated year and ends in a future stated year. You may choose the desired income (or withdrawal) start date up to five years after Account enrollment (the “Accumulation Phase”), after which there will be a “Decumulation Phase” of up to 25 years during which you receive recurring withdrawals. At the end of the fixed time period (based on your time horizon), your Account is expected to have no or a relatively low remaining asset balance. Your investment returns and the withdrawal amounts received over the course of your Account’s time period are subject to changes due to general economic conditions, general market fluctuations, and the risks inherent in securities markets. There is no guarantee that sufficient income will be achieved to provide adequate income through your stated end year or throughout retirement. A portion of the cash allocation can also be for operational and implementation and/or investment purposes as directed by the CIO. The cash allocation will be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations, rebalancings, market conditions and the CIO’s cash management approach and market view and concerns. For the cash allocation, the CIO determines whether to hold cash as a cash balance (which is then swept in accordance with the Account’s cash sweep option) and/or to invest in money market funds. In certain circumstances, including periods of volatile or uncertain market conditions, the CIO may determine that the cash allocation comprise all or a substantial portion of a particular Strategy’s model portfolio for defensive purposes. Some portion of your Account assets will be held as cash for operational considerations. For more information, see “Item 4 Treatment of Cash Balances in your Account” and “Item 4 Funding and Operation of Accounts-Cash Balances.” As described in more detail below in “Item 4 The Program Fee and Other Charges,” the cash in the Account will be subject to the Program Fee. Effect of Withdrawal Changes and Withdrawals on an Income-Focused Strategy. You should understand that changes made to the amount of recurring withdrawals and any unscheduled cash withdrawals will result in changes to the amount of recurring withdrawals that you will receive over the term of your Strategy. Choosing an amount of recurring withdrawals that is higher than the hypothetical projections or actual income received or making unscheduled withdrawals will result in lower hypothetical projections in future years and reduce the amount of recurring withdrawals that will be supported over the term of your Strategy. In addition, if the value of your Account drops below the required minimum, due to unscheduled withdrawals or recurring withdrawals that exceed the hypothetical projections, or otherwise, we may determine that the Strategy is no longer appropriate for you and your Account will be subject to termination. You will have the opportunity to monitor hypothetical projections and manage the amount of recurring withdrawals as a part of the annual review, as described in more detail below. Merrill Guided Investing Brochure | 9 MGI-2A 032125 Depending on numerous factors, including if you make unscheduled withdrawals from your Account, if the value of the assets in your Account drops to an amount that is at or below a certain dollar amount, we may be unable to rebalance the investments in your Account to reflect any changes in the Strategy’s allocation. In addition, as your Account approaches its future stated year, it is expected that the portion of your Account comprising the cash allocation will increase relative to the portion comprising ETFs. This may also result in our inability to rebalance the investments in your Account to the Strategy’s allocation. Annual Review of Withdrawal Amount. Each year your Account is subject to a mandatory annual review of the next year’s withdrawal amount. We require that you complete the annual review when prompted by us within two weeks of receiving a notification. As a part of the annual review, you must confirm certain information regarding your Account, including the amount and frequency of the recurring withdrawals you would like to receive for the next calendar year based on the hypothetical projected income amount. We will provide an updated hypothetical projection of investment and income for the next calendar year and other information relevant to your Strategy. If you do not provide the requested information, we will continue to apply the terms applicable to your Account from the current year. Failure to complete the annual review may result in recurring withdrawals that are inconsistent with the hypothetical projections and this may cause you to withdraw on a recurring basis amounts that are higher than the projections. As discussed above, recurring withdrawals that exceed the hypothetical projections will result in a lower amount of future recurring withdrawals over the term of your Strategy. For additional information on withdrawals, including special processing guidelines, see “Item 4 Funding and Operation of Accounts” at the section “Required Withdrawals for Income-Focused Goals.” Investment and Trading Authority; MAA’s Role Pursuant to an agreement between MLPF&S and MAA, MLPF&S provides advisory services through the Program, in part, by furnishing investment recommendations and guidelines to MAA for a Strategy based on one or more model portfolios in accordance with the applicable Profile. All Strategies developed by MLPF&S will be implemented by MAA with full investment and trading discretion. MAA will generally implement the CIO’s recommendations for a Strategy without change, subject to your Reasonable Investment Restrictions, cash commitments and other considerations. MAA may determine, in its sole discretion, in light of operational or investment considerations, to deviate from a model portfolio on a limited basis (i.e., to select another security or increase the cash allocation within a model portfolio). By your choosing a Strategy for an Account, as provided in the Agreement, you have granted MAA investment and trading discretion for investments occurring in the Strategy. Through that discretion, we will have complete trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets in your Account in accordance with your selected Strategy without any prior notice. This authority will remain in place until we have received and accepted instruction from you to either change the Strategy or terminate the Account. As part of your grant of authority described above, MAA has the authority to make certain investment and trading decisions including: • Implementing, as applicable, the model-based recommendations or other investment guidelines and/or instructions of the CIO. • Rebalancing an Account to align with the Tactical Asset Allocation or Strategic Asset Allocation model for a Total Return-Focused Strategy, as applicable, due to a change in the value of the Account. • Processing all contributions, including initial and any subsequent cash deposited in the Account, withdrawal requests and Account terminations. • Processing allocations to cash and/or cash alternatives in amounts needed to meet your instructions for annual withdrawal amounts for an Account with an Income-Focused Goal. • Periodically rebalancing the Account as further described below. • Implementing your Reasonable Investment Restrictions, if any, described in the section “Reasonable Investment Restrictions.” • Implementing your tax-selling instructions (if any) where acceptable to MAA, as further described in the section “Tax Matters.” • Implementing tax efficient management overlay services (discussed below in “Optional Account Services for Growth-Focused Goals”), if these services have been selected by you for an eligible Account. Merrill and MAA are authorized and directed by you to sell promptly any investments you contribute that are not eligible or not acceptable for a Program Service or Strategy. MAA actively manages your Account’s investments and may rebalance these investments to the Strategy’s allocations at any time in its sole discretion, including rebalancing to align with the Strategy’s model due to a change in the value of the Account. In light of other considerations in an Account, MAA can effect rebalancing and other transactions even though they may generate tax liabilities, including short-term taxable income. In its discretion, MAA may decide not to process certain rebalancing transactions. Delays in the processing of any rebalancing activities that MAA undertakes can occur from time to time, based on, among other things, market conditions, illiquid securities, as well as the availability of ETFs and mutual funds and other factors. The frequency and parameters MAA uses to rebalance your Account in a selected Strategy may change at any time and may be different from the parameters used in other types of investment strategies or investment advisory programs sponsored by Merrill. MAA arranges for trades to be executed through Merrill or a Merrill Affiliate and may arrange for trades to be executed through a broker or dealer other than Merrill or a Merrill Affiliate (an ”Unaffiliated Trade Counterparty”). In its discretion and subject to legal requirements, MAA may utilize the services of its Affiliates for investment, trading and administrative support. MAA generally takes necessary actions consistent with implementing a Strategy, including for any investments subject to regulatory limitations and restrictions and related internal policies applicable to us and our Affiliates’ overall investment activities described further in the section “Activity by Merrill, Affiliates and Personnel.” Reasonable Investment Restrictions You may request that we impose certain investment restrictions on the management of your Account assets relating to the purchase of specific constituent Funds. For a restriction to be acceptable under the Program, it must first be determined to be “reasonable” by us (a “Reasonable Investment Restriction”). You may request to have different investment restrictions applied to each of your Accounts. If accepted, the Reasonable Investment Restriction that MAA is responsible for managing or implementing in your Account will be included in a periodic Program Report or other communications and on the Program Merrill Guided Investing Brochure | 10 MGI-2A 032125 Website. It will be applied to your Account until; (1) you take action to change, withdraw or waive the restriction; (2) we determine that it is no longer a Reasonable Investment Restriction based on factors we deem relevant in our discretion, including for example, the level of the security holding percentage in the Strategy; or (3) we are no longer able to implement the restriction in our systems due to changes in the security identifier or symbol, corporate action events, or otherwise. Please note that investment restrictions will not apply to securities or other interests in individual companies held in the portfolio of any constituent Fund held in your Account. We reserve the right to modify our practices regarding investment restrictions in our sole discretion at any time without notice. Further, we reserve the right to deem any requested investment restriction to be unreasonable and to not accept the requested investment restriction. If one or more investment restrictions are determined to be unreasonable, the restriction will not be applied and you should consider whether to remain in the Program or consider other more appropriate Strategies in the Program. The termination of an Account from the Program will discontinue the application of the Reasonable Investment Restrictions for that account as a brokerage account or other account no longer enrolled in the Program. If you elect to impose Reasonable Investment Restrictions, you accept any effect that such Reasonable Investment Restrictions may have on the investment performance and diversification of your Account. The performance of an Account with a Reasonable Investment Restriction will differ from, and may be lower than the performance of, an Account without such Restriction. In addition, your decision to impose a Reasonable Investment Restriction that alters the allocation of any Strategy and/or that results in a replacement Fund exposes your Account to additional (and potentially unforeseeable) risks that are inconsistent with the objective of your Strategy. Implementing certain Reasonable Investment Restrictions result in Funds in your Account being sold which could result in taxable events. MAA will determine whether a restriction request is reasonable and how to allocate investments based on an accepted Reasonable Investment Restriction. MAA will allocate the assets that would have been invested in the particular constituent Fund included in the Strategy impacted by the Reasonable Investment Restriction in the following ways: (1) pro-rata across other Strategy investments held in the Account; (2) by using one or more replacement Funds; and/or (3) by remaining uninvested in cash. Available Strategies, Profiles and Prospectus Delivery Merrill determines the manner and extent to which Strategies are made available to clients through the Program, including when a Strategy may change or no longer be offered. Occasionally, we may decide to discontinue offering or to replace certain Strategies. As a general matter, we make these decisions based on a variety of factors, including client needs, available investment styles, platform capacity, client demand and the outcome of due diligence and evaluation reviews including with the assistance of the CIO. Merrill, through the CIO, also selects the constituent Funds in the Strategies and can change constituent Funds without notice to you. See “Item 6 Portfolio Manager Selection and Evaluation.” Where Merrill determines to close a Strategy to new investments and/or additional contributions, Merrill may replace the identified Strategy with another Strategy selected by us, maintain current positions in the identified Strategy and invest any new contributions and sale or redemption proceeds in a replacement Strategy selected by us, and/or maintain in cash any new contributions or sale or redemption proceeds relating to the identified Strategy in cash until a replacement is chosen by us or you direct us to invest in an alternative Strategy. If we determine to replace the identified Strategy, we will endeavor to choose a replacement with an investment objective that is consistent with the identified Strategy. This replacement Strategy may include constituent Funds with higher expenses than you had been paying. If you do not instruct us to the contrary, your continued participation in the Program after receiving notice of such replacement or other action will be considered your consent to the action. If you do not agree with the replacement Strategy, you can terminate the Account from the Program. We generally will provide you with notice of any discontinuation, closing or replacement event respecting a particular Strategy prior to it taking place. We, however, may provide you with notice after we have already taken action. This flexibility to act quickly helps enable us to take action where we believe the replacement and its timing are in clients’ best interest. If your Account is not eligible for the replacement Strategy, we may terminate your Account from the Program. MAA is responsible for implementing our decisions and related actions. We will provide you access through the Program Website to important information about each Strategy through a document known as a “Profile.” The Profile will describe the relevant objectives, styles and risks of the particular Strategy. It will also describe the roles of the CIO and MAA in implementing the Strategy. The Profile includes performance history and data as indicated in the Profile. It will include actual composite performance data developed by MAA in its implementation of the Strategy. Before selecting a recommended Strategy, you should read the detailed description provided in the Profile for the recommended Strategy through the Program Website. If you have any questions, please contact us at 877.444.0916. When a fund that is registered under the Investment Company Act (a “Registered Fund”) is purchased for an Account that has selected the Strategy, in light of the discretionary authority you have granted to us in connection with managing your Account, either of us is authorized to receive the Registered Fund prospectus in lieu of it being automatically delivered to you. If you would like a copy of the Registered Fund prospectus, you may obtain one, free of charge, by contacting us at 877.444.0916 or via the Program Website. Notwithstanding the foregoing, Merrill may continue to send the Registered Fund prospectus to you in its sole discretion. Program Guidelines We have established certain guidelines relating to the management of assets in the Program. The Program guidelines change at our discretion or can be waived under certain circumstances for certain clients. In certain situations, you may be notified if your investment activity or holdings deviate from our Program guidelines, including Target Asset Allocation guidelines, and will be requested to take certain actions to comply with these guidelines. If you decide not to take the requested action, we have the right to terminate your Account from the Program which converts the Account to a brokerage account. The Strategy chosen for your Account and the assets comprising the Strategy in the aggregate are designed to align to the designated Target Asset Allocation and objective for the Account. On the Program Website, you will be able to view the actual asset allocation for your Account (“Actual Asset Allocation”) and compare it to the Target Asset Allocation for your Account. At times, your Account’s Actual Asset Allocation may become misaligned with the Strategy allocation for many reasons, such as market movement, additions and withdrawals of assets from your Account, changes in the Strategy you select or purchases and sales of certain securities in your Account. Merrill Guided Investing Brochure | 11 MGI-2A 032125 On a periodic basis, we will monitor the assets in the Account to the applicable Target Asset Allocation within certain parameters. Because your Account’s Target Asset Allocation is based on your Account risk tolerance, your Account time horizon and, if applicable, a Goal Target and any aligned External Assets, you will have to make a new Strategy selection for your Account if these factors change and the change results in a different recommended Target Asset Allocation. In addition, keep in mind that the time horizon for your Account will change (become smaller) as time passes, and the Target Asset Allocation will change over time (except if your Account already has a recommended Target Asset Allocation of Conservative). If, as a result of the passage of time, your Account’s recommended Target Asset Allocation changes, you will be presented with a new recommended Strategy, if applicable, for selection. With the selection of a new Strategy, certain securities held in your Account will be sold that may result in taxable gains or losses or fees or charges (if applicable) for your Account. If there is a prolonged misalignment, we will ask you to take action in order to remain in the Program, including updating your risk tolerance or time horizon, so that the Account meets the Program guidelines. Our supervision and monitoring do not substitute for your own continued review of your assets and the performance of your investments in your Account. You are responsible for reviewing the Program communications, including performance reports, trade confirmations and account statements that we send to you via the Program Website. If you identify any discrepancies or inaccurate information, you should promptly let us know by contacting us at 877.444.0916. Treatment of Cash Balances in your Account While enrolled in the Program, your Account will have an allocation to cash balances. This allocation results from the CIO’s decision as the investment manager of the Strategy selected for your Account, to keep a cash balance for operational and/or investment purposes as part of the investment strategy. The cash allocation for the Strategy is based on a number of factors, including the nature of the investment strategy being implemented, the types of investments being purchased for the strategy and the circumstances relating to the trading for those securities, market conditions as well as for trade execution facilitation, meeting operational contingencies and having funds available to pay the monthly fee charged for Program Services without generating trade activity in the Account. In certain circumstances, including periods of volatile or uncertain market conditions, any cash allocation may comprise all or a substantial portion of your Account assets based on, for example, concerns about the market or a decision to pursue a defensive investment strategy. Your Account’s uninvested cash balance is automatically swept with your consent to a cash sweep option for your Account under the terms of your underlying brokerage account agreement (the “Cash Sweep Program”). The available automatic cash sweep options under the Cash Sweep Program vary based on the Merrill account type and other criteria. Not all Merrill account types have the same cash sweep option. The only automatic cash sweep options currently available for Merrill account types eligible for enrollment in the Program are the Merrill Lynch Direct Deposit Program (the “MLDD Program”) and, for retirement accounts, the Retirement Asset Savings Program (“RASP”). The MLDD Program and RASP provide for an automatic sweep of cash balances to bank deposits with BANA and other banks affiliated with us (“Bank Affiliates”). Please refer to your account agreement and related disclosures for additional information regarding the automatic sweep options for your type of account. The Sweep Program Guide for Merrill Clients, which can be found on mymerrill.com, provides an overview of the automatic cash sweep options and how they work and a chart of automatic cash sweep options by Merrill account type. The current rates and yields for the cash sweep options are available at mymerrill.com and from us. Your cash balance, like other investments, is subject to the Program Fee. As described earlier in this Brochure, any cash balances held as part of your Account assets can be invested as directed by the CIO in cash alternatives, including money market mutual funds, available through the Program. We discuss the treatment of cash balances and other considerations relating to cash in various parts of this Brochure, including: (1) Item 4 at the sections “Brokerage, Banking-Related and Custodial Arrangements and Services-Cash Sweep Program and other Banking-Related Services,” “The Program Fee and other Charges-Determination of how the Program Fee is Charged,” and “Funding and Operation of Accounts-Cash Balances” and (2) Item 9 at the sections “Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and the Cash Sweep Program.” Brokerage, Banking-Related and Custodial Arrangements and Services You are required to maintain a securities (brokerage) account with MLPF&S through Merrill Edge Self-Directed Investing. The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance for your Account and access to Strategies and ongoing monitoring. The Program Fee you pay covers these Program Services and your payment for the trade execution, clearance and settlement services provided by Merrill and MAA. It also covers custody of assets. Note that certain fees unrelated to investment activity, like fees for banking-related or cash transfer activities, wire transfer fees, foreign currency wire and conversion fees, account service fees, transaction fees and certain transactional costs, are not covered by the Program Fee, including those described in “Item 4 The Program Fee and Other Charges.” In addition, your brokerage account agreement and documents will provide you with information about certain brokerage services and related transaction and account fees for your Merrill account. Brokerage Trading Services Generally. In effecting transactions for your assets in the Program, we or our Affiliates will be acting exclusively as a broker- dealer and can arrange for trades to be executed through Merrill or a Merrill Affiliate or through an Unaffiliated Trade Counterparty. If we or one of our Affiliates effect the transaction through an Unaffiliated Trade Counterparty, we will take into account various factors, such as the nature and quantity of the securities involved, the markets involved, the reputation and perceived soundness of the firm, the firm’s clearance and settlement capabilities and other factors relevant to the selection of a broker-dealer for the execution of client securities transactions. Trades will be handled by MLPF&S consistent with best execution and other regulatory obligations. Even in meeting these obligations, it is possible that you may be able to obtain better prices for transactions if such trades were executed with other broker-dealers or third parties, including having smaller spreads (the difference between the bid and the offer price) or at more favorable net prices. We seek to effect transactions correctly, promptly and in the best interests of clients. In the event an error occurs in our handling of client transactions, we seek to identify and correct it as promptly as possible without disadvantaging you. Depending on the circumstances, corrective actions may include canceling a trade, adjusting an allocation, and/or reimbursing you. In general, in instances where we are responsible for effecting the transaction, we may Merrill Guided Investing Brochure | 12 MGI-2A 032125 reimburse you for any losses directly resulting from trade errors, credit to you any profits directly resulting from such trade errors that are corrected after the settlement of the transaction or retain for ourselves any profits directly resulting from such trade errors that are corrected prior to the settlement of the transaction. We may, but are not required to, aggregate orders for the sale or purchase of securities for your Account with orders for the same securities for our other clients, proprietary accounts or the accounts of our employees and/or Affiliates, without your prior authorization. In such cases, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro rata shares of any fees. MAA’s ability to implement the recommendations of the CIO as to a particular Strategy may be affected by the liquidity of the security, market volatility, and any price limits that may be imposed by Merrill. This may in turn have a negative impact on the performance of a Strategy. In your Agreement, you appoint us to act as your agent and attorney-in-fact with such discretionary power and authority to buy, sell or otherwise effect transactions in constituent Funds as part of the Strategy, and any other securities or other property in your name for your Account. You also authorize and direct us to cause all transactions to be effected through MLPF&S or its Affiliates acting as agent or, as permitted by law, as principal. Principal transactions are only effected in accordance with Program guidelines and applicable regulations. You, and not we, will bear the cost of any fees that are not covered by the Program Fee and that are payable to Unaffiliated Trade Counterparties (including on fixed income or over-the-counter transactions in which Merrill and its Affiliates act as agent). Rules for Cash Accounts and Margin Transactions. As a broker-dealer, Merrill is responsible for compliance with federal margin rules. Accounts in the Program are set up only as cash Accounts. This account notation means that margin is not permitted and purchases of securities must be fully paid for on the date of the trade. With a cash Account, if securities are sold before the payment for their purchase has settled, an event known as a “free- riding violation” has occurred. Free-riding is prohibited under margin rules and our Program guidelines. Having a “free-riding” violation may result in your Account being restricted for 90 days or “frozen.” The imposition of such a freeze could have a negative effect on your Account and performance. The risk of engaging in an inadvertent “free riding” violation and therefore freezing of your Account is enhanced: (1) when you change Strategies and reconstitute your investments or (2) when you withdraw cash from your Account when there is a pending order to purchase a security. Certain of your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through certain Affiliated loan programs (i.e., the Loan Management Account® and Mortgage 100®/ Parent Power® mortgage programs) or through unaffiliated loan programs (together, the “Lending Programs”). The costs, risks and other features and conditions of a loan under the Affiliated Lending Programs are more fully described in the separate lending documentation you receive in connection with any such loan and are not described in this Brochure. There are risks, costs, and conflicts of interests associated with Lending Programs. The costs, including interest, associated with a loan through any Affiliated Lending Program are not included in the Program Fee and will result in additional compensation to us, our Affiliates, and our financial advisors. The interest charges on any loan combined with the fees charged for Program Services may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. See the sections ”Item 6 Investment Strategies and Risk of Loss-Securities-based Lending with your Account” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Participation in Affiliate Lending Programs and Margin.” Cash Sweep Program and Other Banking-Related Services. As provided in the brokerage account agreement and documents you executed to open your account, unless you elected the “No Sweep” option, you have consented to having your Account’s uninvested cash being treated as a cash balance and being automatically swept to the cash sweep option for your Account under the Cash Sweep Program. For Strategies, unless the cash allocation is invested in a constituent Fund as directed by the CIO, the cash allocation will be treated as a cash balance in the Account subject to the automatic sweep functionality. Under the MLDD Program and RASP, an Account’s cash balance is swept to accounts held at our Bank Affiliates. Under each of these programs, Merrill as your agent establishes the bank deposit accounts on your behalf at the Bank Affiliate as provided for in your underlying brokerage account agreements. Bank deposits in the MLDD Program and RASP are insured by the Federal Deposit Insurance Corporation (“FDIC”). Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Certain conditions must be satisfied for deposit insurance coverage to apply when bank deposits are opened on your behalf in the name of Merrill as your agent. Merrill has in place business requirements and practices that are reasonably designed to satisfy those conditions, which include, but are not limited to, proper account titling and recordkeeping. The sweep deposit accounts at the Bank Affiliates are protected by FDIC insurance, up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership category, per bank. FDIC insurance covers both principal and credited interest, up to applicable limits. Any deposits maintained with a Bank Affiliate in the same account ownership category, whether directly, through other Merrill accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If your total cash balances in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of bank product (i.e., a certificate of deposit) of a Bank Affiliate in the MLDD Program or RASP exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Neither Merrill nor the Bank Affiliates manage or monitor the deposits swept under the MLDD Program and RASP for FDIC insurance limit purposes. Deposits are not aggregated or limited under the MLDD Program and RASP based on the FDIC limits for the same depositor in the same bank across Merrill accounts. Merrill does not undertake through the Program or the Agreement or the underlying brokerage agreement to provide you notice that cash balances in your Account or Accounts or in any of your brokerage accounts exceeds the FDIC coverage limit for any of our Bank Affiliates. Monitoring FDIC insurance coverage limits is expressly not a Program Service. You are responsible for monitoring the total amount of deposits held at the Bank Affiliates in order to determine the extent of FDIC insurance. The agreements and disclosures that you received in connection with establishing your underlying Merrill brokerage account and the Sweep Program Guide for Merrill Clients include additional information about FDIC insurance. A paper copy can be obtained from us. For additional information on FDIC insurance, visit fdic.gov. Cash balances swept under the Cash Sweep Program to a bank deposit account of our Bank Affiliates will bear a rate of interest that has been established for, and in light of the features of, the MLDD Program and RASP. The rate of interest for such deposit accounts will be periodically set and reset by the Bank Affiliates in their discretion. The rate is variable and may change at any time after the account is opened without notice or limit. Under the MLDD Program and RASP, interest rates are tiered based upon a client’s relationship with Merrill. Accounts with the MLDD Program and RASP as their Cash Sweep Merrill Guided Investing Brochure | 13 MGI-2A 032125 Program that are enrolled in the Program and in specified Merrill investment advisory programs receive the highest tier rate available under the Cash Sweep Program. A brokerage account with cash swept into MLDD Program or RASP that enrolls in the Program will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. Please note that the interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. Certain account types have the option to select the “No Sweep” option under their underlying brokerage agreement which results in cash being held in the account as a cash balance and not ‘swept’ to any available sweep option under the Cash Sweep Program. The cash balance will not earn interest or dividends. The cash held in the Account will be covered by the Securities Investor Protection Corporation (“SIPC”) up to $500,000 per client, inclusive of $250,000 for cash. As a registered broker-dealer, Merrill benefits from the possession or use of cash balances, also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. The CIO determines whether to hold a cash balance and/or invest in a money market fund or other cash alternatives available for your Account through the Program. If no action is taken by the CIO to select a cash alternative, cash balances will automatically be swept under the Cash Sweep Program. There are conflicts of interest associated with the Cash Sweep Program which are discussed in “Item 9 Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Custodial Arrangements and Services. MLPF&S will act as the custodian for the assets held in the Program. Your assets will be maintained in an account established at MLPF&S through the applicable securities (brokerage) account you have opened. Any assets held in the Program in Retirement Accounts must be and remain free from any lien, charge or other encumbrance. Any assets held in the Program in Accounts other than Retirement Accounts must be and remain free from any lien, charge or other encumbrance (other than a lien, charge or other encumbrance in favor of us or our Affiliates), unless we agree otherwise. You must notify us in writing prior to effecting loans secured by securities in the Program (including loans by our Affiliates) (commonly referred to as “collateralizing”). No specific securities in your Account should be held as collateral to secure any loan you may have. We will not provide advice on or oversee any of your collateral arrangements. Unless we otherwise agree, the terms of the Agreement will prevail in the event of any conflict between the terms of the Agreement and your collateral arrangements. You must also disclose to any lender the terms of the Agreement. There are adverse effects of collateralizing Accounts, including, but not limited to, the fact that the lending institution may require additional collateral or liquidation of securities to meet a call, as well as the related tax consequences. You must promptly notify us of any default or similar event under your collateral arrangements as defined in the respective collateral arrangements. From time to time, Merrill (doing business as Merrill Edge) may offer to clients or potential clients certain promotions or rewards in connection with opening, maintaining or adding assets to a Merrill securities account. Such promotions or rewards may include, by way of example, the payment of a cash reward. The promotions may require a client to request to receive or participate in the promotion or reward, and/or require a client to meet various eligibility criteria. While these promotions or rewards may extend to a client’s Merrill securities account that holds assets in the Program, participation in the Program is not a condition for these promotions or rewards. Account Features Proxy Voting. You have the right to vote proxies for securities held in your Account and you will retain proxy voting authority for your Account. You cannot delegate to us and we do not accept or assume any proxy voting authority for securities held in your Account. We will promptly send you proxy ballots and related shareholder communications that we receive, as well as any other information intended for distribution to you. You are responsible for taking any actions. If MLPF&S, as custodian of your Account, does not receive voting instructions from you, it will comply with the rules of the SEC and applicable self-regulatory organizations relating to such matters, as required by law. As a broker dealer, MLPF&S uses a third-party service provider for certain proxy- related functions, including processing and forwarding proxy and other issuer related materials, and receives amounts collected by the vendor for the costs of these services as permitted by applicable securities regulations. Trade Confirmation Statements. You will receive trade-by-trade confirmation statements electronically for transactions in your Account. Electronic Delivery Service. By enrolling in the Program and signing the Agreement and consenting to electronic delivery, you have agreed to electronic delivery of Program materials, including this Brochure and the Agreement and any changes, supplements or amendments to these materials as well as other Program notices and materials. We will not send you paper versions of documents as part of the Program unless required by applicable law or in our sole discretion. Please see the information in “Item 4 Electronic Accessibility Requirement.” Certain of our materials, including this Brochure, are compatible with various types of assistive devices, such as screen readers. Other Program materials have varying degrees of compatibility with different assistive devices. If you experience difficulty in accessing a Program document with an assistive device, please contact us at 877.444.0916 and request that the document be made accessible. Optional Account Services for Growth-Focused Goals We offer you the ability to elect certain Services for an Account. Neither Merrill, nor our Affiliates, employees, or agents will be liable for any loss or expense that may result from your use of any of these optional Services except as otherwise provided in the Agreement. There may be current tax consequences with any transaction occurring under these optional Services. We do not provide tax, accounting or legal advice and you should review any planned financial transactions or arrangements with your professional tax or legal advisors for these matters. MAA Tax Efficient Management Overlay Services. Through the Program Website, you can elect tax efficient management overlay services from MAA (the “TEM Overlay Services”) for a taxable Account with a Growth-Focused Goal enrolled in the Program. TEM Overlay Services will only apply to eligible securities within the Account for which it was selected and therefore may not apply to all securities in the Account. The TEM Overlay Services are not available to you for an Account with an Income-Focused Goal or for a Retirement Account. Merrill Guided Investing Brochure | 14 MGI-2A 032125 TEM Overlay Services seek to help manage your electing Account’s investment and trading activity in a Total Return Strategy in a more tax-efficient manner as considered under U.S. tax rules and regulations. Through rules-based rebalancing, portfolio management and loss harvesting approaches, the TEM Overlay Services generally try to increase post-tax value for the electing Account by seeking to: • opportunistically sell securities that have a loss and invest proceeds in the underlying Total Return Strategy-aligned replacement securities for at least 30 days. • engage in tax lot management by prioritizing sales of securities that result in the lowest tax cost, as circumstances warrant. • defer short-term gains by restricting sales of short-term tax lots if the tax lot holding period will go long-term within 31 days or less. • engage in tax efficient management by realigning the Account’s portfolio to the underlying Total Return Strategy weights and giving a sell preference to depreciated securities. • overweight gains and underweight losses by not selling appreciated securities and selling depreciated securities relative to the underlying Total Return Strategy, as circumstances warrant. • avoid wash sales. The available TEM Overlay Services are tax efficient rebalancing and, depending upon your Account’s underlying Total Return Strategy, either dynamic tax loss harvesting or quarterly loss harvesting. Your Account’s Total Return Strategy determines the eligible TEM Overlay Services for the Account that will be presented to you through the Program Website as part of considering the TEM Overlay Services. These TEM Overlay Services are described in greater detail in the respective term sheets and other materials available through the Program Website. Through the Program Website, you can elect the TEM Overlay Services for the eligible Account and authorize MAA to effect the TEM Overlay Services and the related securities transactions on an ongoing basis without making any additional contact with you. This authority will continue in effect until you change or cancel the TEM Overlay Services for the associated Account (which you may do at any time) or terminate the associated Account from the Program. As part of this election through the Program Website, you also acknowledge the risks and limitations associated with the TEM Overlay Services, which are summarized on the Program Website and described in other disclosures provided to you in connection with the TEM Overlay Services election, as well as in this Brochure in the sections “Item 4—Tax Matters” and “Item 6—Particular Risks Regarding the TEM Overlay Services.” The TEM Overlay Services will only take into consideration the trading activity that occurs in that electing Account. If there are any Reasonable Investment Restrictions in place for the electing Account, MAA will seek to take those investment restrictions into consideration when applying the TEM Overlay Services and identifying appropriate replacement securities (if any). MAA may make available additional TEM Overlay Services from time to time. There is no separate or additional fee that is charged by Merrill or MAA for providing the TEM Overlay Services to an eligible Account. MAA reserves the right to charge a fee for TEM Overlay Services upon prior written notice. Automatic Withdrawal Service for Growth-Focused Goals. Through the Program Website, you may enroll at no additional cost in the Automatic Withdrawal Service available from Merrill as custodian of your Account. Through this service, you request scheduled withdrawals from your Account to an eligible account designated by you. By doing so, you authorize and instruct us to effect the chosen scheduled withdrawals and any related securities transactions for the withdrawals on an ongoing basis without making any additional contact with you. Your instructions will continue in effect until you change or cancel your instructions, your instructions expire by their stated terms, your Account is approaching and/or reaches the required minimum or your Account is terminated. Information relating to your schedule of automatic withdrawals will be displayed on the Program Website. You can change or cancel your scheduled instructions at any time. You should carefully review and understand the terms of Automatic Withdrawal Service on the Program Website and how the service affects your Account before enrolling. We may terminate the offering of this service at any time upon prior notice to you. We will attempt to process all withdrawal requests in a prompt manner. If your withdrawal request requires the liquidation of any securities, it may take up to 10 business days to process. Frequent withdrawals may affect the performance, asset allocation and achievement of your investment goal for your Account. Except as otherwise provided in the Agreement, none of Merrill, MAA, their Affiliates, employees, or agents will be liable for any loss or expense that may result from your use of any of this service. There may be current tax consequences with any transaction occurring under this service. Having an account (including your Account) with the Automatic Withdrawal Service may affect your Account that elects the TEM Overlay Services. We do not provide tax, accounting or legal advice and you should review any planned financial transactions or arrangements with your professional tax or legal advisors for these matters. See “Item 4 Tax Matters.” The Program Fee and Other Charges The Program Fee Rate. You agree to pay to us an annual asset-based fee (the “Program Fee”) at the rate of 0.45% (the “Program Fee Rate”) based on the asset value of the Account for the Services provided in the Program under the Agreement. The Program Fee Rate is nonnegotiable and payable monthly in advance. The Program Fee is subject to change from time to time, upon notice to you. Your continued use of our Services will constitute your agreement to any such change. Upon your request, and at no charge, you may contact us by telephone at 877.444.0916 to request information regarding your Program Fee and its calculation. The Program Fee does not include all of the charges that may apply to your Account. Please see the section “Fees and Expenses Not Covered by the Program Fee” for a list of other fees and expenses that you may be charged and that are not included in the Program Fee. You may be eligible for benefits such as Program Fee discounts, rebates or credits under certain promotional programs (“Bank programs”) that BANA offers from time to time for its banking product clients who also use the products or services of its Affiliates, including Merrill. In general, you must be a banking client of BANA, elect to participate in these Bank programs, and meet certain eligibility criteria of the Bank programs in order to receive the benefits available to clients of Merrill under these Bank programs. For additional information on these Bank programs, please contact us at 877.444.0916 or visit the Program Website. The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance under the terms of the Program. The Program Fee you pay covers the Program’s Services, including investment advice and guidance under the Program, as well as brokerage and custodial services relating to your Account. Certain services that are normally available in certain types of brokerage accounts will not be available to your Account enrolled in Merrill Guided Investing Brochure | 15 MGI-2A 032125 the Program, including margin lending, check writing, Visa cards and client order entry. The full amount of the Program Fee payable under the Agreement will be charged in accordance with the terms of this Agreement, regardless of the amount of transactions effected in your Account. We offer similar programs and/or investment strategies in different sales channels and at different fee levels. The Program Fee may be higher or lower than the fees for another investment advisory program and/or the cost of similar services offered through other financial firms. See “Ability to Obtain Certain Services Separately and for Different Fees” in this Item 4. Calculation and Payment of the Program Fee. The Program Fee is payable monthly in advance and generally will be calculated based on the value of the assets in your Account as of the last business day of the prior month. In certain instances and in our sole discretion, we can fully or partially waive or reduce your Account’s Program Fee for a particular month or as part of promotional activities. From time to time, Merrill may offer to clients or potential clients certain promotions in connection with newly enrolling an account in the Program. Such promotions can include, by way of example, the waiver of the Program fee for a time period. The promotions could require a client to request to receive or participate in the promotion, and/or require a client to meet eligibility criteria. For additional information on any current promotions relating to a Program Fee waiver, please contact us at 877.444.0916 or visit the Program Website. When you enroll a new Account in the Program, an initial Program Fee will be assessed during the week following the date on which you have contributed the required minimum level of assets to the Account for the Strategy you select. The initial Program Fee will be calculated and paid to Merrill based on: (1) the market value of the assets in your Account as of the earlier to occur of the last business day of the week or the last business day of the month following required funding; and one-twelfth of the annual Program Fee Rate applicable to such market value and prorated based on the number of days remaining in the month from the date of required funding. After the initial Program Fee, the monthly Program Fee is typically charged to your Account during the first week of the current calendar month. The Program Fee will be calculated and paid to Merrill based on: (1) the value of the assets in your Account as of the last business day of the previous calendar month; and (2) one-twelfth of the annual Program Fee Rate applicable to such value. If you or we terminate your Account, we will refund to you a pro rata portion of the Program Fee based on the number of calendar days remaining in the month. The refund, if any, will be applied to your Account typically during the week following Account termination. See “Item 4 Funding and Operation of Accounts-Termination of Enrollment in the Program” for further information. Deduction of the Program Fee from Your Account. You have agreed in the Agreement as follows: • Unless otherwise agreed to between you and Merrill in writing, the Program Fee and any other fees payable under the Agreement will be deducted directly from your Account. • Merrill is authorized to deduct the Program Fee (and any other fees payable) from the assets held in your Account, to the extent permitted by law, if full payment of such Fees has not been timely received or, if earlier, at the time the Account is terminated. • The Program Fee and any other fees for your Account will be payable, unless otherwise indicated, first from the withdrawal by Merrill of your balances in the bank deposit account, as you authorize in the Agreement or other document, and second from free credit or cash balances, if any, in your Account. • You will make timely payment of all amounts due to Merrill under the Agreement, and any unpaid Program Fees may result in the termination of your Account. • Unless this is a Retirement Account, all assets in your Account or otherwise held by Merrill or its Affiliates for you will be subject to a lien for the discharge of your obligation to make timely payment to Merrill of the Program Fee to the extent permitted by law (and any other fees payable under the Agreement), and Merrill may sell assets in your Account to satisfy this lien. • You can instruct us to deduct the Program Fee from an alternate account. If you wish to instruct us to collect the Program Fee from an alternate account, please download the form and instructions for selecting an alternate account at: merrilledge.com/AltDebitForm. If free credit or cash balances within the alternate account you have designated for your Program Fee to be deducted from are not available, the Program Fee will be deducted from your Account. Determination of how the Program Fee is Charged. Except as noted, you will be charged the Program Fee on all assets in your Account, including cash and cash alternatives. Generally, all Account values used to determine the Program Fee are based on the value of the assets in your Account, as determined by Merrill. In calculating such Account values, we will use a variety of pricing sources, including our Affiliates. The Program Fee will be applied to any cash and any cash alternatives held within your Account, including any cash and any cash alternatives held as part of the Income-Focused Strategies. This includes (1) money market funds and other cash alternatives held as part of the Strategy; (2) cash that is treated as a cash balance which is automatically swept into a cash sweep option applicable to your Account in accordance with the Cash Sweep Program; and (3) cash in your Account due to your having chosen the “No Sweep” option as provided for in the Merrill brokerage account agreement. The Program Fee is in addition to other compensation that we and our Affiliates earn on cash and cash alternatives held in your Account, including a cash allocation for an Account with an Income-Focused Goal. Depending on interest rates and other market factors, the yield that you earn on cash balances and cash alternatives has been, and can be in the future, lower than the Program Fee that you may pay on assets held in your Account. As a result, depending on the interest rate environment, you may experience a negative overall investment return with respect to cash and cash alternatives and, in some situations, the effective return on cash held in a bank deposit account can be negative. For more information about the Cash Sweep Program, including compensation and benefits we and our Affiliates receive, see “Item 4 Funding and Operation of Accounts-Cash Balances” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Fees and Expenses Not Covered by the Program Fee. The Program Fee does not cover: • Dealer spread charges, mark-ups or mark-downs charged by executing broker-dealers or other over-the-counter transactions in which Merrill or its Affiliate acts as agent or dealer spreads, markup or mark-down charges, underwriting discounts, selling concessions or other transaction charges with respect to any principal transaction effected by MLPF&S or our Affiliate. Merrill Guided Investing Brochure | 16 MGI-2A 032125 • Transfer taxes. • Exchange fees, alternative trading system fees, required SEC fees or similar fees charged by third parties, including issuers. • Electronic fund, wire and other Account transfer fees, including certain fees and charges relating to transfer and termination fees, banking-related services, such as banking, check writing services and money transfers, wire transfers including foreign currency wire transfers either in or out of your Account and foreign exchange conversion fees and costs (including any fees or markups or mark-downs in connection with foreign currency exchange or conversions) and certain corporate action fees. • Fees, expenses and charges charged by Funds or by the managers or sponsors of Funds, including internal fees, expenses and charges of the constituent Funds used in the Strategies. • Any other charges imposed by law or otherwise agreed to with regard to the Account (including those charges payable to Merrill and/or third parties as described in the Brochure). The Strategies available in the Program utilize ETFs and mutual funds, each of which has internal fees and expenses that are specified in the individual Fund prospectus or offering materials. For investments in constituent Funds that are part of the Strategy, you will bear your proportionate share of such constituent Funds’ fees and expenses including, but not limited to, management fees and performance-based compensation paid to such Funds’ investment managers or their Affiliates, fees payable to the constituent Funds’ professional and other service providers, transaction costs and other operating costs. All of these fees and costs may be material, and some may be paid to Merrill and its Affiliates as compensation for services rendered. Any contingent deferred sales charge, redemption or other fees imposed by a Fund manager as a result of your redeeming a mutual fund to invest in a Strategy will be separate from, and, in addition to, the Program Fee. The Program Fee does not cover or offset any of the fees and expenses that any constituent Fund may incur for transactions occurring within the constituent Fund itself, including commissions and other transaction-related charges incurred by the constituent Fund, even if we effect these transactions for the constituent Fund or provide services to the Fund. The Program Fee does not include certain fees and charges relating to transfers and terminations, certain corporate actions and banking-related and cash transfer services, including banking, check-writing services and money transfers, wire transfers, foreign currency wire transfers and conversions. Certain of these fees and charges are detailed in the Merrill Edge Self-Directed Commission Schedule and Miscellaneous Fees, available at merrilledge.com/pricing. Please see the brokerage account agreement and account enrollment documents relating to brokerage services and related transactions and account fees for your Merrill account. If you have any questions about any charges or fees applicable to your Account, please contact us at 877.444.0916. When your Account invests in Funds, you generally will purchase shares that have no front-end sales load or contingent deferred sales charge, or for which such loads or charges are waived. However, as a Fund investor, you will bear your proportionate share of such Fund’s fees and expenses including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. Any Fund redemption or other fees imposed by a Fund manager as a result of you redeeming the Fund to invest in a particular Program Strategy will be separate from the Program Fee. The Program Fee does not cover or offset any of the fees and expenses that any Fund may incur for transactions occurring within the Fund itself, including commissions and other transaction- related charges incurred by the Fund, even if we effect these transactions for the Fund. Except as otherwise provided for Retirement Accounts, the Program Fee will not be reduced even if MLPF&S or its Affiliate effects transactions for the Funds or otherwise provides services to the Funds for compensation. Ability to Obtain Certain Services Separately and for Different Fees You may be able to obtain some of the same or similar Program Services or types of investments through a brokerage account or other investment advisory programs and services offered by Merrill. Many of the tools and analytics that are used to support services provided through the Program are also available through Merrill without enrolling in the Program and paying the Program Fee. You should consider the brokerage and investment advisory services we make available to determine which may be most appropriate for you. You may also be able to obtain the same or similar Services, investment solutions, or types of investments through other programs or services (in either other investment advisory programs or in brokerage) offered by Merrill. These may be available at a lower or higher fee than the fees charged for the Program. You may also be able to obtain some or all of these types of services from other firms, and if they are available, the fees associated with them may be lower or higher than the fees we charge. More broadly, when you compare the services, investment solutions, account types and programs and their relative costs, you should consider various factors, including the following: • Your preference for an investment advisory or brokerage relationship. • Your preference for a discretionary or a nondiscretionary relationship. • Your preference for a fee-based or commission-based relationship. • Your preference for an online-only relationship compared to having access to a financial advisor. • The types of investment vehicles and solutions that are available in each Merrill program or service. • Whether a particular investment solution offered in one service is available through another Merrill program or service at a lower or higher cost. • How much trading activity you expect to take place in your account. • How much of your assets you expect to be allocated to cash. • The frequency and type of client profiling reports, performance reporting and account reviews that are available. We offer other investment advisory programs, including Merrill Guided Investing with Advisor (“MGI with Advisor”), the Merrill Edge Advisory Account program (“MEAA”), which is similar to the MGI with Advisor program, and the Merrill Lynch Investment Advisory Program (“IAP”). These investment advisory programs have different service models and set of investment offerings than the Program. In the case of IAP, from a service model perspective, you have direct access to and advice and guidance from your dedicated financial advisor, whom you have personally selected and chosen to work with to discuss the particular investment strategy and available alternatives. Through IAP, you have access to a much larger set of managed investment strategies and the ability to access investment approaches and investment products and solutions that are unavailable in the Program, MGI with Advisor or in MEAA. The Merrill Guided Investing Brochure | 17 MGI-2A 032125 Program only offers access to a limited list of Strategies constructed by the CIO and not the fuller complement of Strategies available in IAP. Depending on the IAP fee agreed to with a Merrill financial advisor chosen by you, the Strategies, as well as other managed strategies that are similar to those available in the Program, could be available at a higher or lower cost than is charged in this Program. With MGI with Advisor and MEAA, you may access certain of the Strategies available in the Program for a fee that is greater than the Program Fee and you have access to a Merrill financial advisor for advice and guidance as to those investment solutions through a call center or at select bank branches. MGI with Advisor and MEAA only offer certain strategies and not the fuller complement of strategies available in IAP. We have provided you with materials that help to explain the various platforms and programs we offer, including our Form CRS and “Summary of Programs and Services” available at merrilledge.com/relationships. These documents are available on the Program Website. Funding and Operation of Accounts Establishing an Account. By signing the Agreement, you can open an Account and enroll in the Program electronically. You may need to sign a separate agreement if you want to open an account, including in any other account ownership capacity, such as a trustee of a trust, as a custodian of an account for a minor or as a joint account owner. The effective date of the Agreement for your Account will be the date of its acceptance by us and will be indicated in the Program Report for the Account. The Agreement will not apply to any accounts not reflected in the Program Report. As discussed above, you must provide us with a valid email address to enroll in the Program. Our advisory relationship begins upon the effective date of the Agreement with you. Any preliminary discussions or recommendations provided to you before we accept the Agreement do not constitute investment advice under the Advisers Act and should not be relied on as fiduciary investment advice. A Client request to enroll in the Program or to initiate a Strategy change is not considered a market order due to the requirements for enrollment including funding as well as the administrative processing time needed to implement enrollment instructions. We will initiate Program Services for new Accounts after your execution of any required Account documentation, approvals and funding of the Account and expect such enrollment to occur promptly. The investment of assets of an Account will only occur when all operational requirements have been met. Account acceptance may be delayed or rejected if the account is underfunded or funded with ineligible assets. Funding Your Account. You may fund your Account by depositing cash and/or securities acceptable to us. Contributions of cash and securities to your Account may be made at any time. There may be a delay between the date that cash and securities are contributed to an Account and the date that MAA invests such cash (or liquidates contributed securities if applicable). Except as otherwise provided in the Agreement, we will not be liable for any lost opportunity profits that may result from a delay in investing or liquidating any contributed securities in order to invest the proceeds into a Strategy. We may determine in our sole discretion that certain assets, including securities or pending orders relating to securities, are ineligible for the Program or otherwise unacceptable. If we determine in our sole discretion that any contributed investments are ineligible or are unacceptable by your execution of the Agreement, you are authorizing us to sell those investments promptly and to charge a commission for the sale of these assets. We also may request that you take action to transfer the ineligible assets out of an Account. Failure to comply with the request to transfer such assets out of an Account enrolled in the Program may result in that Account’s termination from the Program. We will as a general matter sell any assets you have in your Account in order to invest in accordance with the particular Strategy that you select for your Account. If we determine not to sell the particular asset, are unable to sell the asset or if you specifically direct us in writing to not liquidate the asset (before it has been liquidated), we have the right to transfer the asset to a securities brokerage account. You are responsible for all tax liabilities arising from the sale of these securities. If we are unable to liquidate investments transferred for the purpose of funding your Account, we will not be able to enroll your Account in the Program and if your Account is already enrolled in the Program, your enrollment may be terminated. In such cases, we will notify you of your options which may include transferring securities to a new or existing securities (brokerage) account (not part of this Program) or sending the securities back to the originating firm or account. Special Note about Funding your Account with Mutual Fund Shares. Before contributing mutual fund shares to the Program, you should consider the fact that you may have paid a front-end sales charge and may be obligated to pay a contingent deferred sales charge or redemption fee. if the mutual fund shares are redeemed by us in order to invest in the Strategy you have selected. These fees, where applicable, will remain your responsibility and will be in addition to the Program Fee. Each mutual fund has its own system of share classes for certain types of clients and accounts. The Program eligible mutual fund share classes vary depending on the mutual fund, its roster of share classes and our agreements with them. In general, the share classes that are eligible for the Program do not have any sales loads or annual asset-based fees. Annual asset-based fees include service fees or Rule 12b-1 fees charged by mutual funds. There are some mutual funds available in the Program that have such annual asset-based fees due to share class availability. If you contribute or hold mutual fund shares that we deem to be ineligible for the Program, we will either sell them and purchase the share class eligible for the Program if consistent with the Strategy model or we will exchange them, under the authority provided to us under the Agreement, mutual fund prospectus rules and our own policies, into the Program-eligible share class as promptly as practicable if consistent with the Strategy model. We may also require you to remove them from the Account. We may not elect to exchange particular share classes of a mutual fund if, for example, there is no equivalent class eligible for the Program or if other circumstances exist. By contributing mutual fund shares to your Account in the Program, you could be subject to higher expenses overall once the shares are exchanged into a class we deem to be eligible or if you held them in your brokerage account. Prior to contributing any mutual fund shares to your Account, you should consider the impact of the sale or exchange of these shares. In addition, from time to time, a constituent Fund may authorize us to make available to clients participating in the Program a class of shares with a lower fee structure that we believe is more beneficial to you than the class of shares previously made available in the Program. Where such exchange is available, under the authority provided to us in the Agreement, we will effectuate an exchange to the other class of shares of the same mutual fund with the lower fee structure as promptly as practicable upon becoming aware of such availability. Merrill Guided Investing Brochure | 18 MGI-2A 032125 Withdrawal Requests. For withdrawal requests, the liquidation of certain securities will typically be required. Withdrawal requests will be implemented as promptly as practicable, although implementation of the withdrawal may be delayed in certain instances, such as during periods of extreme market volatility. The following will apply to our handling of a withdrawal request: • You can make a request to withdraw your assets via the Program Website or by calling us at 877.444.0916. If you have questions or would like information relating to a withdrawal request, you can also call us at this number. • We require at least five business days’ prior notice to withdraw assets from your Account. For certain Strategies and/or securities and in certain situations, it may take longer than five (5) business days before you can access your requested funds. MAA’s ability to liquidate may be impacted by market conditions and events or pending rebalancing actions being taken for the Account. • Withdrawal requests will be handled as promptly as practicable given other activities that may be occurring at the same time in an Account, like changes to a Strategy, any rebalancing transactions in process and other activity affecting the Account. • Funds must be withdrawn from the Account by you as soon as practicable after settlement date and if the requested funds are not withdrawn from the Account within fifteen calendar days after the settlement date, the funds may be subject to reinvestment into the relevant Strategy without notifying you. • We reserve the right to liquidate, redeem or exchange Funds and other securities that are transferred from an Account to a brokerage account. • We reserve the right to terminate any Account that falls below (1) for the Total Return-Focused Strategies, the required minimum asset size of $1,000 and (2) for the Income-Focused Strategies, the required minimum asset levels as we determine from time to time; or, in either case, as otherwise reflected in the applicable Profile for the Strategy. • We will charge the Program Fee on the value of your Account investments until the proceeds from any sale or redemption of such securities is settled and the proceeds moved out of the Account. • Taxable gains and losses may be realized as a result of your withdrawal instructions. Required Withdrawals for Income-Focused Goals. Recurring withdrawals for your Income-Focused Goals have special processing guidelines. Each year the total amount needed to meet the annual withdrawal amount will be allocated to cash and/or cash alternatives (the “Cash Withdrawal Allocation”) in the Account until the scheduled withdrawal date(s). The scheduled recurring withdrawal amount for the initial year will be calculated (if applicable) and processed to an Account’s Cash Withdrawal Allocation once instructions are provided to us during or shortly following the enrollment of your Account in the Program. The scheduled recurring withdrawal amount for each subsequent calendar year will be calculated (if applicable) and processed to an Account’s Cash Withdrawal Allocation by the beginning of that calendar year. As part of your instructions, you can elect to withdraw the full amount of the Cash Withdrawal Allocation in your Account as a one-time withdrawal request at the beginning of, or at any time throughout, the year. One-time withdrawal requests in an Account will be processed in accordance with our standard withdrawal request guidelines described above. You can also elect to withdraw partial amounts of the Cash Withdrawal Allocation in your Account over the course of the year at a set frequency we make available (e.g., monthly). You will be charged a Program Fee on the Cash Withdrawal Allocation amount held in your Account until amounts are withdrawn from the Account. You can instruct that the withdrawal amounts be directed to a separate brokerage account or in a deposit account at a Bank Affiliate or at other banking institution. Since these types of accounts are not Program Accounts, the cash in these accounts will not be subject to the Program Fee and will not receive any Program Services. We will not be an investment adviser or fiduciary with respect to such cash in these accounts. If you take withdrawals from your Account that exceed the actual income, it will impact future recurring cash withdrawals. Your instructions will continue in effect until you change or cancel your instructions, your instructions expire by their stated terms, your Account is approaching and/or reaches the required minimum or your Account is terminated. It is important to understand that changes you make to the amount of recurring withdrawals and any unscheduled cash withdrawals will result in changes to the amount of recurring withdrawals that you will receive over the term of your Account in the Strategy. Choosing an amount of recurring withdrawals that is higher than the hypothetical projections or actual income received or making unscheduled withdrawals will result in lower hypothetical projections in future years and reduce the amount of future recurring withdrawals over the term of your Account in the Strategy. Unless the CIO directs that your Account’s Cash Withdrawal Allocation be invested in a cash alternative, like a money market fund, your Account’s Cash Withdrawal Allocation will be treated as a cash balance in your Account that will be automatically swept to the cash sweep option applicable to your Account under the Cash Sweep Program. Other than for Retirement Accounts, there is also a “No Sweep” option. You will be charged a Program Fee on any cash balances and cash alternatives held in your Account. For additional information on cash balances and the Cash Sweep Program, see Item 4 at the sections “Treatment of Cash Balances in your Account” and “Brokerage, Banking-Related and Custodial Arrangements and Services-Cash Sweep Program and other Banking-Related Services.” Any cash allocations invested in a money market fund are subject to such money market fund’s management, distribution, transfer agent, and other expenses. These fees and expenses are in addition to, and will not reduce, your Program Fee, except as required by law. We receive compensation in connection with any such money market fund holdings. See “Item 4 The Program Fee and Other Charges-Determination of how the Program Fee is Charged” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest.” We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See “Item 9 Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Changing Your Strategy. You may be presented with a new recommended Strategy in the future to reflect a change to information you provided through the Online Profiling Process such as a change to your financial situation, time horizon and risk tolerance, or for other reasons. We will implement any approved change to the Strategy that you select as soon as reasonably possible. Termination of Enrollment in the Program. The Agreement may be terminated at any time by either us or you, with written notice to the other party. The termination of the Agreement will terminate enrollment of the Account in the Program. You can request to terminate your Account’s enrollment in the Program either online via the Program Website or by phone at 877.444.0916. Any request to terminate will be confirmed with you via email. If you Merrill Guided Investing Brochure | 19 MGI-2A 032125 terminate enrollment of your Account in the Program online, your positions will remain intact in a securities (brokerage) account with Merrill (Merrill Edge Self-Directed Investing). Your termination of a particular Account will not automatically terminate any of your other Accounts. Termination of the Agreement will not affect or preclude the consummation of any transaction initiated prior to termination. Termination of your Account will be effective following the completion of processes that may be required to terminate the Account, including any required liquidations. If you would like to liquidate all or part of your positions when terminating your enrollment in the Program, you may do so by calling us at 877.444.0916. We will attempt to process your requests in a prompt manner. We will not be responsible for market fluctuations in your Account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient liquidation of an Account include, but are not limited to, size and types of securities, liquidity of the markets and market-makers’ abilities. Due to the administrative processing time needed to terminate an Account, termination requests cannot be considered market orders. It could take up to several business days under normal market conditions to process your request. Upon termination of an Account or the Agreement, a pro rata adjustment to the Program Fee for the remainder of the billing period will be made, which may result in a refund of a portion of the Program Fee monthly payment. In addition, your Account will be converted to, and designated as, a brokerage account that will be subject solely to the terms and conditions of the Merrill securities brokerage account agreement. Merrill reserves the right to take action under its Program guidelines to terminate the Account from the Program if we are unable to obtain instructions from you as to your Account in a timely manner. You (or any other party acting on your behalf) will have the sole responsibility for the investment of assets in the brokerage account. In the event of a termination, the Account assets will not be liquidated but will be held in your brokerage account, except where the holding of such security in that account is not permitted. For certain mutual funds, the advisory share class of such funds are not eligible to be held in an account that is not enrolled in the Program. Upon Account termination, termination of the Agreement or if you or we move or transfer the mutual fund shares from your Account to a brokerage account, we will automatically liquidate, redeem or exchange these shares into another appropriate share or unit class in accordance with the applicable offering materials and our own policies without providing prior notice. Additional fees and expenses may apply upon such liquidation, redemption or exchange. Any liquidation, redemption or exchange will generally be effected as soon as practicable, which may be as soon as the close of the next business day following a termination or transfer. Brokerage share classes of mutual funds generally will have higher operating expenses than advisory share classes of mutual funds that are eligible for the Program and will charge sales loads and annual asset-based fees only applicable to the brokerage share classes. These fees will be used to compensate Merrill or one of its Affiliates. Cash Balances. Your Account will have a cash allocation that will be based on the asset allocation and investment determinations that the CIO has made and, if applicable, amounts of cash set aside for the Cash Withdrawal Allocation of an Account with an Income-Focused Goal. The CIO determines whether to keep a cash balance for operational and/or investment purposes as part of the Strategy. In certain circumstances, including periods of volatile or uncertain market conditions, any such cash allocation may comprise all or a substantial portion of your Account assets invested in a particular Strategy based on, for example, concerns about the market, a decision to pursue a defensive investment strategy, or for cash management purposes. Some portion of your Account will be held in cash for operational considerations, including transaction processing and Program Fee collection. Unless the CIO directs that your Account’s cash allocation be invested in a cash alternative, like a money market fund, your Account’s cash allocation will be treated as a cash balance in your Account that will be automatically swept to the cash sweep option applicable to your Account under the Cash Sweep Program. Other than for Retirement Accounts, there is also a “No Sweep” option. You will be charged the Program Fee on the cash or cash alternatives held in your Account. The CIO can invest cash balances in money market funds which have a one-day settlement period. Any cash allocations invested in a money market fund are subject to such money market fund’s management, distribution, transfer agent, and other expenses. These fees and expenses are in addition to, and will not reduce, your Program Fee, except as required by law. We receive compensation in connection with any such money market fund holdings. See “Item 4 The Program Fee and Other Charges-Determination of how the Program Fee is Charged ” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest.” We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See “Item 9 Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Legal Matters and Related Services. We will not advise or act for you with respect to any legal matters for securities held in your Account, including bankruptcies or class actions and as your broker dealer, MLPF&S will endeavor to send you any documents received with respect to such matters. We will respond to corporate actions for securities in the Account. Corporate actions for a client’s account can include any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. Your Responsibilities for Account Operation and Management. You must notify us through the Program Website and the Online Profiling Process promptly of any material change in financial circumstances, investment objectives or investment restrictions that may affect the nature of the investment advice and services provided to Program Accounts. You are responsible for monitoring the total amount of deposits held at any one bank, including at any of our Bank Affiliates, for FDIC insurance limits. See “Item 4 Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services.” There is more detailed information about FDIC insurance and limits in the Sweep Program Guide for Merrill Clients. Tax Matters General Tax Matters. You are responsible for all tax liabilities and tax-return filing obligations arising from the transactions in your Account enrolled in the Program. We do not, and will not, offer tax advice to you and we strongly encourage you to seek the advice of a qualified tax professional. Merrill Guided Investing Brochure | 20 MGI-2A 032125 You should also understand that we are not responsible for attempting to obtain any tax credit or similar item or preparing and filing any legal document (including, but not limited to, proofs of claim) on your behalf. You should be aware that tax consequences may arise when Strategy changes occur in your Account such as rebalancing, liquidations and redemptions, and as a result of any action undertaken as part of the TEM Overlay Services if elected for an eligible Account. Except to the limited extent described in this section, we specifically disclaim any undertaking of tax management of your Account or investments and assume no responsibility for any resulting tax consequences. Additionally, if you direct us to take certain actions for tax related reasons, there is no assurance that your desired tax effect will be realized. For example, if you direct us to realize gains in your Account, when we resume normal trading activity, such activity could generate new taxable losses or gains, and the same or similar securities may be repurchased. Similarly, if you direct us to realize losses in your Account, when we resume normal trading activity in your Account, such activity could generate new taxable losses or gains. Upon your request to realize losses within an Account and not as part of the TEM Overlay Services, we will attempt to undertake the following: (1) restrict purchases of substantially identical securities in the Account for a minimum of thirty-one calendar days following the sale of securities at a loss in the Account; (2) restrict sales of substantially identical securities in the Account that are currently at a loss for a period of thirty-one calendar days following the purchase of securities in the Account; and (3) at our discretion, engage in strategies to invest the available proceeds for varying time periods in substitute securities, current holdings, and/or alternative securities such as ETFs. We also could determine to hold cash in certain circumstances. We do not make any guarantee that these actions will be successful in recognizing these losses. We are not providing any tax advice with respect to the effects of these transactions including whether a loss has been disallowed under the wash sale rules under the Code. We do not take into account the trading activity in any of your other accounts, including your other Accounts in the Program or any accounts you have with Merrill or its Affiliates or third parties. You should consult your own professional tax advisor regarding the tax consequences of these transactions. You should be aware that as a result of these transactions, a higher than normal cash allocation may result for a period of time. In addition, this type of transactional activity may adversely affect Account performance and may increase the volatility of its results. Special Risks and Limitations associated with the TEM Overlay Services. We make available to eligible Accounts the TEM Overlay Services provided by MAA. There are risks and limitations associated with the TEM Overlay Services and these limitations may result in tax inefficient trades and wash sales. The TEM Overlay Services are designed to effect tax efficient management under U.S. tax rules and regulations. You should consult your tax and/or legal advisor prior to electing the TEM Overlay Services, as well as on an ongoing basis, to determine whether the wash sale rules, the straddle rules, or other special tax rules could apply to your trading activity. Generally, under the wash sale rules, if a security is sold for a loss and the same (or a substantially identical) security is repurchased either 30 days before or 30 days after the date of sale, the loss is disallowed. In addition, other tax treatment rules, such as the straddle rules, may disallow losses. There is little authority governing whether an ETF or mutual fund replacement security is “substantially identical” to another ETF or mutual fund security for purposes of the wash sale rules. As such, no assurances can be provided that if we choose an ETF or mutual fund security as a replacement security to the sold security, the replacement ETF or mutual fund security will not be deemed “substantially identical” for purposes of the wash sale rules. The TEM Overlay Services apply on a per-Account basis only and only to the Account that has selected the TEM Overlay Services. Please note, however, that the wash sale rules apply to securities transactions in not only that Account but also to securities transactions in all other accounts held by you, your spouse and certain entities controlled by you and your spouse. The accounts covered under the wash sale rules include all taxable accounts and retirement accounts held at Merrill or its Affiliate that are brokerage accounts and/or accounts enrolled in investment advisory programs, and all securities accounts of any type held with third parties in each case, held by you, your spouse and certain entities controlled by you and your spouse (collectively, “securities accounts”). The TEM Overlay Services will not take into account trading activity in any of these other securities accounts. The sale of a security for a loss in an Account with the TEM Overlay Services elected will not generate a loss for tax purposes if the security or position was part of a wash sale or straddle as a result of trading activity or securities in any other of your securities accounts. In addition, the purchase of a replacement security in an Account with the TEM Overlay Services elected may give rise to a wash sale with respect to a security or position in any of your securities accounts (including those of your spouse and certain of your spouse’s controlled entities). Similarly, other trades executed in any securities account may also result in a wash sale in the Account with TEM Overlay Services elected. If you have elected to participate in the optional Automatic Withdrawal Service offered through the Program for certain eligible Accounts, the transactions that occur as a result of the TEM Overlay Services could result in wash sales, even in the Account that has elected TEM Overlay Services. In applying the TEM Overlay Services to an Account that includes selling securities and investing in the underlying Total Return Strategy-aligned replacements, the performance of any replacement security selected will not be the same as that of the security sold and, in fact, the replacement security may perform worse than the security sold. Any tax-related benefits that result from the TEM Overlay Services may be negated or outweighed by investment losses and/or missed gains (realized and unrealized) that also may result. An Account that elects TEM Overlay Services will generally trade more frequently than an account which has not elected the TEM Overlay Services. There are implicit trading opportunity costs associated with the additional turnover which may affect the returns on your Account. Electing the TEM Overlay Services may not be appropriate for your financial situation. If you are taxed at lower aggregate marginal income tax rates, you may be less likely to benefit from the TEM Overlay Services than would an investor taxed at higher aggregate marginal income tax rates. Because you may use capital losses only to offset certain amounts of capital gains that you might have, and possibly, to a limited extent, ordinary income, if you have net capital losses in excess of the applicable threshold, you may not realize as many immediate tax benefits through the application of the TEM Overlay Services to your Account. When selling a security that is held in two or more tax lots, TEM Overlay Services may seek to minimize the capital gains tax consequences of the sale and in doing so may consider the holding periods (long-term or short-term) of the securities sold. It is your obligation to monitor transactions across all of your accounts to identify any wash sales or straddles and you are responsible for all tax liabilities attributable to the disallowance of any losses pursuant to the wash sale rules or of any deferral under the straddle rules. Merrill and MAA cannot provide any assurances that losses will not be disallowed pursuant to the wash sale rules or deferred under the straddle rules. If you elect the TEM Overlay Services, you should consider monitoring trade-by-trade confirmations and, to the extent any security is sold for a loss, refraining from acquiring Merrill Guided Investing Brochure | 21 MGI-2A 032125 the same (or a substantially identical) security in your Account or any of your securities accounts. Despite this, it is possible that you may still be subject to the wash sale or straddle rules in any given tax year. Item 5. Account Requirements and Types of Clients Merrill requires that all clients who wish to enroll in the Program enter into the Agreement through the use of the Program Website as described in the Agreement and Brochure. The Agreement sets forth the terms and conditions that govern the handling of the client’s Account and defines the investment advisory relationship between the client and Merrill and MAA in providing Program Services. A separate Account is required for each Strategy selected by the client. Merrill and MAA can decline to accept a particular client or account in the Program at any time and for any reason at their sole discretion. Not all Merrill account types are eligible for enrollment in the Program. Investors generally eligible to participate in the Program include individuals, certain trusts, Retirement Accounts, joint account owners and custodians for an account for minors. Certain Services, such as the optional Automatic Withdrawal Service and the optional TEM Overlay Services, are only available for eligible Accounts. Following enrollment, an Account must maintain a minimum asset amount set by us in our discretion in order for us to provide Program Services. If your Account’s assets do not meet this minimum, we may request that you contribute additional funds to your Account. If you decide not to take the requested action, we reserve the right to terminate your Account from the Program, which converts the Account to a brokerage account type. We may change these minimums at any time. Total Return-Focused Strategy Minimum. The minimum initial investment requirement for your Account is $1,000 or as otherwise provided on the Profile for the Strategy. We may waive or change this minimum at any time. Income-Focused Strategy Minimum. The minimum initial investment requirement for your Account is $50,000 or as otherwise provided on the Profile for the Strategy. We may waive or change this minimum at any time. Item 6. Portfolio Manager Selection and Evaluation Review and Selection of Strategies and Funds Available in the Program General. Through the Program, we make available Strategies with various investment styles and corresponding risk levels, in each case that we decide in our discretion to make available in the Program. The determination to include the Strategies selected in, or to remove them from, the Program is made by us based on a variety of factors, including client needs, investment styles available in the marketplace, platform capacity, client demand and the outcome of reviews conducted by or under the auspices of Merrill, including through the CIO. The CIO is a Merrill business group providing investment solutions, portfolio construction advice and wealth management guidance and is separate from MAA and from the Merrill business group that administers the Program. CIO Review Process. We perform, through our product teams’ internal business processes, initial and periodic reviews of Strategies and constituent Funds that comprise the Strategies. In addition to these business processes, we have in place an investment review (“CIO Review Process”) conducted by or under the auspices of personnel of the CIO of Funds, including those included in the Strategies constructed by the CIO. All constituent Funds included in the Strategies are subject to the CIO Review Process. The CIO Review Process consists of proprietary processes conducted by the CIO and those processes and reviews provided by third-party reviewers that we have engaged for this purpose. The third-party reviewer services are generally consistent with the multi-factor processes that the CIO deploys but they are not identical. We, through the CIO, have reviewed such third-party reviewers’ processes and believe they are reasonable and appropriate in light of the objectives of the Program. Once we identify a need for a particular investment management style, or strategy, a quantitative and qualitative due diligence process is employed, including but not limited to, the organizational structure and stability of the investment manager or Fund manager or sponsor, adherence to investment style, including sustainability or ESG attributes, where relevant, evaluation of risk and volatility, investment professional and strategy resources, investment philosophy and process, portfolio construction, performance, and operating and administrative capability. Based on these factors and using the information collected, the CIO Review Process involves quantitative and qualitative analytical methods, some of which may be subjective. Generally no single factor will be determinative. Our reviews may involve in-person visits, telephone conference calls, reviews of performance, and updates of certain Fund manager prepared materials or Fund documents and information. We may also conduct periodic analysis of composite performance data, however, we, do not perform audits of Funds or Fund Managers or sponsors to verify past performance information provided to us. For each Strategy, we will periodically evaluate factors related to the Strategy and constituent Fund investments that we deem appropriate. There is no assurance that the CIO Review Process or our internal reviews will identify the best performing Funds. For each Fund available at Merrill, including the constituent Funds, we will periodically evaluate factors related to the Fund investments that we deem appropriate. In addition, we may initiate reviews based on various factors determined by us and the CIO to be appropriate, including the level of assets in a Strategy or constituent Fund in client accounts at Merrill or its Affiliate, the number or percentage of Merrill or its Affiliate clients in a Strategy and constituent Funds and the asset class involved. If we identify concerns regarding a Strategy or constituent Fund that we find significant or important, we may choose not to accept any new investments in that Strategy or the constituent Fund. A drift or variation of the style of management of a particular Strategy or constituent Fund from the stated style does not require a removal from our Program offering. Merrill retains the decision-making authority to add or remove a Strategy or a constituent Fund, regardless of or in light of the results of any review conducted, including the CIO Review Process. Merrill Guided Investing Brochure | 22 MGI-2A 032125 Our product teams’ internal business review and the CIO Review Process form the basis for Merrill determining whether to make ETFs available for use in the Program. In addition, the CIO Review Process determines whether ETFs will be included in a Strategy constructed and implemented by the CIO. The CIO Review Process and conclusions from that process do not rely on or otherwise use the research reports and ratings related to certain ETFs of the BofA Global Research Group (“Research Ratings”) as an input or factor. The CIO, BofA Global Research and other business units of BofA Corp. apply different methodologies in their review of ETFs and may arrive at different or inconsistent conclusions. Note that Fund managers include as part of their investment portfolios individual equity and fixed income securities based on their own review and portfolio management processes and determinations. These individual securities may not be covered, and are not required to be subject to, the CIO Review Process. Our review, including through the CIO Review Process, of the Strategies and constituent Funds does not substitute for your ongoing monitoring of your Account and the performance of your investments. Strategy Construction Through the Program, we, through the CIO, will construct the Strategies and select the Funds and the allocations or allocation ranges for each Strategy. In general, we develop the Strategies in an effort to seek to strike a balance between current income and growth for Total-Return Focused Strategies and to seek to obtain a continuing stream of income from investments and that changes over time and for recurring Account withdrawals through a stated end year for Income-Focused Strategies, as described in the Profile for the particular Strategy. The CIO selects the constituent Funds for the particular Strategy and, when doing so, selects only those subject to the CIO Review Process and those that are considered to have sufficient assets under management and to meet minimum trading volume parameters. In addition, it considers and evaluates their share price or net asset value, along with the corresponding allocation weighting, in light of the Strategy’s investment minimum. The CIO determines the allocations or allocation ranges for the Strategies. It develops the strategic asset allocations for the Strategies based on its long- term expected return, risk and correlation assumptions for each asset class (“capital market assumptions”), its view of the appropriate long term allocation guidelines to follow in light of market conditions, expected trends and, as applicable, corresponding tactical asset allocation adjustments. The tactical asset allocation adjustments are applied to those long-term asset allocations based on the CIO’s near-term market, economic and asset class expectations. These tactical adjustments overweight or underweight specific asset classes, incorporating its investment views on how market dynamics, phases of the economic or business cycle, and particular investment themes may affect the Strategies. In order to determine tactical asset allocations, the CIO utilizes internal as well as third-party research and data at both the macro and micro levels. Once the Strategies are constructed, the CIO regularly monitors and reviews them and makes adjustments based on asset allocation changes. The Funds used in the Strategies are also periodically reviewed to ensure they continue to meet the criteria for inclusion. The Strategies are also subject to internal governance and oversight processes on a periodic basis, which may include a review of Strategy performance against expectations as well as any applicable investment or regulatory restrictions. In addition, for Income-Focused Strategies, the CIO provides estimates of projected income amounts (e.g., baseline and variable) based on your initial investment, withdrawal start year and the Strategy that you select. The projected income amounts for the future years are based on your investment amount, your Target Asset Allocation and a U.S. Treasury Yield Curve. A U.S. Treasury Yield Curve is a collection of yields of U.S. Treasury bills, notes, and bonds with different maturities. The projected income amounts are calculated to increase by applying a cost-of-living adjustment that assumes a constant inflation rate for your Time Horizon. The projected income amounts may be adjusted to higher amounts in future years based on the performance of the portfolio and based on the previous projected income amounts. The projected income amounts additionally depend on the capital market assumptions set by CIO. The capital market assumptions are long-term views of major asset classes—including stocks, bonds, cash, and alternative investments. More specifically, they are estimates, for a 25-year planning horizon of the expected returns, volatility, and correlations of a set of asset classes that is broadly representative of the investment universe. The projected income amounts will be adjusted based on the capital market assumptions of the asset classes, prior withdrawals and the performance of the portfolio. They are hypothetical estimates and are intended for illustration purposes only. For more information about how these projections are calculated, how the information you provide is used, the assumptions used and limitations of these projections, please consult “Hypothetical Income Projections Tool“ document available on the Program Website. HYPOTHETICAL PROJECTED INCOME IS NOT GUARANTEED AND DOES NOT PREDICT ACTUAL FUTURE PERFORMANCE. The Program does not currently offer any Related Funds. However, to the extent any Related Funds become available, we may determine to include them in a Strategy. The conflicts of interest and other considerations arising from the use of Strategies constructed, implemented and managed by Merrill or any of its Affiliates are discussed in “Item 9 Compensation, Conflicts of Interest and Material Relationships.” Available Information Regarding Strategies and Funds For the Strategies, we make available to you a document that contains a description of the Strategy you select referred to as a “Profile” on the Program Website. You should carefully read the Profile provided and understand the relevant objectives, styles and risks. The Profiles for the Strategies include performance information from MAA. No claim is made that performance information contained in a Profile has been calculated according to any industry standards. Your Account performance also may differ for a variety of other reasons, including timing of enrollment in the Program, client-imposed Reasonable Investment Restrictions and other considerations. Please note that any past performance shown on a Profile is not indicative of future results and your investment performance for any Strategy in your Account may differ from the information presented in the Profile for that Strategy. We will also make available on the Program Website the applicable Prospectus and/or disclosure documents for the Funds included in your Account, in our discretion and/or as required by law. These disclosure documents will describe the relevant objectives, styles and risks of the constituent Fund. We make available information on the Program Website of regular or ad hoc publications, including those from the CIO that reflect its opinions and views with respect to a Strategy or constituent Fund. Merrill Guided Investing Brochure | 23 MGI-2A 032125 For an eligible Account, you will be provided with documents that contain descriptions of the TEM Overlay Services (“Term Sheets”) on the Program Website. You should carefully read the Term Sheets provided and understand the relevant approaches of the TEM Overlay Services and the risks and limitations. Additionally, the TEM Overlay Services are subject to internal governance processes. Advisory Services Provided by Merrill and Certain Affiliates Merrill and MAA will generally act as the portfolio manager for your Account as described above in Item 4 at the section “Investment and Trading Authority; MAA’s Role.” We act as both the wrap fee program sponsor and portfolio manager for the Strategies offered through the Program. Merrill receives the Program Fee as described in this Brochure. We also act as the portfolio manager in other wrap fee programs sponsored by us. We act as an investment adviser in certain investment advisory programs, like MGI with Advisor and MEAA, which provide investment advisory services that are similar to the Program Services but are not the same. Additional information is available in “About Us and the Program” and in “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” The CIO releases information and analyses used in the Program to Merrill, MAA, our Affiliates and financial advisors at the same time. It is possible that our Affiliates and other investors will act on that information before Merrill or MAA has had the chance to evaluate and act on those changes. Accounts participating in Merrill programs that commence trading after those of other Affiliates may be subject to price movements, particularly with large orders or where securities are thinly traded, that would cause them to receive prices that are less favorable than those potentially obtained by Affiliates or other investors. Tailored Investment Advice As described above in “Item 4 Services, Fees and Compensation,” we will recommend an Account Target Asset Allocation based on certain information provided by you, and you will be able to select a Strategy for your Account designed for your Account Target Asset Allocation and other information you provide to us. Clients may impose Reasonable Investment Restrictions as described in the “Item 4 Services, Fees and Compensation-Reasonable Investment Restrictions.” Performance-Based Fees The Program does not charge performance-based fees. Certain Funds that may be constituent investments as part of the Strategy you select, however, may be subject to performance-based fees or varying Fund expense charges that are imposed by the Fund’s manager, adviser or other party that are based on performance of the Fund. Methods of Analysis The implementation and management of any Strategy will be dependent upon CIO’s investment expertise, philosophy and process. As described in the “Portfolio Manager Selection and Evaluation” section, we use certain methods of analysis and investment strategies to provide clients with access to professional investment advice and make available a choice of various investment styles and corresponding risk levels. You should understand that all investments involve risk (the amount of which may vary significantly), that investment performance can never be predicted or guaranteed and that the value of your Account will fluctuate due to market conditions and other factors. Investment Strategies and Risk of Loss Set forth below is a summary description of material risks related to the Services provided in the Program and investment strategies and products that have significant or unusual risks. The information provided below is meant to summarize certain risks and is not inclusive of each and every potential risk associated with each investment type or applicable to a particular Account. Therefore, you should read all risk disclosures and determine whether a particular Strategy is suitable for your account in light of your specific circumstances, investment objectives and financial situation. General Risks of Investing Through the Program. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed and the values of your assets will fluctuate due to market conditions and other factors. Investments made, and the actions taken, for your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g., COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Strategies that consist of constituent Funds that invest in equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, the selected sectors or industries or the securities market as a whole, such as changes in economic or political conditions. Constituent Funds can also invest in fixed income securities. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain Strategies consist of constituent Funds that invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments by constituent Funds in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the constituent Fund may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. Merrill Guided Investing Brochure | 24 MGI-2A 032125 You should review the offering materials and other disclosures available for the Strategies and for the constituent Funds to get an appreciation of their associated risks and fees. We make no representations or warranties with respect to the present or future level of risk or volatility in your Account or the Strategy or investment’s future performance or activities. You are assuming the risks involved with investing in the Strategies and the constituent Funds. You could lose all or a portion of the amount held in your Account in a Strategy. There is no assurance that the performance results of any benchmark or index used in connection with a Strategy, including those shown in a Profile, can be attained. Market movements and other factors may result in significant differences between the performance of your Account, your Account’s Target Asset Allocation and the Strategy selected for your Account. In addition, you may impose Reasonable Investment Restrictions on your Account that may result in your Account being concentrated in one or a few sectors, industries or securities. Concentrated portfolios typically increase the risk and volatility of the Account and may result in a decrease in diversification. If you align External Assets to any Goal Target that you set for your Account, the composition of those assets, market volatility and conditions and changes that you may make to your External Asset holdings will have an impact on reaching your Goal Target. Particular Risks Regarding the Income-Focused Goal. The hypothetical projected income amount is based on the information you provide to us and the methodology, assumptions and limitations of the tool we use to calculate the hypothetical projections. The assumptions used to derive the hypothetical projected income amount involve a significant element of subjective judgment. In all cases, hypothetical projected income is only an estimate of future results that is based upon assumptions made at the time the projection is developed and other factors as discussed herein. There can be no assurance that the hypothetical projected income will be obtained, and actual income received over the course of the Strategy may vary significantly from the projections. You should expect that the amount of income and recurring withdrawals received each year will change. The hypothetical projected income assumes that your stated Risk Tolerance does not change over the course of the Strategy. If you change this or other information such as your time horizon or the amount of your initial contribution, the projections will change. The hypothetical projections are presented as of the date on which they are provided. If you perform the calculation on a different date, the results may be different due to the difference in time or if any of the underlying assumptions change, even if your information hasn’t changed. Your investment returns and the amount of income and recurring withdrawals received over the course of your time horizon are subject to changes due to general economic conditions, general market fluctuations, and the risks inherent in securities markets. Investment markets can be volatile and prices of investments can change substantially due to various factors. You may experience losses or the Strategy may result in you not receiving adequate income, or income consistent with your hypothetical projected income, at and through retirement. This may be due to any of the risks discussed herein and, in particular, any of the following factors, the scope and magnitude of which cannot be predicted with any level of certainty: (1) market fluctuations; (2) economic growth or recession; (3) local, regional, or global events; (4) changes in interest rates; (5) changes in inflation rates; (6) national or international political changes; (7) changes in the actual or perceived creditworthiness of issuers; (8) general market liquidity; and (9) changes in the Code. The Income-Focused Goal does not ensure that you will have assets in your account sufficient to cover your retirement expenses; this will depend on, among other things, the amount of money you have invested in the Strategy, the returns of the markets over time, the amount you spend in retirement, and your other assets and income sources. The Income-Focused Goal and Strategies do not take into account any assets, investments or income you have (such as pension, Social Security benefits or other retirement income) other than your stated initial investment or current investment balance. WE DO NOT PROVIDE A GUARANTEE THAT SUFFICIENT INCOME WILL BE ACHIEVED TO PROVIDE ADEQUATE INCOME THROUGH YOUR STATED END YEAR OR THROUGHOUT RETIREMENT. If you request that we change your Goal or Strategy, stop or modify the amount or duration of any recurring withdrawals, the likelihood of meeting your Goal may decrease. In particular, if your withdrawal amount is more than the actual income amount, your future annual withdrawal amounts for the rest of your withdrawal period could be reduced significantly. Certain mutual funds or other products may pursue a similar strategy to the Income-Focused Strategies and may charge lower fees than your Account. The Income-Focused Goal is not an annuity and you should consider whether an annuity product is more appropriate for you. Particular Risks Regarding the TEM Overlay Services. If you elect the TEM Overlay Services on your eligible Account, you assume the risks associated with MAA’s investment decisions and trading activity. You also acknowledge that MAA may sell all or a portion of the securities in your Account, either initially or during the course of providing the TEM Overlay Services to your Account and that you understand the risks and limitations associated with the TEM Overlay Services which are summarized in this Brochure, including in the “Item 4.—MAA Tax Efficient Management Overlay Services” and “Item 4.— Tax Matters” sections and the Program Website. You are responsible for all tax liabilities arising from these transactions. We will not offer tax advice to you on these or other issues. Use of Strategies Where Merrill Is the Manager. The Strategies currently available in the Program are those that are constructed and managed by Merrill (through the CIO) and implemented for Accounts by MAA. These Strategies are not subject to the same level of review that is applicable to third- party manager strategies that Merrill offers in its other investment advisory programs. Information and Cybersecurity Risks. With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and, accordingly, BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities, the Funds and Fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. Merrill Guided Investing Brochure | 25 MGI-2A 032125 We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents directed at BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents as well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we or our service providers will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory and operational reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. ESG themed Strategies or Funds. There is an increasing number of products and services that purport to offer environmental, social, and governance (“ESG”) investment related strategies. The variability and imprecision of industry ESG definitions and terms can create confusion. Fund managers and sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. You should review the offering materials and Profiles to gain an understanding of how they define and use ESG screens and restrictions in connection with their investment products. Merrill and MAA generally do not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the Fund manager) other than as part of the CIO Review Process. ESG Strategies, including ESG-related Funds, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by the CIO or fund manager, will align with your ESG-related beliefs or values. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the CIO’s or Fund manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities and, as a result, investment performance could suffer. When evaluating investments for an ESG Strategy, the CIO or Fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment of an investment’s ESG or sustainable attributes. Neither Merrill nor MAA, guarantees or validates any third- party data, ratings, screenings or processes. ETF Investing. Certain Strategies you select generally consist of shares of, or interests in, ETFs. As an ETF shareholder, you, along with other shareholders of the ETF, will bear a proportionate share of the ETF’s expenses, including, as permitted by applicable law, certain management and other fees, which may be payable to us or and our Affiliate. An ETF’s prospectus contains a description of its fees and expenses. When you invest in an ETF, you will indirectly pay a proportionate share of the ETF’s costs for services that may be similar to, or duplicative of, services rendered as part of the Program and paid for directly through the Program Fees. Among other services provided, we or our Affiliates may effect transactions for any of the ETFs offered through the Program, and any compensation paid to us or our Affiliates by the ETF (or its Affiliates) is in addition to the Program Fee. Due to the additional economic benefit to us or our Affiliates when assets in your Account are invested in an ETF that pays compensation to us or our Affiliates, a conflict of interest exists. We attempt to address this conflict by selecting ETFs based on the investment merits of the particular investment products and not based on the compensation that we and our Affiliates earn and through the disclosure in this Brochure. Below is a summary of certain risks relating to investing in ETFs that may apply to all or certain types of ETFs included in a Strategy. Please refer to the particular ETF prospectus for more information about the risks applicable for a particular ETF. If you would like a copy of a particular ETF prospectus, you may obtain one, free of charge, by contacting us at 877.444.0916 or via the Program Website. Merrill Guided Investing Brochure | 26 MGI-2A 032125 ETFs are subject to risks relating to market trading that include the potential lack of an active market for ETF shares and disruptions in the creation and redemption process. Although ETF shares are listed on a national securities exchange, it is possible that an active trading market in the shares of a particular ETF may not develop or be maintained, particularly during times of severe market disruption. If ETF shares need to be sold when trading markets are not properly functioning, the ETF shares may be sold at a significant discount to their Net Asset Value (“NAV”). In some cases, it may not be possible to sell ETF shares in the secondary market. For example, an unanticipated closing of the national securities exchange on which an ETF’s shares are listed or one or more markets on which either the ETF’s shares trade or the ETF’s portfolio holdings trade or the inability of such markets to open for trading during normal business hours, such as in response to a natural disaster or other event causing severe market disruption, could result in the inability to buy or sell shares of the ETF and the ETF’s inability to buy and sell exchange-traded portfolio securities during that period, or in a disruption of the ETF’s creation and redemption process, and may make it difficult for the ETF to accurately price its investments, thereby potentially affecting the price at which ETF shares trade in the secondary market. All of these events could adversely affect the performance of the ETF. Trading in ETF shares also may be halted by an exchange or other markets because of market conditions or other reasons. If a trading halt occurs, an investor may temporarily be unable to purchase or sell shares of the ETF. Similarly, an exchange or other markets may issue trading halts on specific securities or derivatives, which will affect the ability of the ETF to buy or sell certain securities or derivatives. In such circumstances, the ETF may be unable to rebalance its portfolio or accurately price its investments and may incur substantial trading losses. ETF shares also may trade on an exchange or in other markets at prices below their NAV. The NAV of ETF shares will fluctuate with changes in the market value of the ETF’s holdings and the exchange-traded prices of the ETF’s shares may not reflect these market values. Only a firm that is an “Authorized Participant” may engage in creation or redemption transactions directly with an ETF. To the extent that these institutions exit the business or are unable to proceed with creation and/or redemption orders with respect to an ETF and no other Authorized Participant is able to step forward to create or redeem, ETF shares may trade at a discount to NAV and possibly face delisting. This risk is exacerbated if an ETF has a limited number of institutions that serve as Authorized Participants. Certain ETFs may effect creations and redemptions for cash, rather than in-kind. As a result, an investment in such an ETF may be less tax-efficient than an investment in a more conventional ETF. ETFs generally are able to make in-kind redemptions and avoid being taxed on the gain on the distributed portfolio securities at the ETF level. An ETF that effects redemptions for cash, rather than in-kind distributions, may be required to sell portfolio securities in order to obtain the cash needed to distribute redemption proceeds. If the ETF recognizes a gain on these sales, this generally will cause the ETF to recognize a gain it might not otherwise have recognized, or to recognize such gain sooner than would otherwise be required if it were to distribute portfolio securities in-kind. ETFs generally intend to distribute these gains to shareholders to avoid being taxed on the gain at the ETF level and otherwise comply with the special tax rules that apply to it. This strategy may cause shareholders to be subject to tax on gains they would not otherwise be subject to, or at an earlier date than, if they had made an investment in a different ETF. Moreover, cash transactions may have to be carried out over several days if the securities market is relatively illiquid and may involve considerable brokerage fees and taxes. These brokerage fees and taxes, which will be higher than if the ETF sold and redeemed its shares principally in-kind, will be passed on to purchasers and redeemers of creation units in the form of creation and redemption transaction fees. In addition, cash transactions may result in wider bid-ask spreads in shares trading in the secondary market as compared to ETFs that transact exclusively in-kind. ETFs that seek to track the performance of a specified underlying index (“Index ETFs”) are not actively managed and the investment advisers of such ETFs do not attempt to take defensive positions in declining markets. Therefore, Index ETFs may be subject to greater losses in a declining market than a fund that is actively managed. A number of factors may affect an Index ETF’s ability to achieve a high degree of correlation with its underlying index, and there can be no guarantee that an ETF will achieve a high degree of correlation with its underlying index either on a single trading day or for a longer time period. Factors such as ETF expenses, imperfect correlation between the ETF’s investments and the components of the underlying index, rounding of share prices, changes to the composition of the underlying index, regulatory policies, a high portfolio turnover rate, and the use of leverage all contribute to tracking error and correlation risk. Failure to achieve a high degree of correlation may prevent an ETF from achieving its investment objective and cause the ETF’s performance to be less than you expect. An ETF may be subject to stock market risk, which is the chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. To the extent an ETF invests in foreign issuers, those investments can be riskier than investments in U.S. issuers. Foreign stocks tend to be more volatile and less liquid than U.S. stocks. The prices of foreign stocks and the prices of U.S. stocks may move in opposite directions. In addition, if an ETF’s underlying or target index becomes focused in stocks of a particular market sector, the ETF would have proportionately higher exposure to the risks of that sector. An ETF may be subject to country/regional risk and currency risk. Country/ regional risk is the chance that world events — such as political upheaval, financial troubles, or natural disasters — will adversely affect the value of securities issued by companies in foreign countries or regions. If an ETF invests a large portion of its assets in securities of companies located in any one country or region, the ETF’s performance may be hurt disproportionately by the poor performance of its investments in that area. Currency risk is the chance that the value of a foreign investment, measured in U.S. dollars, will decrease because of unfavorable changes in currency exchange rates. An ETF may be subject to the risk that returns from non-U.S. small-and mid-capitalization stocks will trail returns from global stock markets. Historically, non-U.S. small-and mid-cap stocks have been more volatile in price than the large-cap stocks that dominate the global markets, and they often perform quite differently. Small and midsize companies tend to have greater stock volatility because, among other things, these companies are more sensitive to changing economic conditions. To the extent an ETF is invested in fixed-income securities, such as bonds, it may be subject to the risk that a bond issuer will fail to pay interest or principal in a timely manner or that negative perceptions of the issuer’s ability to make such payments will cause the price of that bond to decline. An ETF may also be subject to counterparty risk or the risk that a counterparty fails to meet its contractual obligations to the ETF. In such situations, an ETF may be unable to terminate or realize any gain on the investment or transaction, or to recover collateral posted to the counterparty, resulting in a loss to the ETF. If the ETF holds collateral posted by its counterparty, it may be delayed or prevented from realizing on the collateral in the event of a bankruptcy or insolvency proceeding relating to the counterparty. ETFs invested in fixed-income investments may experience a decline in income when interest rates fall. This decline can occur because the ETF may subsequently invest in lower-yielding bonds as bonds in its portfolio mature, are near maturity or are called, bonds in the underlying index are substituted, or the ETF otherwise needs to purchase additional bonds. During periods of falling interest rates, homeowners will refinance their mortgages before their maturity dates, resulting in prepayment of mortgage-backed securities held by an ETF. The ETF would then lose any Merrill Guided Investing Brochure | 27 MGI-2A 032125 price appreciation above the mortgage’s principal and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the ETF‘s income. In addition, issuers of callable bonds may call securities with higher coupon rates or interest rates before their maturity dates. An ETF would then lose any price appreciation above the bond’s call price and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the ETF’s income. An increase in interest rates may cause the value of securities held by an ETF to decline. During periods of rising interest rates, certain debt securities will be paid off substantially more slowly than originally anticipated, and the value of those securities may fall. For mortgage-backed securities, the risk is that during periods of rising interest rates, homeowners will prepay their mortgages at slower rates. This will lengthen the duration or average life of mortgage- backed securities held by an ETF and delay the ETF’s ability to reinvest proceeds at higher interest rates. To the extent an ETF invests in lower-quality debt securities (“high-yield” or “junk” bonds), which are considered predominantly speculative, the ETF is subject to the substantially greater risk of default of such securities than higher-quality debt securities. Lower-quality debt securities can be illiquid, and their values can have significant volatility and may decline significantly over short periods of time. Lower-quality debt securities tend to be more sensitive to adverse news about the issuer, or the market or economy in general. An ETF invested in municipal securities can be significantly affected by political or economic changes as well as uncertainties in the municipal market related to taxation, legislative changes or the rights of municipal security holders, including in connection with an issuer insolvency. Municipal securities backed by current or anticipated revenues from a specific project or specific assets can be negatively affected by the inability to collect revenues for the project or from the assets. Mutual Funds and Non-traditional Funds. The Strategies you select may invest in shares of, or interests in, mutual funds. Please refer to the particular mutual fund prospectus for more information about the risks applicable for that mutual fund. If you would like a copy of a particular mutual fund prospectus, you may obtain one, free of charge, by contacting us at 877.444.0916 or via the Program Website. As a Fund shareholder, you, along with other shareholders of the Fund, will bear a proportionate share of the Fund’s expenses, including, as permitted by applicable law, certain management and other fees which may be payable to us or our Affiliate. The Fund’s prospectus or other disclosure document contains a description of its fees and expenses. Not all Fund fees and expenses are applicable to every Strategy offered. If you invest in a Fund, you will indirectly pay, through the Fund’s net asset value, a proportionate share of the Fund’s costs for services that may be similar to, or duplicative of, services rendered as part of the Program and paid for directly through the Program Fees. The CIO may determine to invest in shares of or interests in Non-traditional Funds (“NTFs”). NTFs are mutual funds and ETFs registered with the SEC that we classify as “Alternative Investments” as an asset class because their principal investment strategies utilize alternative investment strategies (including short selling, leverage and derivatives as principal investment strategies) or provide for alternative asset exposure as the means to meet their investment objectives. NTFs may not have the same type of non-market returns as other types of Alternative Investments since NTFs have a relatively liquid and accessible structure with daily pricing and liquidity, are subject to a more structured regulatory regime and offer lower initial and subsequent investment minimums. The fees and expenses incurred by any Fund purchased for you through the Program may be in addition to certain of the expenses covered by the Program Fee. Among other services provided, we or our Affiliates may effect transactions for any of these Funds, and any compensation paid to us or our Affiliates by the mutual funds, or their Affiliates, is in addition to the Program Fee. Due to the additional economic benefit to us or our Affiliates when assets in your Account are invested in a mutual fund, a conflict of interest exists. See Item 9 at the section entitled “Offering of Investments or Programs Managed by Us or Our Affiliates.” Securities-based Lending with your Account. Your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through certain unaffiliated or affiliated loan programs, such as, the securities-based lending Loan Management Account® (“LMA”) and Mortgage 100®/Parent Power® mortgage programs (collectively referred to as “Lending Programs”). Under such Lending Programs, you may receive loan proceeds as a result of an arrangement whereby your Account is pledged to a lender, and, in certain circumstances, the lender may be an Affiliate. If you have elected to participate in a Lending Program, the terms and conditions applicable to that Lending Program are governed by the applicable loan documents and other service agreements and are not included or described further herein. You should review carefully the terms, conditions and any related risk disclosures for such Lending Program and understand that such risks may be heightened in the event you hold a concentrated position in your pledged Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. A collateral call could disrupt the management of your Account. You may not be: (1) provided with prior notice of a liquidation of the securities in your pledged Account or (2) entitled to choose the securities which are to be liquidated by the lender. The costs associated with such a lending arrangement under a Lending Program are not included in the Program Fees and may result in additional compensation to us and our Affiliates. You are encouraged to speak with us if you have questions about how your Account may be used in connection with a Lending Program and how such an arrangement should be taken into consideration when discussing the management of your Account. If you have any questions, please contact us at 877.444.0916. Voting Client Securities You have the right to vote proxies for securities held in your Account and will retain proxy voting authority for such securities. You cannot delegate to us and we do not accept or assume any proxy voting authority for securities held in your Account. Item 7. Client Information Provided to Portfolio Managers As part of the online enrollment process (including the Online Profiling Process), we elicit information about your financial circumstances, risk tolerance, time horizon and other relevant information relating to your Account. We will rely on information you provide in managing your assets and servicing your Account. It is your responsibility to notify us promptly of any updates to such information. You can do this by updating your Account information through the Program Website or by phone at 877.444.0916. Failure to do so could affect the suitability of the Services being provided. In the Agreement, you have represented that the information that you provide us is accurate and complete in all material respects. We will not be required to verify the accuracy of any such information. Merrill Guided Investing Brochure | 28 MGI-2A 032125 If you have an investment policy statement or other investment guidelines, it is your responsibility to ensure that the investment policy statement or guidelines are properly reflected in your responses to us and are reflected in your Program Report, including any investment restrictions. We do not have any responsibility to review, monitor or adhere to any investment policy statement, investment guidelines or similar document relating to your Account, and adherence to such investment policy statement, guidelines or similar document is solely your responsibility. Item 8. Client Contact with Portfolio Managers We will make one or more of our advisory or investment personnel reasonably available for consultation with you if you request. Item 9. Additional Information Disciplinary Information The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill’s Form ADV at adviserinfo. sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self- reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’s remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. Other Financial Industry Activities and Affiliations Merrill, an indirect wholly owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through its Affiliate, BofA Securities, Inc., it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and Merrill Guided Investing Brochure | 29 MGI-2A 032125 custodial services. MAA, an indirect wholly owned subsidiary of BofA Corp., is a registered investment adviser that provides investment advisory services to clients that enroll in the Program and other investment advisory programs, including MEAA, MGI with Advisor and IAP. As registered investment advisers, Merrill and MAA complete Form ADVs, which contain additional information about those entities, BofA Corp. and their Affiliates. Information is available through publicly available filings at the SEC or at adviserinfo.sec.gov. For purposes of Form ADV Part 2, certain Merrill and/or MAA management persons are registered as registered representatives or associated persons of Merrill. In the future, certain Merrill and/or MAA personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of Merrill to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, including us, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include: (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning; asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research across the following disciplines: global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act, and additional information about BofA Corp. can be found in publicly available filings with the SEC. Conflicts of Interest and Information Walls Merrill, MAA and their parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time while mitigating any conflict arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within BofA Corp. possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct, which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., BofAS, MLPF&S and MAA and their Affiliates evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. Code of Ethics Each of MLPF&S and MAA has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services under the various investment advisory programs for which they are a registered investment adviser. Each Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that each of MLPF&S and MAA follows in conducting our business with integrity and professionalism. Each Code of Ethics covers such topics as the: requirement that all employees comply with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. All covered personnel must certify the receipt of the Code of Ethics. The Merrill Investment Adviser Code of Ethics is available at mymerrill.com/ADV/materials or we will provide a copy of each of the Code of Ethics to you upon request. MLPF&S and MAA have each imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of their securities transactions and have implemented procedures for monitoring these transactions, as well as those of all our employees. Compensation, Conflicts of Interest and Material Relationships Compensation and Benefits. Merrill earns revenue from the Program Fee you pay. Merrill also earns revenue from other fees and payments you may make, including commissions, mark-ups and mark-downs, up-front sales charges and other sales charges and fees paid in connection with brokerage transactions (collectively, “Sales Charges”) and from what it receives from Affiliates and from third-party investment managers, fund managers and product distributors and sponsors (“Third-Party Firms”) related to transactions in your Account. In addition, we earn revenue from the referrals to Affiliates (including referring to an Affiliate for banking products or services). Merrill may also receive revenue from third parties depending on the investment products in which you invest. The amount of revenue we receive varies depending on the type of account relationship you have with us—whether your Account is enrolled in the Program or is a brokerage account and the investment products in which you invest and the services you use. The revenue we receive from your enrollment in the Program may also be more or less than the revenues that would be received if you had instead participated in our other investment advisory programs or if you had engaged in the investment activities in a brokerage account. The more assets there are in your Account, the more you will pay in fees, creating a financial incentive if you increase the assets in your Account. In the Program, we make more revenue based on the level of assets in the Account as well as the level of the Program Fee. Separate and apart from the Program, we may suggest or recommend that clients, including Program clients, use our securities account, execution and custody or other services for investment activity, or such services of our Affiliate. Similarly, we may suggest or recommend that you purchase our products or our Affiliates’ products. When you engage in brokerage activities and/or you use or purchase Merrill’s or our Merrill Guided Investing Brochure | 30 MGI-2A 032125 Affiliate’s services or products, you pay Sales Charges that compensate us and/or our Affiliates. A portion of the Sales Charges we receive is directly or indirectly used to pay compensation to our Merrill financial advisors and other employees. Management personnel and other employees of Merrill, MAA and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is a financial incentive for management to structure the scope and approach of the compensation program to result in revenue for Merrill and BofA Corp. Our representatives may provide information about banking products and lending services of BANA or purchase products or services of our Affiliates. In addition, they may refer clients to BANA and other Affiliates for financial services that they provide, including transaction execution and investment banking services and products (including banking products). Similarly, employees of BANA, BofAS and other Affiliates may refer clients to Merrill for brokerage and investment advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. If a Merrill representative refers a client to BANA or other Bank Affiliates to establish a bank account directly with the bank, Merrill receives a payment directly from each Bank Affiliate based on the daily deposit balance held by the Bank Affiliate. The amount of the payment made to Merrill varies from time to time and varies based on the Bank Affiliate. We may waive all or part of this payment. These referrals result in a conflict of interest because Merrill and our Merrill representatives are incentivized to introduce products or financial, banking and lending services that provide us or our Affiliates additional compensation. Merrill financial advisors have a financial incentive to recommend or complete the rolling over assets (a “rollover”) from an employer-sponsored retirement plan (such as a 401(k) plan) or from a retirement account at another firm into an Individual Retirement Account (IRA) or other similar account. This is because transactions in the rollover IRA will generate either investment advisory fees if that account is enrolling the Program, Sales Charges if a brokerage account and other compensation that benefits Merrill and the financial advisor. Merrill financial advisors have a financial incentive to recommend or complete Rollovers because the subsequent or related enrollment into the Program will increase the number of accounts serviced by the Merrill financial advisor and help them achieve certain performance goals. We address compensation conflicts described in this “Compensation and Benefits” section and in other sections of the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure, by requiring clients to affirm their interest for the Program and products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices and account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, our representatives are not permitted to recommend investment advisory programs, investment securities and services to a client but may only inform a client about available programs and options. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. Account and Program Choice. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Clients have the ability to enroll accounts in the Program holding some or all of their investment assets and to have brokerage accounts for some or all of their assets. The various programs we offer and ways to interact with Merrill are outlined in our Form CRS, this Brochure and in the Summary of Programs and Services. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. There are differences among the programs and account relationships. You may be able to obtain the same or similar Services or types of investments you obtain in the program through a brokerage account or other investment advisory programs and services offered by Merrill. These may be available at lower or higher fees than the Program Fee you pay. You may also be able to obtain some or all Services from other firms and at fees that may be lower or higher than the Program Fee we charge. The amount of revenue we receive depends on the type of account and relationship you choose. In the Program, you will pay the Program Fee. The Program Services include ongoing fiduciary investment advice and guidance for your Account, access to investment strategies and ongoing monitoring as described in this Brochure, as well as the services of trade execution, clearance and settlement of transactions and custody of assets. In the Program, the amount of compensation paid to us depends on the level of assets in your Account and the Program Fee, as well as certain indirect compensation outlined in this Brochure. In a brokerage account, you will pay per trade Sales Charges to purchase and sell securities. The amount of brokerage revenues we receive depends on the level of trading activity in the Account, the applicable Sales Charges as well as other indirect compensation. Your brokerage account agreement and documents will provide you with information about certain brokerage services and related transaction and account fees for your Merrill account. You could pay higher or lower fees in a brokerage account than from one enrolled in the Program depending on the Sales Charges, frequency of trading and the investment products for investment and other factors. Certain Strategies are available to you outside of the Program for more or less than you would pay in the Program. When you compare the account types and investment advisory programs and their relative costs with what is available in the Program, you should consider the various factors outlined in the section “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Certain of these factors relate to your preferences regarding the relationship, whether you are seeking ongoing monitoring services provided for in the Program, how you want to pay for investment services, the Program Fee, the level of service and the managed investment solutions you are interested in investing in. We disclose in this Brochure the conflicts associated with account and program choice and by providing clients with upfront information about our available programs. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Variable Compensation by Product and Service. We select the investment solutions that are available in the Program and the investment products and solutions that are available in a brokerage account based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and consistency of the execution of their strategy within the respective arrangement. The revenues we receive from a securities transaction vary based on the type of security or investment product and its terms. For certain securities or investment products, Third-Party Firms make Merrill Guided Investing Brochure | 31 MGI-2A 032125 payments to us as compensation for various services and support. These payments also vary depending on the type of security or investment product. Not all securities and investment products make payments to us or our Affiliates and not every investment solution is available in the Program. The variable nature of third-party payments creates a conflict of interest because it provides an incentive to utilize products for which Merrill receives third- party payments or is more highly compensated by the product provider over those where we do not receive such payments or higher compensation. We address this conflict through the disclosure in this Brochure and by selecting Funds based on the investment merits of the particular investment products and not based on the compensation from Third-Party Firms. In addition, we select investment products and solutions that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. For additional information, please review “Compensation Received by Us for Sub-accounting Services,” “Mutual Fund Arrangements and Compensation,” “Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Offering of Investments or Programs Managed by Us or Our Affiliates” in this section below. Compensation Received by Us for Sub-accounting Services. We only make available in the Program mutual funds and money market funds (each, a “fund”) that pay us to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges, dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under agreements with each of these funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services to the holders of these funds maintaining shares in an Account as well as in other Merrill securities accounts and receives the agreed-upon sub-accounting services fee. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by fund types, fund and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. Due to applicable regulation, we do not retain compensation for sub- accounting services for funds held in Retirement Accounts. The sub-accounting service or distribution fees received from the mutual fund or a fund service provider or its Affiliate relating to mutual fund or other securities holdings in a Retirement Account will be credited to the Retirement Account on a periodic basis. For U.S. mutual funds, depending on the specific arrangements, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market mutual funds, the sub-accounting services asset-based fee is generally 0.005% per annum. We have a conflict of interest in selecting certain fund products (or share classes) for inclusion as part of the Strategies available to you. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of the Strategies but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting services fees that we charge will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the sub-accounting services fees paid for these services varies among funds and, in certain instances, between share classes of individual funds. This results in a conflict of interest because it creates an incentive for us to recommend that you invest in funds and share classes that pay higher fees. We will receive higher sub-accounting fee payments from fund families that have higher fund assets held in our clients’ accounts because the service fee calculation is based off of the level of the asset holdings. Additionally, there is a benefit to us because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. We address these conflicts of interest in the following ways. We disclose the nature of our sub-accounting service arrangements. We also determine the compensation paid to our personnel on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our personnel do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we and our Affiliates select funds that are available through the Program as well as in our brokerage accounts and in other of our investment advisory programs based primarily on the CIO Review Process and business reviews. Mutual Fund Arrangements and Compensation. For constituent mutual funds that are part of a Strategy, your assets are generally invested in the lowest cost share class eligible for the Program. The Program-eligible Fund share classes vary depending on the Fund, its roster of share classes and our agreements with the Funds. In general, the share classes that are eligible for the Program do not have annual asset based fees like Rule 12b-1 fees, although there are some mutual funds available in the Program that have such fees due to share class availability or legacy positions that are pending conversion to an eligible share class. Certain mutual funds offer a fund share class that does not include a sub-accounting services fee. Accordingly, you should not assume that you will be invested in the share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. In addition, the share class of money market funds available will not necessarily be the lowest cost share class available from the money market fund. It is generally in your best interest to purchase lower-fee share classes because your returns are not reduced by additional fees and expenses. For clients in the Program, the CIO who manages the Strategies’ models does not have an incentive to recommend or select share classes that have higher expense ratios because the compensation of CIO personnel is not affected by the share class selected. From time to time a fund may authorize us to make available to clients participating in the Program a class of shares of such fund with a lower fee structure that we believe is more beneficial to you than the class of shares previously made available in the Program. Where such exchange is available, under the authority provided to us under the Agreement, we will effectuate an exchange to the other class of shares of this fund with the lower fee structure as promptly as practicable. For additional information on mutual funds and money market funds you can review our “Mutual Fund Investing at Merrill” document which is accessible at ml.com/funds. Cash Sweep Program Compensation Received by Us and Our Affiliates. Merrill benefits financially when your cash balances are held in the bank deposit accounts affiliated with the Cash Sweep Program. Merrill receives payments from our Bank Affiliates on a per account basis for each account that sweeps to one of our Bank Affiliates relating to offering and supporting the Cash Sweep Program. The fees we receive from the Bank Affiliates is one of many factors that affect the interest rate paid by the Bank Affiliates on your swept cash balances under the Cash Sweep Program. If you choose the “No Sweep” option, we also benefit from the custody or use of uninvested cash balances also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. For deposits unrelated to the Cash Sweep Program to our Bank Affiliates relating to referrals, we are entitled to receive a fee directly from each Bank Affiliate based on the daily deposit balance, which fee can be waived in whole or in part. Merrill Guided Investing Brochure | 32 MGI-2A 032125 The Bank Affiliates benefit financially from the Cash Sweep Program. Through the Cash Sweep Program, they receive a stable, cost-effective source of funding. They use the cash funds deposited in the bank deposits to fund their current and future lending, investment and other business activities. The participation of the Bank Affiliates in the Cash Sweep Program increases their respective deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” they earn on the deposits— the difference between the interest paid on the bank deposits and other amounts paid to Merrill related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in your Account (which is the result of a recommendation from the CIO) that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more our Bank Affiliates benefit. Cash balances swept to a bank deposit account of our Bank Affiliates under the Cash Sweep Program will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts is periodically set and reset by the Bank Affiliates in their discretion. Interest rates for the MLDD Program and RASP are tiered based upon your relationship with Merrill and Accounts that enroll in the Program and in specified Merrill investment advisory programs receive the highest tier rate available under the Cash Sweep Program. The interest rate you earn will likely be lower than yields on certain money market funds and other cash alternatives. We address the conflicts of interests associated with the Cash Sweep Program and the deposit accounts in a variety of ways, including through disclosure in this Brochure, by requiring clients to affirm their interest for the Cash Sweep Program options in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to your participation in the Cash Sweep Program. We have adopted various policies and procedures reasonably designed to prevent the cash sweep arrangement compensation and other business arrangements from affecting the nature of the advice we and our financial advisors provide. Offering of Investments or Programs Managed by Us or Our Affiliates. We and our Affiliates offer their own managed products or wrap programs that are similar to this or other Merrill programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including as to recommendations and review determinations. This is due to, among other things, the differing nature of our Affiliate’s investment advisory services and differing processes and criteria upon which determinations are made. We and our Affiliates may provide some or all of the same services offered in the Program through other firms, affiliated or unaffiliated with us, which offer programs similar to the Program at fee rates that may differ from the Program Fee. We do not currently offer any Related Funds. We may, however, include Related Funds as an investment product available in the Program in the future. If offered as an eligible investment in the Program, we would benefit from our economic interest in such entities or their Affiliates when they receive compensation for providing investment advisory, administrative or other services to any such Related Funds. We would address these conflicts by disclosing them in this Brochure. Separate and apart from the Program, Merrill, through its associates, may suggest or recommend that you use the Merrill brokerage account and our execution and custody or other services for other of your investment activity or use the services of our Affiliates. Similarly, Merrill associates may suggest or recommend that you purchase our products or those of our Affiliates. Where you use or purchase our or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Our personnel will, as permitted by applicable law and our policies, receive compensation (the amount of which varies) in connection with these products and services. We address the conflicts of interest presented by these Affiliated transactions by having in place various policies and procedures reasonably designed to prevent the receipt of compensation by Merrill and its Affiliates and other business arrangements from affecting the nature of the advice we provide, although such policies and procedures do not eliminate such conflicts of interest. Other Compensation Received by Us and Our Affiliates. Where permitted by law, Merrill may execute certain transactions on a principal basis through itself or its Affiliates. Transactions that are considered principal transactions include those trades executed in a principal capacity whereby, our Affiliate acts as your trade counterparty and/or acts as a market maker for, or has a proprietary position in, the securities that are the subject of the transaction. We and our Affiliate receive compensation in connection with principal transactions, including markups, markdowns, underwriting discounts, selling concessions and other compensation. We can profit from transacting as your counterparty or having proprietary positions in the subject securities. Moreover, we have an incentive to recommend a transaction in a security that our Affiliate maintains in inventory that is otherwise difficult to sell. Where not prohibited by law, Merrill may engage in agency cross transactions when it acts as agent for both buyer and seller in a transaction. If this type of trading execution occurs, since Merrill generally receives compensation from each party to an agency cross transaction, there is a conflict of interest between our obligations to you and to the other party to the transaction. Third-Party Firm Business Relationships and Support. We and our Affiliates have business relationships with Third-Party Firms. We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for funds and product vehicles managed or sponsored by them (e.g., mutual funds, ETFs). We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates by a Third-Party Firm is additional compensation to us for services we and our Affiliates provide. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. Additionally, we select Strategies and Funds that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our financial professionals provide. Merrill Guided Investing Brochure | 33 MGI-2A 032125 Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (“Conferences”) for invited Merrill professionals. These financial professionals include financial advisors employees who work for a Merrill branch, market or division to support the financial advisors (Field Management Employees) and employees who cover product, CIO and home office support functions (Non-Field Employees). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third-Party Firms participate (“Client Events”). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending financial advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with holding such Conferences and Client Events in the amount of approximately $21 million from participating Third-Party Firms. Certain Third-Party Firms periodically host or participate in meetings (“Manager Meetings”) where they provide certain financial advisors, Field Management Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending financial advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provided monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of charitable events and causes that we requested or initiated with the Third-Party Managers in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives to recommend products of participating Third-Party Firms. They give those participating in Conferences, Client Meetings, Manager Meetings and charitable events with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for Field Management Employees to approve those recommendations and for non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our financial advisors to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Management Employees to approve recommendations of products and services of those participating Third-Party Firms. Furthermore, we do not incentivize Non- Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. Third-Party Firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs of Conference and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Representatives of Third-Party Firms will, from time to time, meet and work with our financial advisors and other employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third- Party Firms from providing or paying for, and our financial advisors and other employees, from receiving, gifts and entertainment (including meals) other than as permitted by and subject to the limits established under Merrill internal policies. In general, they may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting Third-Party Firm representatives access to our financial advisors and other employees and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to take certain action in favor of the investment products of those Third-Party Firms. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. Provision of Diversified Financial Services by Us and our Affiliates. BofA Corp. is a diversified financial services company that generally seeks to provide a wide range of services to retail and institutional clients for which it receives compensation. As a result, we, BofA Corp. and our Affiliates can be expected to pursue additional business opportunities with the entities whose investments Merrill and its Affiliates make available through the Program. Consistent with industry regulations, these services that we and our Affiliates provide include banking and lending services, sponsorship of deferred compensation and retirement plans, recordkeeping services, investment banking, securities research, institutional trading and prime brokerage services, custody services, investment advisory services, licensing arrangements involving indices and effecting portfolio securities transactions for our clients. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships is publicly available in Regulation NMS Rule 606 reports we file with the SEC. From time to time, Merrill may offer to clients or potential clients certain promotions or rewards in connection with opening, maintaining or adding assets to a Merrill securities account. Such promotions or rewards may include, by way of example, the payment of a cash reward. The promotions may require a client to request to receive or participate in the promotion or reward, and/or require a client to meet various eligibility criteria. While these promotions or rewards may extend to a client’s Merrill securities account that holds assets in the Program, participation in the Program is not a condition for these promotions or rewards. Merrill Guided Investing Brochure | 34 MGI-2A 032125 Participation or Interest in Client Transactions and Conflicts of Interest There are various ways that we can be viewed as participating or having an interest in client transactions. These situations and any conflicts of interest arising from such activities, execution approach or other capabilities we offer in the Program are discussed in this section and throughout the Brochure. Cash Balances and Cash Sweep Program. The Sweep Program Guide for Merrill Clients provides information on the fees that Merrill receives from the Bank Affiliates for each account, including a Program Account that sweeps to the MLDD Program or RASP. These fees are up to $100 per year for each account received from the Bank Affiliates. This compensation is subject to change from time to time, and Merrill may waive all or part of it. Merrill may benefit from the possession or use of cash balances, also known as free credit balances, in your accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. As further described in “Item 4 Funding and Operation of Accounts-Cash Balances,” cash balances may be held in your Account for a number of different reasons, including as part of a Strategy’s asset allocation to cash or to support recurring withdrawals, including Cash Withdrawal Allocation for an Account with an Income-Focused Goal. To the extent Merrill through its CIO does not select a cash alternative for your Account’s cash allocation, there is a conflict of interest between you and us because the cash allocation will be maintained in your Account as a cash balance. For most clients, cash balances will be swept to bank deposit accounts at our Bank Affiliate through the Cash Sweep Program. See “Item 9 Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates” above. Participation in Affiliate Lending Programs and Margin. There are conflicts of interest when you use a loan from Merrill or one of its Affiliates secured by your Account assets as collateral. These conflicts exist with a margin loan from Merrill or with any of our Affiliate lending programs that may be available to you from an Affiliate lender. In the case of a loan from our Affiliate, including but not limited to the Loan Management Account® product (“LMA® account”), the Affiliate lender intends to derive a profit as lender based on interest and/or fees, if any, charged on the loan. The lender, whether it be Merrill or its Affiliate, has a lien on your Account assets that are used as collateral for the loan. The lender will act to protect itself as lender in connection with the loan, and this may be contrary to your interests and/or investment objectives. Please refer to “Item 6 Investment Strategies and Risk of Loss” for additional information. Activity by Merrill, Affiliates and Personnel. As part of a global financial services firm, Merrill will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by Merrill or any of its Affiliates, its or its Affiliates’ roles in connection with other clients and in the capital markets, its internal policies, and/or potential reputational risk. As a result, client accounts managed by Merrill may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by BoA Corp. We and our Affiliates act in a variety of capacities to a wide range of clients. From time to time in the course of those duties, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. See ”Conflicts of Interest and Information Walls” in this Item 9. Similarly, we may give advice or take action with regard to certain clients, including clients in the Program, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken for certain securities, mutual funds, ETFs or investment managers. In some instances, the actions taken by our Affiliates for similar services and programs may conflict with the actions taken by us. This is due to, among other things, the differing nature of our Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. In addition, potential conflicts of interest also exist when Merrill maintains certain overall investment limitations on positions in securities, Funds or other financial instruments due to, among other things, investment restrictions imposed upon Merrill or its Affiliates by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude the inclusion of particular securities, Funds or financial instruments in a client’s Account where Merrill or MAA provide discretionary management services, even if the securities or financial instruments would otherwise meet the investment objectives of such Account. We and our Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs by us, our Affiliates and those of our clients that have granted discretion to us, our Affiliates (“discretionary clients”) to avoid potential restrictions on our ability and our Affiliate’s ability to engage in principal trading and other transactions such funds. Registered Funds identified by us for these limitations from time to time are referred to as “In-Scope Funds.” A portion of the aggregate ownership limit is attributed to our Affiliates. When we and our Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to us, or our Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because our and our Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest for us in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. From time to time, however, a constituent Fund selected for a Strategy may invest in securities issued by BofA Corp. or its Affiliates to achieve its investment objective. Any such investments by a Fund are required to comply with the applicable provisions of the Investment Company Act, including limitations on investments in securities-related businesses, and will not be influenced by MLPF&S or MAA. From time to time, a shareholder of BofA Corp. could acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Account, such as buying or selling securities issued by the shareholder or its Affiliates, will be limited. The CIO releases information and analyses about a Strategy or a constituent Fund covered under its CIO Review Process to Merrill, MAA, and our Affiliates at the same time and BofA Global Research releases its research opinions and research reports to the public at the same time as Merrill, MAA and our Affiliates receive it. It is possible that our Affiliates and other investors act on that information before Merrill or MAA have had the chance to evaluate and act on those changes. Accounts that commence trading after the release of such information will be subject to price movements that would cause them to receive prices that are less favorable than those potentially obtained by our Affiliates or other investors. We address these conflicts in a variety of ways. including through disclosure in this Brochure; our policies that require that our recommendations of Strategies be suitable for each client based upon investment objectives, risk tolerance, financial situation and needs; and a variety of restrictions, Merrill Guided Investing Brochure | 35 MGI-2A 032125 procedures and disclosures designed to address potential conflicts of interest — both those arising between and among Accounts as well as between Accounts and our business. For example, our personnel also are subject to personal trading restrictions as detailed in our policies and procedures and Code of Ethics. Trade Execution. We or our Affiliate may execute transactions in your Account on a principal basis (that is, when we or an Affiliate sell a security to you, or buy a security from you, for our own account) as permitted by law, and upon your consent (when required by applicable regulations). Principal transactions may give you access to investment opportunities or trade executions that might not otherwise be available to you, such as trading of fractional shares within your Account. Principal transactions may not be effected for Retirement Accounts, except in accordance with applicable law. There are conflicts of interest present when we execute transactions in your Account on a principal basis. If Merrill effects a principal transaction for your Account, then in addition to the Program Fee, we receive a benefit from the “spread” or the difference between the price we pay for a security and the price at which we sell it to you, or between the price we may pay for a security that we may buy from you and the price for which we may later sell it. The receipt of additional compensation and an incentive to recommend a transaction involving our inventory present conflicts between our interest and yours. The types of securities that may be purchased or sold on a principal basis in your Account pursuant to the terms of your Agreement may change in the future and could become more limited. We may, at times, have the opportunity to act as agent for both buyer and seller in a transaction for your Account. This is called an agency-cross transaction. Since we generally will receive compensation from each party to an agency-cross transaction, there is a potential conflict between our responsibilities and loyalties to you and to the other party to the transaction. Any compensation we receive will be in addition to the Program Fee. The Agreement generally gives us permission to engage in agency-cross transactions for your Account, except where prohibited by law. You may revoke your consent at any time by notifying us in writing. At times, we may consider a security being sold by one investment advisory client to be appropriate for purchase by another investment advisory client account. In such cases, we may arrange to transfer or “cross” the security directly between the affected accounts. Any cross transactions in your Account would be effected in accordance with applicable law and your Agreement. Cross transactions generally will be effected at an independently determined market price and will not result in any additional compensation to us. For a Retirement Account that is subject to ERISA or the Code’s prohibited transaction rules, transactions, including agency-cross transactions, will be effected by or through Merrill or our Affiliates in compliance with ERISA Section 408(b)(19), U.S. Department of Labor Prohibited Transaction Exemption 86-128, or otherwise in a manner that is not prohibited by ERISA or the Code. We do not receive payment for order flow from liquidity providers to which we route our customer orders in equity securities. We directly or indirectly (through our Affiliates) receive rebates from, and pay fees to, certain registered securities exchanges for providing or taking liquidity on those exchanges, according to those exchanges’ published fee schedules filed with the SEC. In some cases, the rebates received by us from an exchange will, over a period of time, exceed the fees paid to the exchange. The rebates and payments from these third parties vary depending on the order and the exchange to which orders are directed and create a conflict of interest because we are incentivized to recommend transactions that provide us with greater rebates or payments from these exchanges. Covered Entities under the Volcker Rule. We may provide certain entity clients that qualify as “family wealth management vehicles,” or FWMV clients, with both the Program Services as well as lending services and engage, where permitted, in principal transactions. In doing so, we rely on the exception under the Volcker Rule implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Agreement. For certain entity clients that are deemed ”covered fund” clients under the Volcker Rule, we are not permitted to offer both Program Services and the availability of margin, lending or other extensions of credit from us or any of our Affiliates, including BANA, or engage in certain principal transactions. Certain other transactions between BANA or its Affiliates and the entity client will also be prohibited. Account Reviews and Reporting An important part of the Program relationship involves providing you with the opportunity to engage in periodic online reviews. These reviews provide updates on the progress of your Account, performance of your Account’s portfolio and other important information about your investments. This review is also an opportunity to ensure that the information you provide is complete, accurate and reflects your financial situation and objectives for the Accounts enrolled in the Program. As noted above, if there are multiple owners on this Account, the information you provide should reflect the views and circumstances of all owners on the Account. If you are the fiduciary of this Account for the benefit of the account owner or account holder (e.g., the trustee for a trust or custodian for an UTMA), please keep in mind that these assets will be invested for the benefit of such account owner or account holder. A periodic review of an Account should typically occur on an annual basis; however, we have the ability under our Program guidelines to extend or defer the timing of the review under certain circumstances and for certain periods of time. We will contact you periodically, primarily through electronic means, to request that you review your information for each of the Accounts in the Program and ensure that it is up to date. You will be required to perform your review through the Program Website. You may receive additional reminders through other means to complete your review through use of the Program Website. If you do not respond to our requests to review your information to ensure it is up to date, we will view that as confirmation that your information continues to be accurate and complete if certain criteria is met under our Program Guidelines. Because these reviews provide you with important information relating to your Account, you are encouraged to take advantage of these opportunities to participate in Account reviews. If you do not participate in your Account review, we may, in our discretion, terminate your Account. At the time of your periodic review, we may determine to recommend a new Strategy for your Account. If we recommend a new Strategy for your Account, we will notify you to consider and, if acceptable to you, to select the new Strategy for your Account. We will periodically communicate to you important information about how we are managing your assets in the Program. The primary means through which we will communicate with you and memorialize in writing the important terms, conditions and information about your Account and Strategy is through a Program Report. You will receive a Program Report from us after we accept your enrollment in the Program and when you make a Strategy change and when your Target Asset Allocation for the Account is changed. Merrill Guided Investing Brochure | 36 MGI-2A 032125 The information set forth in the initial and each subsequent Program Report is how we reflect the Services that we will provide to you with respect to the assets in your Account and pursuant to the Agreement. You should review each Program Report we send to you carefully to ensure that the information reflected therein is accurate and you should contact us or update your information via the Program Website if you believe any of the information is, or becomes, inaccurate. We will send you periodic updates that contain information about your Account, including trade confirmation information and account statements. We will also provide you with performance information online through the Program Website to help you monitor and assess the performance of your Account and the Strategy you select. This includes information regarding investment return, risk and selected benchmark comparisons for your Account assets in the Strategy you select. You should review all such materials carefully and promptly report any discrepancies to us. As an accommodation to you, we may agree, in our sole discretion, to include, in certain of our Program communications and reports, information about External Assets that you have provided to us in connection with your Goal Target. The Program Fee will not apply to these External Assets. We reserve the right to change the format, content and nature of the presentation of information in the Program Report in our sole discretion. The Program Report or other Program communications, including those prepared or delivered in a digital or electronic format, may also include information about your accounts that are not subject to the Agreement, including, in our discretion, your brokerage accounts, other investment advisory program accounts and banking relationships and accounts held at other financial institutions. Their inclusion in a Program Report or other materials is provided for your information only and does not change the nature of our obligations to you under agreements related to those accounts and relationships. The Program Fee will not apply to these accounts or relationships, and we will not be an investment adviser or a fiduciary with respect to the assets in such accounts, solely by virtue of their inclusion in a Program Report or other materials we provide. Any such included accounts will continue to be subject to the terms and conditions of the applicable securities or other account agreements. Any advice that we may provide to you with respect to the assets in such accounts, including asset allocation advice, will be incidental to the services that we provide to you under the other applicable securities or other account agreements. Referrals and Other Arrangements Our employees may refer advisory clients to BANA and other of our Affiliates for products and services. Similarly, employees of BANA and its Affiliates may refer clients to MLPF&S for brokerage and investment advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. MLPF&S financial advisors may receive compensation for referrals to the Program. We have entered or may enter into marketing arrangements with third parties who, for compensation, will provide consulting or other services to us in connection with marketing our various advisory programs. Each such marketing arrangement is or will be governed by a written agreement between us and the third-party, and will be disclosed to you, as required by law. Financial Information Not applicable because (1) Merrill is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act (2) Merrill and MAA do not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (3) there is no financial condition of which we are aware that is reasonably likely to impair Merrill or MAA’s ability to meet contractual commitments to its clients; and (4) Merrill or MAA each has not been the subject of a bankruptcy petition at any time during the past 10 years. Merrill Guided Investing Brochure | 37 MGI-2A 032125 Glossary “Account” means the securities account to which the Agreement applies and that is enrolled in the Program, as set forth in the Program Report. “Account Risk Tolerance” is a reflection of your tolerance for potential loss of some or all the assets in your Account in exchange for greater potential returns, which is expressed in three levels; Low (Conservative), Medium (Moderate) and High (Aggressive). “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Affiliate” means a company that is controlled by, in control of, or under common control with another company. “Agreement” means the investment advisory agreement for the Program among the client, MAA and MLPF&S, as it may be amended from time to time. “Allocation Profile” means the allocation of assets to one or more asset classes that is based on certain information you provide as part of the Online Profiling Process and through the Program Website. Hypothetical projections are calculated based on a goal’s Allocation Profile. “BofAS” means BofA Securities, Inc., an Affiliate of Merrill. “Bank Affiliate” means Bank of America, National Association (BANA) or other banks that are affiliated with us. “Cash Sweep Program” means the program provided as part of your brokerage account agreement whereby cash balances in your Account are automatically swept into a cash sweep option available for your Account type. “CIO” means the Chief Investment Office of MLPF&S. “Code” means the U.S. Internal Revenue Code of 1986, as amended. “Constituent Fund” means a Fund that is included as part of a Strategy. “Effective Date” means the date the account’s enrollment in the Program is accepted by us. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “FDIC” means the Federal Deposit Insurance Corporation. “FINRA” means the Financial Industry Regulatory Authority, Inc. “Fund” means registered investment companies, including mutual funds and ETFs. “Investment Company Act” means the Investment Company Act of 1940, as amended. “Lending Programs” means, collectively, certain unaffiliated or affiliated loan programs, such as, but not limited to, the securities- based lending Loan Management Account® (“LMA”) and Mortgage 100®/Parent Power® mortgage programs. “MLDD Program” means the Merrill Lynch Direct Deposit Program. “NTF” means a nontraditional mutual fund or ETF registered with the SEC that is classified as an Alternative Investment by us because its principal investment strategies utilize alternative investment strategies or provide for alternative asset exposure as the means to meet its investment objectives. “Program” means Merrill Guided Investing, an online investment advisory program described in this Brochure. “Program Report” (also referred to as a Portfolio Summary) means a periodic communication sent to you electronically that contains important terms, conditions and information about your Portfolios, Accounts and Strategies. “Program Website” means merrilledge.com/guided-investing. “RASP” means the Retirement Asset Savings Program. “Reasonable Investment Restrictions” means one or more reasonable investment restrictions accepted by us that you would like to impose for your Account, such as identifying a mutual fund or ETF that should not be purchased. “Related Fund” means any Fund sponsored, managed, or advised by us, or any of our Affiliates. “Retirement Account” means an individual retirement account within the meaning of Section 408(a) of the Code, a simplified employee pension within the meaning of Section 408(k) of the Code, a simple retirement account within the meaning of Section 408(p) of the Code, and a Roth IRA within the meaning of Section 408A of the Code. “SEC” means the United States Securities and Exchange Commission. “Services” means the services provided through the Program and described in this Brochure. “Strategy” means an investment strategy developed by the CIO to align to a particular Target Asset Allocation. “Third-Party Firms” means third-party investment managers, fund managers, product distributors and sponsors, insurance companies and other product providers. “Unaffiliated Trade Counterparty” means a bank, broker or dealer other than Merrill or a Merrill Affiliate. “You” or “your” means each account owner or account holder or fiduciary acting on behalf of an account owner or account holder (e.g., trustee for a trust or custodian for an UTMA). L-03-25 Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. ©2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated. Printed in the U.S.A. Merrill Guided Investing Brochure | 38 MGI-2A 032125

MERRILL GUIDED INVESTING WITH ADVISOR merrilledge.com/guided-investing WRAP FEE PROGRAM BROCHURE Please retain for your records Managed Account Advisors LLC 101 Hudson Street Jersey City, NJ 07302 201.557.0504 Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 888.637.3343 (Main) 888.654.6837 (Program) www.merrilledge.com This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and Managed Account Advisors LLC (“MAA”) relating to Merrill Guided Investing with Advisor (the “Program”), an investment advisory program with digital access and support of an advisor. Information about the Program, including a copy of this Brochure, can be accessed at merrilledge.com/guided- investing. Additional information about MAA and MLPF&S also is available on the SEC’s website at adviserinfo.sec. gov. If you have any questions about the contents of this Brochure, please contact us at 888.654.6837. Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. , MAA or Bank of America Corporation ( BofA Corp.) or any of their affiliates and are subject to investment The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (FDIC) or any other government agency, are not a deposit or other obligation of or guaranteed by MLPF&S risks, including possible loss of principal. March 21, 2025 Merrill Edge, available through Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”), consists of Merrill Edge Advisory Center (investment guidance) and self-directed online investing. MLPF&S is a registered broker-dealer, Member SIPC and a wholly owned subsidiary of Bank of America Corporation. Investment products: Are Not FDIC Insured May Lose Value Are Not Bank Guaranteed Are Not Insured by Any Federal Government Agency Are Not Deposits Are Not a Condition to Any Banking Service or Activity © 2025 Bank of America Corporation. All rights reserved. To learn about Bank of America’s environmental goals and initiatives, go to bankofamerica.com/environment. Leaf icon is a registered trademark of Bank of America Corporation. MGI-A 032125  ITEM 2. MATERIAL CHANGES On March 22, 2024, MLPF&S and MAA together filed their last annual update to its Merrill Guided Investing with Advisor program brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. It also sets forth changes as well as enhancements made in this annual update as well as those made since the 2024 annual update, which were previously communicated. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated Item 9 “Additional Information” at the heading “Disciplinary Information” to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our financial advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Item 9 Compensation, Conflicts of Interest and Material Relationships—Third-Party Firm Business Relationships and Support.” • We have updated our disclosures throughout the Brochure to make other enhancements. MATERIAL CHANGES AND ENHANCEMENTS MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: August 23, 2024 Brochure Update Material Changes and Enhancements • We have modified and added disclosures to describe the optional tax efficient management overlay services from MAA (“TEM Overlay Services”) that a client can now elect for a taxable Account with a Growth-Focused Goal enrolled in the Program. In particular, we updated disclosures in Items 4 and 6 to include descriptions of the optional TEM Overlay Services and the particular risks and limitations associated with the TEM Overlay Services, if elected. October 18, 2024 Brochure Update Material Changes and Enhancements • We updated “Item 9 Additional Information” at the heading “Disciplinary Information” to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” • We have updated our disclosures throughout the Brochure to make other enhancements. Merrill Guided Investing with Advisor Program Brochure | 2 MGI-A 032125 ITEM 3. TABLE OF CONTENTS About Us and the Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Overview of the Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Item 4. Services, Fees and Compensation . . . . . . . . . . . . . . . . . . . . . . . 6 General. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Electronic Accessibility Requirement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Advice and Guidance Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Establishing Your Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Investment Advice Services for Accounts Selecting the Growth-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Recommending a Target Asset Allocation for the Growth-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Recommending a Strategy for the Growth-Focused Goal Type . . . . . . . 8 Investment Advice Services for Accounts Selecting the Income-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Recommending a Target Asset Allocation for the Income-Focused Goal Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Recommending a Strategy for the Income-Focused Goal Type . . . . . . 10 Effect of Withdrawal Changes and Withdrawals on an Item 5. Account Requirements and Types of Clients. . . . . . . . . . . . . 22 Item 6. Portfolio Manager Selection and Evaluation. . . . . . . . . . . . . 23 Review and Selection of Strategies and Funds Available in the Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 CIO Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Strategy Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Available Information Regarding Strategies and Funds. . . . . . . . . . 24 Advisory Services Provided by Merrill and Certain Affiliates . . . . 24 Performance-Based Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Methods of Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Tailored Investment Advice. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Investment Strategies and Risk of Loss . . . . . . . . . . . . . . . . . . . . . . . . 25 General Risks Associated with Investments in your Account . . . . . . . . 25 Target Asset Allocation and Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . 26 Particular Risks Regarding the Income-Focused Goal . . . . . . . . . . . . . . 26 Particular Risks Regarding the TEM Overlay Services. . . . . . . . . . . . . . 26 Use of Strategies Where Merrill is the Manager . . . . . . . . . . . . . . . . . . 26 Information and Cyber Security Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 ESG Themed Strategies or Funds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 ETFs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Mutual Funds and Non-traditional Funds . . . . . . . . . . . . . . . . . . . . . . . . 28 Securities-based Lending with your Account . . . . . . . . . . . . . . . . . . . . . 28 Voting Client Securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Item 7. Client Information Provided to Portfolio Managers . . . . . . 28 Item 8. Client Contact with Portfolio Managers. . . . . . . . . . . . . . . . . 28 Item 9. Additional Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Disciplinary Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Other Financial Industry Activities and Affiliations . . . . . . . . . . . . . 29 Conflicts of Interest and Information Walls. . . . . . . . . . . . . . . . . . . . . 29 Code of Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Compensation, Conflicts of Interest and Material Relationships . 30 Compensation and Benefits to Merrill, Program Advisors and Merrill Management Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Account and Program Choice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Variable Compensation by Product and Service . . . . . . . . . . . . . . . . . . . 32 Offering of Investments or Programs Managed by Us or Our Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Compensation Received by Us for Sub-accounting Services . . . . . . . . 32 Mutual Fund Arrangements and Compensation . . . . . . . . . . . . . . . . . . . 33 Cash Sweep Program Compensation Received by Us and Our Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Other Compensation Received by Us and Our Affiliates. . . . . . . . . . . . 33 Third-Party Firm Business Relationships and Support . . . . . . . . . . . . . 34 Provision of Diversified Financial Services by Us and our Affiliates . . 35 Income-Focused Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Annual Review of Withdrawal Amount. . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Investment and Trading Authority; MAA’s Role . . . . . . . . . . . . . . . . . 11 Reasonable Investment Restrictions . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Available Strategies, Profiles and Prospectus Delivery . . . . . . . . . . 12 Program Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Treatment of Cash Balances in your Account . . . . . . . . . . . . . . . . . . . 13 Account Reviews and Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Brokerage, Banking-Related and Custodial Arrangements and Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Brokerage Trading Services Generally . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Rules for Cash Accounts and Margin Transactions . . . . . . . . . . . . . . . . 14 Cash Sweep Program and Other Banking-Related Services . . . . . . . . 14 Custodial Arrangements and Services . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Account Features . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Proxy Voting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Trade Confirmation Statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Electronic Delivery Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Optional Account Services for Growth-Focused Goals. . . . . . . . . . . 15 MAA Tax Efficient Management Overlay Services. . . . . . . . . . . . . . . . . 16 Automatic Withdrawal Service for Growth-Focused Goals . . . . . . . . . . 16 The Program Fee and Other Charges . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 The Program Fee Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Calculation and Payment of the Program Fee. . . . . . . . . . . . . . . . . . . . . 17 Deduction of the Program Fee from Your Account . . . . . . . . . . . . . . . . 17 Determination of how the Program Fee Is Charged. . . . . . . . . . . . . . . . 17 Fees and Expenses Not Covered by the Program Fee . . . . . . . . . . . . . . 17 Participation or Interest in Client Transactions and Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Cash Balances and Cash Sweep Program . . . . . . . . . . . . . . . . . . . . . . . . 35 Participation in Affiliate Lending Programs and Margin . . . . . . . . . . . . 35 Activity by Merrill, Affiliates and Personnel . . . . . . . . . . . . . . . . . . . . . . 35 Trade Execution. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Covered Entities under the Volcker Rule . . . . . . . . . . . . . . . . . . . . . . . . . 36 Account Reviews and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Referrals and other Arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Financial Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Ability to Obtain Certain Services Separately and for Different Fees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Funding and Operation of Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Opening and Funding your Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Withdrawal Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Required Withdrawals for Income-Focused Goals . . . . . . . . . . . . . . . . . 20 Changes to Your Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Termination of Enrollment in the Program . . . . . . . . . . . . . . . . . . . . . . . 20 Cash Balances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Legal Matters and Related Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Your Responsibilities for Account Operation and Management. . . . . . 21 Tax Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 General Tax Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Special Risks and Limitations associated with the TEM Overlay Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 All capitalized terms used in the Brochure are defined in the body of this Brochure or in the Glossary. Merrill Guided Investing with Advisor Program Brochure | 3 MGI-A 032125  About Us and the Program Both Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and its Affiliate, Managed Account Advisors LLC (“MAA”), offer investment advisory services under the Merrill Guided Investing with Advisor program (“Program”) as discussed in this Form ADV brochure (“Brochure”). Both MLPF&S and MAA are registered with the U.S. Securities and Exchange Commission (“SEC”) as investment advisers and MLPF&S is registered as a broker-dealer. Both Merrill and MAA provide services under the Program in their capacity as a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).Our parent company, Bank of America Corporation (“BofA Corp.”), through Bank of America, N.A. (“BANA”) and other of its Affiliates, provides integrated investment services and is a leading banking institution for consumers, corporations and institutions. When we use the terms “Merrill,” “we,” “our” or “us” in this Brochure, we are generally referring to MLPF&S. We use the terms ”Merrill,” “we,” “our” or “us” to apply to both MLPF&S and MAA for those aspects and services of the Program that MLPF&S and MAA perform jointly. We also indicate where certain services are provided by MAA in its separate capacity. “You” or “your” means each account owner or account holder, or fiduciary acting on behalf of an account owner or account holder (e.g., trustee for a trust or custodian for an UTMA). All capitalized terms are defined in the body of this Brochure and/or in the Glossary. Our Services as an Investment Adviser and Relationship with You under the Program. The Program is designed to help you pursue your investing goals by providing you with investment advice, guidance and access to advisory services and investment solutions and other services as described in this Brochure and delivered through the Program’s interactive website at merrilledge.com/guided-investing (the “Program Website”) and our representatives. For Program services, you work with our Merrill representatives who have the title or designation “Financial Solutions Advisor” (“FSA”) and who are available to you through our call center and at various bank branch locations. In this Brochure, we use the term “Program Advisor” to refer to an FSA. We will provide disclosure documents called the “Form ADV Part 2B – Brochure Supplements,” which describe information about Program Advisors and the role and the services they provide, among other things. We also provide Form ADV Part 2B-Brochure Supplements for other Merrill investment professionals who provide portfolio management services for the investment strategies we offer in your enrollment materials. To obtain the services offered under the Program (“Services” or “Program Services”), you will electronically enter into a written agreement with us (the “Agreement”) that defines the scope of the investment advisory relationship with you and sets forth our obligations to you for the Merrill account that you enroll in the Program (“Account”). This Brochure describes the advisory services that we provide, the fees you will pay, our role and that of our personnel, our other business activities and financial industry affiliations and the economic and other benefits and arrangements we have that create conflicts of interest in certain situations. By accessing the Program Website, you work with our interactive profiling and goal setting process (the “Online Profiling Process”) and a Program Advisor to establish your goal and select an aligned investment strategy available in the Program and receive the Program Services. If you inform us that you wish to terminate an Account’s enrollment in the Program, we will end that investment advisory fiduciary relationship with respect to that Account and will cause that account to be converted to, and designated as, a Merrill brokerage account. Termination of your Agreement will end the investment advisory fiduciary relationship of any Account enrolled in the Program and any such Account will be converted to a brokerage account. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in our Client Relationship Summary on Form CRS (“Form CRS”) and in our Summary of Programs and Services, both of which are available at merrilledge. com/relationships or upon request. In addition, these documents provide a summary of the other available investment advisory programs we offer. Certain aspects of these investment advisory programs are similar to the Program Services. The Program is similar to the Merrill Edge Advisory Account program (“MEAA”) which also provides MEAA-enrolled clients with the ability to work with a Program Advisor. Please refer to “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Under the Program, we are a fiduciary to you. Merrill and MAA each have certain fiduciary obligations in providing the Program Services. As a fiduciary, we will act in your best interest and will endeavor to provide you material facts and information relating to the Program Services. The Brochure is a key element in meeting our disclosure obligations as a fiduciary. The fiduciary standards we aim to follow are established under the Advisers Act and, where applicable, state laws. In addition, for Retirement Accounts, we provide these Program services as a “fiduciary” under Section 3(21) of the Employee Retirement Income Security Act of 1974 (“ERISA”) and under the Internal Revenue Code of 1986 (the “Code”). For Retirement Accounts subject to ERISA, we provide the relevant Program Services as an “investment manager” under Section 3(38) of ERISA. Generally, the Program is designed for clients who are: • Comfortable with online access. • Comfortable accessing a Program Advisor through a call center or in person at certain bank branch locations. • Want to receive the Program Services, including target asset allocation and other ongoing monitoring as described in this Brochure. • Comfortable with the investment choice of a limited set of managed investment strategies complementary to their investment profile. • Willing to pay an asset-based fee for the Program Services, including the investment solutions through managed investment strategies instead of transaction by transaction based fees. The Program is generally not designed for clients who have more complex needs, desire access to a larger offering of investment solutions and strategies or have a preference for frequent in-person interactions with a dedicated financial advisor. Merrill Guided Investing with Advisor Program Brochure | 4 MGI-A 032125Merrill Guided Investing with AdvisorWrap Fee Program Brochure Overview of the Program In the Agreement, we agree to act as your investment adviser and agent and to provide the Program Services described in this Brochure and you grant to us the investment discretion and trading authority necessary to deliver the Program Services you select and agree to the terms and conditions of the Program. For your accounts enrolled in the Program (each, an Account). We will provide you with the Program Services described in this Brochure, including: • Use of the Online Profiling Process, an interactive profiling process on the Program Website that assists in gathering your information. • Personalized investment advice and guidance from Program Advisors and through interaction with the Program Website and its tools and applications. • Access to a select number of managed investment strategies, constructed and implemented by our investment professionals (“Strategies”), which are designed to align with the target asset allocation for your Account. • Ability to set a Goal Target for Growth-Focused goals and use a goal tracking tool on the Program Website. • Ongoing monitoring of the assets in your Account for alignment with the Strategy’s allocation profile as part of our advice and guidance. There is a minimum asset requirement of $20,000 to enroll into the Program. Each Strategy maintains an initial minimum investment amount requirement for an Account which, depending on the Strategy, is either higher or lower than this Program minimum asset requirement. You may use assets in one or more Accounts to meet the Program minimum. We may waive or change these minimums at our discretion. We charge the Program Fee of 0.85% for the Services. The Program Fee per Account you pay is expressed as an annual rate that is prorated for the monthly billing period and is applied to the value of all assets, including cash and cash alternatives, in your Account. Apart from your Account’s initial Program Fee, your Program Fee is payable monthly in advance and generally will be calculated based on the value of the assets in your Account as of the last business day of the prior month. The Program Fee and any other fees payable under the Agreement will be deducted directly from your Account. Information about the Program Fee will be shown in a Program Report that we send to you through the Program Website upon Program enrollment and that we update for important information, including when you make certain changes to your Account. Please review the section “The Program Fee and Other Charges” carefully. By enrolling in the Program and paying the Program Fee, you have access to: • Investment advice and guidance services of a Program Advisor and those Program services delivered through us. • Merrill investment strategies through the Program. • Certain incidental services provided by us through the Program, such as trade execution, custody, performance reporting and related account services. We will execute any transactions in your Account in accordance with our best execution obligations. We supervise the Program Services, our Program Advisors and other personnel responsible for the Program in accordance with our obligations under the Agreement, the Program guidelines that we establish from time to time and the ethical standards we require. There are certain material relationships and conflicts of interest discussed in this Brochure, including in “Item 9 Compensation, Conflicts of Interest and Material Relationships” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest.” Please review these sections carefully before you make a decision to enroll an account in the Program. Details of the Program are provided throughout this Brochure. Merrill Guided Investing with Advisor Program Brochure | 5 MGI-A 032125 Item 4. Services, Fees and Compensation General The Program is designed to help you pursue your investing goals by providing you with the Program Services delivered by us through the Program Website and a Program Advisor, including investment advice, guidance and access to a select set of managed investment strategies (“Strategies”). We make available in the Program a select set of Strategies that are managed by us that consist of diversified portfolios of exchange traded funds (“ETFs”), mutual funds and a cash allocation that are designed to meet a particular Target Asset Allocation. Before investing through the Program, please read the description of our Services and the other information in this Brochure. You may contact us at 888.654.6837 if you have any questions. To take advantage of the Services available through the Program, you must first enter into the Agreement, which will cover an account or accounts that you enroll in the Program (each, an “Account”). In the Agreement, we agree to act as your investment adviser and agent to provide the Program Services described in this Brochure and you grant to us the investment discretion and trading authority necessary to deliver the Services you select and agree to the terms and conditions of the Program. After you are enrolled in the Program, you may be able to select or change certain Services with instructions to us; however, in certain circumstances we may ask you to sign a separate Agreement or complete additional documentation. Electronic Accessibility Requirement. The Program provides you with the Services described in this Brochure electronically through use of the Program Website. In order to enroll in the Program, you must agree during the online account enrollment process to the electronic delivery of documents and information relating to the Program and your Account. You will be required to sign the Agreement and any other agreements necessary to participate in the Program electronically. The Agreement, brochures, supplements, profiles and other disclosures, notices and documents will be delivered to you in electronic format only. We will not send you paper versions of documents as part of the Program unless required by applicable law or in our sole discretion. You are solely responsible for user activity that occurs in your Account and the information provided to us through the Program Website. You are also responsible for maintaining the security and confidentiality of your Account access information. You must notify us immediately if you believe your Account has been accessed in an unauthorized manner or the security and confidentiality of your access information have been compromised. You must provide us with a valid email address as a requirement of Program enrollment and will also be notified via the email address you provided to us when documents are available for viewing in the “Statements and Documents” section of the Program Website. You have an obligation to maintain an accurate and up-to-date email address and to ensure that you have the ability to read, download, print and retain electronic documents. To notify us of any changes to your email address, please update your information via the Program Website or call us at 888.654.6837. Failure to provide accurate contact information could result in termination from the Program. If you are unable or unwilling to accept electronic delivery, your enrollment in the Program may be terminated. For additional details related to electronic communications, please refer to the eCommunications Disclosure in the enrollment documents for the Account available on the Program Website. Advice and Guidance Services Establishing Your Account. You may invest in the Program through a taxable (or non-retirement) account and through a Retirement Account, which is an individual retirement account within the meaning of Section 408(a) of the Code, a simplified employee pension within the meaning of Section 408(k) of the Code, a simple retirement account within the meaning of Section 408(p) of the Code, and a Roth IRA within the meaning of Section 408A of the Code. A Program Advisor, through the Program Website, will help you establish an Account for the assets that you identify. Through the Online Profiling Process and by working with a Program Advisor, you establish a goal and select a recommended target asset allocation and an investment strategy described below for your Account. Through this process, you will be asked to provide us with certain information about your objectives and goal for your Account. Each Account will be tied to a single investing goal that you select and name. The recommendations provided for each Account are intended to align and are limited to the specific investing goal for that Account. Additional investing goals will require that you set up additional Accounts. Through the Program Website and a Program Advisor, we request certain information and ask questions to gather information about you, including important financial and personal information that will be used as the basis for our investment recommendations. It is your responsibility to ensure that the information you provide to us is complete and accurate. When you provide accurate and complete information, we will be better able to make suitable recommendations for your Account assets. It is also your responsibility to notify us if any information you have provided to us about you is inaccurate or becomes inaccurate. If there are multiple owners on this Account, the information you provide should reflect the views and circumstances of all owners or the beneficiaries on the Account. If you are the fiduciary of this Account for the benefit of the account owner or account holder (e.g., the trustee for a trust or custodian for an UTMA), please keep in mind that these assets will be invested for the benefit of such account owner or account holder. If you have changes to the information you provided to us through the Online Profiling Process or to a Program Advisor, you should contact a Program Advisor. If you feel any of the questions through the Online Profiling Process or Program Advisor are unclear or you do not understand why the information is being sought, please contact and/or discuss with the Program Advisor. Be careful when inputting or providing your answers or information. If you enter or provide inaccurate information, the resulting recommendation might not be right for you. The Program incorporates only the financial information you provide, and our investment recommendations are limited to and based only on certain information you provide through the Program Website or to a Program Advisor. We will not independently verify the information you provide through the Program Website and we will not consider other information obtained in connection with another account or relationship with Merrill or its Affiliates other than as described in this Brochure and the Agreement. If you believe there is additional financial information that should be considered to inform the investment recommendations made through the Program, please inform a Program Advisor. You may select between two investing goal types: the Growth-Focused goal type and the Income-Focused goal type. The Growth Focused goal type is designed for general investing, retirement investing and other types of investing goals seeking to grow assets through investing over time for current income and growth (“Growth-Focused Goal”). The Income-Focused goal type is designed for a retirement investing goal seeking to use assets while investing over a defined time period for income (“Income-Focused Goal”). The goal type that you select along with other information about you will help determine the recommended target asset allocation and investment strategies available to you for your particular goal. Merrill Guided Investing with Advisor Program Brochure | 6 MGI-A 032125 As part of establishing the Account with an investing goal, we will recommend an allocation of your assets across one or more asset classes (“Target Asset Allocation”) for your goal and a Strategy designed to align to that Target Asset Allocation and the specific needs of your Account. We make available in the Program a select set of Strategies that are managed by us that consist of diversified portfolios of exchange-traded funds (“ETFs”), mutual funds and a cash allocation that are designed to meet a particular Target Asset Allocation and objective The Account’s cash allocation can be in various amounts for one or more investment and/or operational purposes at the same or different times as described throughout this Brochure. Once your Account is established, we will monitor the assets in your Account for alignment with the Strategy’s allocation as part of our advice and guidance. If appropriate, we will make recommendations regarding changes to your Account, including changes to the Strategy you selected. Investment Advice Services for Accounts Selecting the Growth-Focused Goal Type The Growth-Focused Goal type includes the general investing goal and investing for specific types of goals such as travel, home and education that seek to grow assets through investing over time for current income and growth. The Growth-Focused Goal type also includes investing for retirement for a person who is five or more years away from retiring and who does not intend to use the assets to pay for retirement expenses in the near term. If you’ve already retired and one or more of these scenarios applies, this goal could be appropriate for you if: • You intend to fund most of your retirement expenses through other sources such as Social Security, pension, wages or other savings. • You don’t expect to use most of the assets during retirement. • Your goal is to build your assets. • You expect to leave most of these assets to your heirs rather than spend the funds in retirement. Recommending a Target Asset Allocation for the Growth-Focused Goal Type. As part of establishing the Account, we will recommend a Target Asset Allocation for the Growth-Focused Goal and a Strategy designed to align to that Target Asset Allocation and the specific needs of your Account. We make available a select set of Strategies that are managed by us and are designed for a particular Target Asset Allocation that balance the goals of achieving current income and growth (“Total Return-Focused Strategies”). Once your Account is established, we will monitor the assets in your Account for alignment with the Strategy’s allocation as part of our advice and guidance. If appropriate, we will make recommendations regarding changes to your Account, including changes to the Strategy you selected. Setting the Risk Tolerance and Time Horizon. The Strategy you select will be based on responses and information you provide for your goal, including the risk tolerance for the Account assets (i.e., your tolerance for potential loss of some or all of the assets in your Account in exchange for greater potential returns) and the time horizon (determined by how long you expect to invest to achieve your goal). For a retirement investing goal, the time horizon is based on a combination of your stated retirement age and how long you intend to use the assets in your Account after retirement. The risk tolerance options are low, medium, or high, as described below: • A “low” risk tolerance means your primary concern is preserving your capital. Inflation-adjusted returns may be very low or negative balanced by high liquidity and reduced risk of principal loss. • A “medium” risk tolerance means you’re willing to accept some principal loss while pursuing a higher possible total return. Diversification and asset allocation helps to reduce this level of risk. • A “high” risk tolerance means you’re willing to accept the risk of possible loss of principal because you think that overall portfolio results may provide above average returns. These investors may hold concentrated positions and trade frequently. Results may vary widely from one year to the next in the pursuit of longer-term goals. Option to Set a Goal Target. You also have the option, at your election, through the Online Profiling Process or the Program Website, to state a target goal dollar amount (the “Goal Target”) for the goal aligned with your Account. If you provide a Goal Target, this information will be used in addition to your other information (such as your risk tolerance and time horizon) to recommend the Target Asset Allocation and the aligned Strategy. Depending on the amount of the Goal Target, the recommended Target Asset Allocation and Strategy may be different than the one recommended when no Goal Target is provided. The identification of a Goal Target does not constitute a guarantee by us of the future value of the Account or any specific level of performance or rate of return for the Account or any Target Asset Allocation or Strategy that we recommend or undertake on your behalf. There is no guarantee that you will achieve your Goal Target. If stating a Goal Target, you have the option to align certain other assets not held in your Account (“External Assets”) to your Goal Target for the Account. You can link External Assets maintained in accounts with us or our Affiliates that we determine to be eligible in our sole discretion (“Linked accounts”). You can also enter information about External Assets maintained in accounts at a firm that is not our Affiliate that we determine to be eligible in our sole discretion (“External accounts”). Not all accounts with External Assets are appropriate for you to align to your Goal Target for the Account. Please see the Program Website for additional information. If you choose to align External Assets to an Account’s Goal Target, we will provide advice and manage your Account based, in part, on information available or provided for the dollar value balance and asset allocation of these External Assets. Aligning External Assets to your Account’s goal and Goal Target may produce a different Target Asset Allocation recommendation than if they had not been so aligned. The composition of the External Assets, market volatility and conditions and changes that you may make to your External Asset holdings will have an impact on reaching your Goal Target. We are not an investment adviser with respect to External Assets and do not advise you on External Assets. For Linked accounts, we will periodically review the dollar value balance and asset allocation. For External accounts, it is your responsibility to keep the External Asset information you align to a Goal Target updated. It is important for you initially and on an ongoing basis to update the dollar value balance and to classify the External Assets into the appropriate asset class. If the External Asset information is not accurate and complete, the recommended Target Asset Allocation and Strategy for your Account will be affected. In certain circumstances, you will be contacted to consider how changes to External Asset information might impact the Strategy for your Account. Target Asset Allocation Categories. In general, the Target Asset Allocation categories are: • Conservative: primary focus is on portfolio stability and preservation of capital with the achievement of low or negative investment returns in exchange for reduced risk of loss of principal and liquidity. • Moderately Conservative: primary focus is to achieve a modest level of portfolio appreciation with minimal principal loss and volatility. Merrill Guided Investing with Advisor Program Brochure | 7 MGI-A 032125 • Moderate: primary emphasis is to strike a balance between portfolio stability and portfolio appreciation with the assumption of moderate level of risk and level of volatility and principal loss. • Moderately Aggressive: primary emphasis is on achieving portfolio appreciation over time with the assumption of a fair amount of risk, and high level of volatility and risk of principal loss. • Aggressive: primary emphasis is on achieving above-average portfolio appreciation over time with the assumption of substantial risk and a significant level of portfolio volatility. Each of these categories have associated asset class allocation ranges. The associated allocation ranges and our method of monitoring activity may change from time to time and without prior notice to you. Our more conservative Target Asset Allocations typically recommend a greater percentage of your assets be allocated to fixed-income and cash asset classes, rather than to the equity asset class. Our more aggressive Target Asset Allocations typically recommend a greater percentage of your assets be allocated to the equity asset class, rather than to fixed-income and cash asset classes. You should consider carefully the recommended Target Asset Allocation for your Account. We will use your Target Asset Allocation, along with certain other information provided by you through the Online Profiling Process, to assist in recommending a Strategy for your Account. Any changes to your risk tolerance or time horizon or, if applicable, Goal Target and any aligned External Assets may lead to a different recommended Target Asset Allocation and therefore potential changes to the Strategy recommended for your Account. It is your responsibility to ensure that the information you provide to us through the Online Profiling Process is complete and accurate so that we will be better able to make appropriate recommendations for you and your Account assets. As part of the Program Services, we use wealth management planning tools that provide hypothetical projections of possible investment outcomes for the asset classes included in the recommended Target Asset Allocation based on certain information you provide as part of the Online Profiling Process and through the Program Website for the Account (an “Allocation Profile”). Hypothetical projections and analyses do not reflect or project actual investment performance of your Account, the TEM Overlay Services (if elected) and the Strategy you select or the underlying securities in the Strategy and are not guarantees of future results. Any hypothetical projections presented through the Program Website make use of probabilistic modeling, a statistical modeling technique in which a set of future outcomes are forecasted based on the variability or randomness associated with historical occurrences. For an Account without a Goal Target (as defined below), the projections presented illustrate possible investment outcomes determined by the use of probabilistic modeling based on our forward-looking return assumptions for the asset classes included in the recommended Target Asset Allocation and based on certain information you provided as part of the Online Profiling Process and through the Program Website for an Allocation Profile. For more information about how these projections are calculated, how the information you provide is used, the assumptions used and limitations of these projections, please consult the “Hypothetical Projections Tool” document available on the Program Website. As part of the Program Services, we also use a wealth management tool to provide you with the ability to track your progress to your Goal Target, if desired. No representation is made that the Strategy will achieve the Goal Target and the actual returns for your Account could be significantly higher or lower than the Goal Target. For the purposes of these projections, any External Assets in Linked accounts will have the asset allocation determined by us based upon our asset class designation of the Linked account holdings. External Assets in External accounts will have the asset allocation provided by you through the Program Website and, if you do not provide this information, we will assume these External Assets have the same asset allocation as the Target Asset Allocation for your Account. You should consider these limitations carefully as you review the projections and illustrations for progress to your Goal Target and you should not rely on that information when making an investment decision. For more information about how the projections are calculated, how the information (including information about External Assets) you provide is used, the assumptions used and limitations of the projections, please consult the “Goal Target Funding Status Analysis” document available on the Program Website. Recommending a Strategy for the Growth-Focused Goal Type. After we help you establish a Target Asset Allocation for your Account with a Growth- Focused Goal type, we, through the Online Profiling Process and/or a Program Advisor, will recommend to you one or more Strategies available in the Program. Our advice is based on the information you have provided to us for that Account and is limited by the stated and agreed-upon: (1) size of your investment; (2) Account Target Asset Allocation; (3) Account Strategy; (4) other applicable factors such as the type of Account you establish; and (5) Account investment restrictions, if any, that are accepted as provided in the section “Reasonable Investment Restrictions” below. If you wish to proceed, you will select the recommended Strategy to have implemented in your Account based on the results of the Online Profiling Process and by working with a Program Advisor. If you wish to utilize multiple Strategies for your investment assets in the Program, you will be required to open a separate Account for each Strategy. Total Return-Focused Strategies. We make available a set of Strategies that are designed for a particular Target Asset Allocation and that balance the goals of seeking current income and growth (“Total Return-Focused Strategies”). The Total Return-Focused Strategies available for the Growth-Focused Goal type are model portfolios of primarily of ETFs (but can include mutual funds) and cash and/or cash alternatives (referred to as a cash allocation). The ETFs and mutual funds that are included in a Strategy are referred to as “constituent Funds.” These model portfolios are constructed by Merrill, through the Chief Investment Office (the “CIO”) and seek to achieve one or more investment styles or disciplines. The Strategies range from “Conservative” to “Aggressive” and include asset allocations to the asset classes of equity, fixed income and cash. The CIO chooses the constituent Funds for the equity and fixed income asset class exposures and determines the overall asset class allocations of a Strategy to balance the goals of achieving current income and growth. The CIO constructs, implements and/or manages its respective managed portfolios and determines the asset classes, security holdings and weightings in the Strategy, including any cash allocation. The CIO also selects securities holdings that can be converted to cash without experiencing a significant loss due to the lack of a ready market or incurring significant costs or penalties. For exposure to the cash asset class, the CIO determines whether to hold cash as a cash balance (which is then swept in accordance with the Account’s cash sweep option), and/or to invest in money market mutual funds (“money market funds”). If no action is taken by the CIO to select a money market fund, cash balances will automatically be swept under the Accounts’ cash sweep option. The cash allocation in a Strategy is for operational and implementation and/or investment purposes as directed by the CIO. The cash allocation will be higher at certain times depending on the nature of the Strategy, the asset Merrill Guided Investing with Advisor Program Brochure | 8 MGI-A 032125 allocation, the investment determinations, rebalancings, market conditions and the CIO’s cash management approach and market view and concerns. For more information, see “Item 4 Treatment of Cash Balances in your Account” and “Item 4 Funding and Operation of Accounts-Cash Balances.” Certain Strategies have an investment approach that incorporates two model portfolios from the CIO which are designed to support Accounts at different asset levels. These Strategies’ model portfolios are designed to align to the relevant Target Asset Allocation and provide similar diverse market exposure. Accounts with higher asset values (generally starting at $5,000 or as otherwise reflected in the applicable Strategy Profile) are allocated among a range of constituent Funds and a cash allocation using CIO’s tactical asset allocation model portfolio (“Tactical Asset Allocation”) for a Strategy. Accounts with lower asset values are allocated among generally a smaller range of constituent Funds and a cash allocation using CIO’s strategic asset allocation model portfolio (“Strategic Asset Allocation”) for these Strategies. In our discretion, we rebalance an Account to transition between two model portfolios for these Strategies as its asset value changes over time. As we describe in detail below in “Item 4 Investment and Trading Authority; MAA’s Role,” we will have full trading authority to implement the Strategy selected, including rebalancing to transition an Account between the Strategy’s two model portfolios as the Account’s asset value changes over time. The availability of Strategies in the Program is subject to change. You can review materials available on the Program Website and can discuss the available Strategies with a Program Advisor. We will deliver to you through the Program Website a Program Report (also referred to as a Porfolio Summary) upon enrollment that will indicate the Strategy in which you are invested. We may reference this Strategy or use the term “Managed Strategy” as a caption name or reference in the Program Report. Any changes to a different Strategy for your Account will result in an updated Program Report that will be made available to you through the Program Website. If you wish to proceed, you will select the recommended Strategy to have implemented in your Account based on the results of the Online Profiling Process and discussions with a Program Advisor. Any change from one Strategy to another Strategy will require your consent because you retain authority to select and implement any changes between Strategies. Investment Advice Services for Accounts Selecting the Income-Focused Goal Type As part of establishing the Account, you can select the Income-Focused Goal type for either a taxable Account or a Retirement Account. The Income- Focused Goal type is for a retirement investing goal that seeks to use assets while investing over a defined time period for income and is designed for retirees or those retiring in fewer than five years. In addition, if one or more of these scenarios applies, this goal could be appropriate for you if: • You expect to use the assets for retirement expenses for up to 25 years. • You expect to use most of the assets to generate a steady income during retirement. As part of the Program Services, we will recommend a Target Asset Allocation for the Income-Focused Goal and a Strategy designed to align to that Target Asset Allocation and the specific needs of your Account. We make available a select set of Strategies that consists of ETFs and a cash allocation and that are designed for a particular income-focused Target Asset Allocation seeking to obtain a continuing stream of income from investments and that changes over time, and for recurring Account withdrawals through a stated end year (“Income-Focused Strategies”). Once your Account is established, we will monitor the assets in your Account for alignment with the Strategy’s allocation as part of our advice and guidance. If appropriate, we will make recommendations regarding changes to your Account, including changes to the Strategy you selected. Recommending a Target Asset Allocation for the Income-Focused Goal Type. The Strategy you select will be based on responses and information you provide for your goal, including the risk tolerance for the Account assets (i.e., your willingness and ability to incur financial loss for the assets in your Account in exchange for greater potential returns) and the time horizon (determined by when you would like to start receiving income and for how long you would like to receive income). The risk tolerance options are low, medium, or high, as described below. • A “low” risk tolerance means that you are not willing or able to take much risk for your income needs. You’d like a higher initial income and are willing to accept minimal risk to have lower potential increases to future income and a remaining balance. • A “medium” risk tolerance means that you are willing and able to take a moderate level of risk for your income needs. You’d like a modest initial income and are willing to accept some risk to have more potential for increases to future income and a remaining balance. • A “high” risk tolerance means that you are willing and able to take a higher level of risk for your income needs. You’d like a lower initial income and are willing to accept more risk to have greater potential increases to future income and a remaining balance. The time horizon begins with the age you reach in the year of Account enrollment in the Strategy and, if different, includes the age you reach in the year you want to start to take recurring withdrawals from the Account and ends in the year of your last withdrawal from the Account. At the end of the time horizon, your Account is expected to have no or a relatively low remaining asset balance. Your investment returns and the withdrawal amounts received over the course of your Account’s time horizon are subject to changes due to general economic conditions, general market fluctuations, and the risks inherent in securities markets. There is no guarantee that sufficient income will be achieved to provide adequate income through your stated end year or throughout retirement. The recommendations provided for each Account are intended to align and are limited to the specific Income-Focused Goal for that Account. Additional Income-Focused Goals will require that you set up additional Accounts. In general, the Target Asset Allocation categories, which are designed to seek to obtain a continuing stream of income from investments, are: • Stable Income: a low risk tolerance and target allocation generally to the fixed income asset class. • Balanced Income: a medium risk tolerance and target allocations of a mix of fixed income and equity asset classes that will change over time. • Income and Growth: a high risk tolerance and target allocations of a mix of fixed income and equity asset classes that will change over time. Each of these categories have associated asset class allocation ranges. The associated allocation ranges and our method of monitoring activity may change from time to time and without prior notice to you. Our more conservative Target Asset Allocations typically recommend all or most of your assets be allocated to fixed-income, rather than to the equity asset class. Our more aggressive Target Asset Allocation typically recommend a greater percentage of your assets be allocated to the equity asset class, rather than to fixed-income class. You should consider carefully the recommended Target Asset Allocation for your Account. Merrill Guided Investing with Advisor Program Brochure | 9 MGI-A 032125 We will use your Target Asset Allocation, along with certain other information provided by you through the Online Profiling Process, to assist in recommending a Strategy for your Account. Any changes to your risk tolerance or time horizon may lead to a different recommended Target Asset Allocation and therefore potential changes to the Strategy recommended for your Account. It is your responsibility to ensure that the information you provide to us through the Online Profiling Process is complete and accurate so that we will be better able to make appropriate recommendations for you and your Account assets. As part of the Program Services, we use wealth management planning tools that provide hypothetical projections of investment and income amounts for the asset classes included in the recommended Target Asset Allocation based on your Allocation Profile. Hypothetical projections do not reflect or project actual investment performance of your Account, the investment performance of any assets held by you outside the Account (e.g., Social Security), the Strategy you select or the underlying securities in the Strategy and is not a guarantee of future results, including future income. The hypothetical projections present possible income-focused investment outcomes determined by the use of probabilistic modeling based on our forward-looking return assumptions your Allocation Profile. For more information about how these projections are calculated, how the information you provide is used, the assumptions used and limitations of these projections, please consult the “Hypothetical Income Projections Tool” document available on the Program Website. Recommending a Strategy for the Income-Focused Goal Type. After recommending a Target Asset Allocation for your Account with an Income- Focused Goal Type, we, through the Online Profiling Process and a Program Advisor, will recommend to you one or more Strategies available in the Program. Our advice is based on the information you have provided to us for that Account and is limited by the stated and agreed-upon factors as follows: (1) size of your investment; (2) Account Target Asset Allocation; (3) Account Strategy; (4) other applicable factors such as the type of Account you establish; and (5) Account investment restrictions, if any, that are accepted as provided in the section “Reasonable Investment Restrictions” below. If you wish to proceed, you will select the recommended Strategy to have implemented in your Account based on the results of the Online Profiling Process and by working with a Program Advisor. If you wish to utilize multiple Strategies for your investment assets in the Program, you will be required to open a separate Account for each Strategy. Income-Focused Strategies. We make available a select set of Strategies that are designed for a particular income-focused Target Asset Allocation seeking to obtain a continuing stream of income from investments and that changes over time and for recurring Account withdrawals through a stated end year (“Income-Focused Strategies”). The Income-Focused Strategies available for Income-Focused Goal types are model portfolios constructed by MLPF&S, through its CIO that consist of constituent Funds (primarily ETFs but can include mutual funds) and cash and/or cash alternatives (referred to as a cash allocation). The Income-Focused Strategies range from “Stable Income” to “Income and Growth.” The availability of Strategies in the Program is subject to change. You can review materials for the Income-Focused Strategies on the Program Website. The Program Report that we make available to you through the Program Website will indicate the Strategy in which you are invested. We may reference this Strategy or use the term “Managed Strategy” as a caption name or reference in the Program Report. Any change to a different Strategy for your Account will result in our providing you an updated Program Report through the Program Website. The Strategies include investment allocations to one or both of the fixed income and equity asset classes and a cash allocation. The CIO chooses the constituent Funds for one or both of the equity and fixed income asset class exposures and determines the overall asset class allocations of an Income- Focused Strategy that aim to obtain your hypothetical projected income. The CIO also selects securities holdings that can be converted to cash without experiencing a significant loss due to the lack of a ready market or incurring significant costs or penalties. Your Account’s cash allocation is to support anticipated withdrawals in a particular year based on your Account instructions for a fixed time period of up to 25 years that begins in your designated year and end in a future stated year. You may choose the desired income (or withdrawal) start date up to five years after Account enrollment (the “Accumulation Phase”), after which there will be a “Decumulation Phase” of up to 25 years during which you receive recurring withdrawals. At the end of the fixed time period (based on your time horizon), your Account is expected to have no or a relatively low remaining asset balance. Your investment returns and the withdrawal amounts received over the course of your Account’s time period are subject to changes due to general economic conditions, general market fluctuations, and the risks inherent in securities markets. There is no guarantee that sufficient income will be achieved to provide adequate income through your stated end year or throughout retirement. A portion of the cash allocation is for operational and implementation and/or investment purposes as directed by the CIO. The cash allocation will be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations, rebalancings, market conditions and the CIO’s cash management approach and market view and concerns. For the cash allocation, the CIO determines whether to hold cash as a cash balance (which is then swept in accordance with the Account’s cash sweep option), and/or to invest in money market funds. For more information, see “Treatment of Cash Balances in your Account” and “Item 4 Funding and Operation of Accounts-Cash Balances.” As described in more detail below in “Item 4 The Program Fee and Other Charges,” the cash in the Account will be subject to the Program Fee. Effect of Withdrawal Changes and Withdrawals on an Income-Focused Strategy. You should understand that changes made to the amount of recurring withdrawals and any unscheduled cash withdrawals will result in changes to the amount of recurring withdrawals that you will receive over the term of your Strategy. Choosing an amount of recurring withdrawals that is higher than the hypothetical projections or actual income received or making unscheduled withdrawals will result in lower hypothetical projections in future years and reduce the amount of recurring withdrawals that will be supported over the term of your Strategy. In addition, if the value of your Account drops below the required minimum, due to unscheduled withdrawals or recurring withdrawals that exceed the hypothetical projections, or otherwise, we may determine that the Strategy is no longer appropriate for you and your Account will be subject to termination. You will have the opportunity to monitor hypothetical projections and manage the amount of recurring withdrawals as a part of the annual review, as described in more detail below. Depending on numerous factors, including any unscheduled withdrawals from your Account, if the value of the assets in your Account drops to an amount that is at or below a certain dollar amount, we may be unable to rebalance the investments in your Account to reflect any changes in the Strategy’s allocation. In addition, as your Account approaches its future stated year, it is expected that the portion of your Account comprising the cash allocation will increase relative to the portion comprising ETFs. This may also result in our inability to rebalance the investments in your Account to the Strategy’s allocation. Merrill Guided Investing with Advisor Program Brochure | 10 MGI-A 032125 Annual Review of Withdrawal Amount. Each year your Account is subject to a mandatory annual review of the next year’s withdrawal amount. We require that you complete the annual review when prompted by us within two weeks of receiving a notification. As a part of the annual review, you must confirm certain information regarding your Account, including the amount and frequency of the recurring withdrawals you would like to receive for the next calendar year based on the hypothetical projected income amount. We will provide an updated hypothetical projection of investment and income for the next calendar year and other information relevant to your Strategy. If you do not provide the requested information, we will continue to apply the terms applicable to your Account from the current year. Failure to complete the annual review may result in recurring withdrawals that are inconsistent with the hypothetical projections and this may cause you to withdraw on a recurring basis amounts that are higher than the projections. As discussed above, recurring withdrawals that exceed the hypothetical projections will result in a lower amount of future recurring withdrawals over the term of your Strategy. For additional information on withdrawals, including special processing guidelines, see “Item 4 Funding and Operation of Accounts” at the section “Required Withdrawals for Income-Focused Goals.” Investment and Trading Authority; MAA’s Role Pursuant to an agreement between MLPF&S and MAA, MLPF&S provides advisory services through the Program, in part, by furnishing investment recommendations to MAA for a Strategy based on one or more model portfolios in accordance with the applicable Profile. All Strategies developed by MLPF&S will be implemented by MAA with full investment and trading discretion. MAA will generally implement the CIO’s recommendations for a Strategy without change, subject to your Reasonable Investment Restrictions, cash commitments and other considerations. MAA may determine, in its sole discretion, in light of operational or investment considerations, to deviate from a model portfolio on a limited basis (i.e., to select another security or increase the cash allocation within a model portfolio). By your choosing a Strategy for an Account as provided in the Agreement, you have granted MAA investment and trading discretion for investments occurring in the Strategy. Through that discretion, we will have complete trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets in your Account in accordance with your selected Strategy without any prior notice. This authority will remain in place until we have received and accepted instruction from you to either change the Strategy or terminate the Account. The investment decisions for a Strategy will generally be implemented for your Account by MAA in accordance with the investment recommendations, guidelines and instructions provided to it by the CIO through model portfolios or other instructions. As part of your grant of authority described above, MAA has authority to make certain investment and trading decisions including: • Implementing, as applicable, the model-based recommendations or other investment guidelines and/or instructions of the CIO. • Rebalancing an Account to align with the Tactical Asset Allocation or Strategic Asset Allocation model for a Total-Return Focused Strategy, as applicable, due to a change in the value of the Account. • Processing all contributions, including initial and any subsequent cash deposited in the Account, withdrawal requests and Account terminations. • Processing allocations to cash and/or cash alternatives in amounts needed to meet your instructions for annual withdrawal amounts for an Account with an Income-Focused Goal. • Periodically rebalancing the Account as further described below. • Implementing your Reasonable Investment Restrictions, if any, described in the section “Reasonable Investment Restrictions.” • Implementing your tax-selling instructions (if any) where accepted to MAA, as further described in the section “Tax Matters.” • Implementing tax efficient management overlay services (discussed below in “Optional Account Services for Growth-Focused Goals”), if these services have been selected by you for an eligible Account. Merrill and MAA are authorized and directed by you to sell promptly any investments you contribute that are not eligible or not acceptable for a Program Service or Strategy. MAA actively manages your Account’s investments and may rebalance these investments to the Strategy’s allocations at any time in its sole discretion, including rebalancing to align with the Strategy’s model due to a change in the value of the Account. In light of other considerations in an Account, MAA can effect rebalancing and other transactions even though they may generate tax liabilities, including short-term taxable income. In its discretion, MAA may decide not to process certain rebalancing transactions. Delays in the processing of any rebalancing activities that MAA undertakes can occur from time to time, based on, among other things, market conditions, illiquid securities, as well as the availability of ETFs and mutual funds and other factors. The frequency and parameters MAA uses to rebalance your Account in a selected Strategy may change at any time and may be different from the parameters used in other types of investment strategies or investment advisory programs sponsored by Merrill. MAA arranges for trades to be executed through Merrill or a Merrill Affiliate and may arrange for trades to be executed through a broker or dealer other than Merrill or a Merrill Affiliate (an ”Unaffiliated Trade Counterparty”). In its discretion and subject to legal requirements, MAA may utilize the services of its Affiliates for investment, trading and administrative support. MAA generally takes necessary actions consistent with implementing a Strategy, including for any investments subject to regulatory limitations and restrictions and related internal policies applicable to us and our Affiliates’ overall investment activities described further in the section “Activity by Merrill, Affiliates and Personnel.” Reasonable Investment Restrictions You may request through your Program Advisor or through the Program Website, that we impose certain investment restrictions on the management of your assets in your Account relating to the purchase of specific constituent Funds. For a restriction to be acceptable under the Program, it must first be determined to be “reasonable” by us (a “Reasonable Investment Restriction”). You may request to have different investment restrictions applied to each of your Accounts. If accepted, the Reasonable Investment Restriction that MAA is responsible for managing or implementing in your Account will be included in a periodic Program report or other communications and on the Program Website, and will be applied to your Account until; (1) you take action to change, withdraw or waive the restriction; (2) we determine that it is no longer a Reasonable Investment Restriction based on factors we deem relevant in our discretion, including for example, the level of the security holding percentage in the Strategy; or (3) we are no longer able to implement the restriction in our systems due to changes in the security identifier or symbol, corporate action events, or otherwise. Merrill Guided Investing with Advisor Program Brochure | 11 MGI-A 032125 Please note that investment restrictions will not apply to securities or other interests in individual companies held in the portfolio of any constituent Fund held in your Account. We reserve the right to modify our practices regarding investment restrictions in our sole discretion at any time without notice. Further, we reserve the right to deem any requested investment restriction to be unreasonable and to not accept the requested investment restriction. If one or more investment restrictions are determined to be unreasonable, the restriction will not be applied and you should consider whether to remain in the Program or consider other more appropriate Strategies in the Program. The termination of an Account from the Program will discontinue the application of the Reasonable Investment Restrictions for that account as a brokerage account or other account no longer enrolled in the Program. If you elect to impose Reasonable Investment Restrictions, you accept any effect that such Reasonable Investment Restrictions may have on the investment performance and diversification of your Account. The performance of an Account with a Reasonable Investment Restriction will differ from, and may be lower than the performance of, an Account without such Restriction. In addition, your decision to impose a Reasonable Investment Restriction that alters the allocation of any Strategy and/or that results in a replacement Fund exposes your Account to additional (and potentially unforeseeable) risks that are inconsistent with the objective of your Strategy. Implementing certain Reasonable Investment Restrictions result in Funds in your Account being sold which could result in taxable events. MAA will determine whether a restriction request is reasonable and how to allocate investments based on an accepted Reasonable Investment Restriction. MAA will allocate the assets that would have been invested in the particular constituent Fund included in the Strategy impacted by the Reasonable Investment Restriction in the following ways: (1) pro-rata across other Strategy investments held in the Account; (2) by using one or more replacement Funds; and/or (3) by remaining uninvested in cash. Available Strategies, Profiles and Prospectus Delivery Merrill determines the manner and extent to which Strategies are made available to clients through the Program and when a Strategy may change or no longer be offered. As a general matter, we make these decisions based on a variety of factors, including client needs, available investment styles, platform capacity, client demand and the outcome of due diligence and evaluation reviews including with the assistance of the CIO. Merrill, through the CIO, also selects the constituent Funds in the Strategies and can change constituent Funds without notice to you. See “Item 6 Portfolio Manager Selection and Evaluation.” Where Merrill determines to close a Strategy to new investments and/or additional contributions, Merrill may replace the identified Strategy with another Strategy selected by us, maintain current positions in the identified Strategy and invest any new contributions and sale or redemption proceeds in a replacement Strategy selected by us, maintain in cash any new contributions or sale or redemption proceeds relating to the identified Strategy in cash until a replacement is chosen by us or you direct us to invest in an alternative Strategy. If we determine to replace the identified Strategy, we will endeavor to choose a replacement with an investment objective that is consistent with the identified Strategy. This replacement Strategy may include constituent Funds with higher expenses than you had been paying. If you do not instruct us to the contrary, your continued participation in the Program after receiving notice of such replacement or other action will be considered your consent to the action. If you do not agree with the replacement Strategy, you can terminate the Account from the Program. We generally will provide you with notice of any discontinuation, closing or replacement event respecting the particular Strategy prior to it taking place. We, however, may provide you with notice after we have already taken action. This flexibility to act quickly helps enable us to take action where we believe the replacement and its timing are in clients’ best interest. MAA is responsible for implementing our decisions and related actions. The Profile for the Strategy will describe the relevant objectives, styles and risks of the particular Strategy. It will also describe the roles of the CIO and MAA in implementing the Strategy. The Profile includes performance history and data as indicated in the Profile. It generally will include actual composite performance data developed by MAA in its implementation of the Strategy. When a fund that is registered under the Investment Company Act (a “Registered Fund”) is purchased for an Account in a Strategy, in light of the discretionary authority you have granted to us in connection with managing your Account, we are authorized to receive the Registered Fund prospectus in lieu of it being automatically delivered to you. If you would like a copy of the Registered Fund prospectus, you may obtain one, free of charge, by contacting us at 888.654.6837 or via the Program Website. Notwithstanding the foregoing, Merrill may continue to send the Registered Fund prospectus to you in its sole discretion. Program Guidelines We have established certain guidelines relating to the management of assets in the Program. The Program guidelines change at our discretion or can be waived under certain circumstances for certain clients. In certain situations, you may be notified if your investment activity or holdings deviate from our Program Guidelines, including Target Asset Allocation guidelines, and will be requested to take certain actions to comply with these guidelines. If you decide not to take the requested action, we have the right to terminate your Account from the Program which converts the Account to a brokerage account. The Strategy chosen for your Account and the assets comprising the Strategy in the aggregate are designed to align to the designated Target Asset Allocation and objective for the Account. On the Program Website you will be able to view the actual asset allocation for your Account (“Actual Asset Allocation”) and compare it to the Target Asset Allocation for your Account. At times, your Account’s Actual Asset Allocation may become misaligned with the Strategy allocation for many reasons, such as market movement, additions and withdrawals of assets from your Account, changes in the Strategy you select or purchases and sales of certain securities in your Account. On a periodic basis, we will monitor the assets in the Account to the applicable Target Asset Allocation within certain parameters. Because your Account’s Target Asset Allocation is based on your Account risk tolerance, your Account time horizon and, if applicable, a Goal Target and any aligned External Assets, changes to these factors may result in a different recommended Target Asset Allocation and/or Strategy. In addition, keep in mind that the time horizon for your Account will change (become smaller) as time passes, and the Target Asset Allocation will change over time (except if your Account already has a recommended Target Asset Allocation of Conservative). If, as a result of the passage of time, your Account’s recommended Target Asset Allocation changes, you will be presented with a new recommended Strategy, if applicable, for selection. With the selection of a new Strategy, certain securities held in your Merrill Guided Investing with Advisor Program Brochure | 12 MGI-A 032125 Account will be sold that may result in taxable gains or losses or fees or charges (if applicable) for your Account. If there is a prolonged misalignment, we will ask you to take action in order to remain in the Program, including updating your risk tolerance or time horizon, so that the Account meets the Program guidelines. Our supervision and monitoring do not substitute for your own continued review of your assets and the performance of your investments in your Account. You are responsible for reviewing the Program communications, including performance reports, trade confirmations and periodic account statements we send to you via the Program Website. If you identify any discrepancies or inaccurate information, you should promptly let us know by contacting us at 888.654.6837. Treatment of Cash Balances in your Account While enrolled in the Program, your Account will have an allocation to cash balances. This allocation results from the CIO’s decision as the investment manager of the Strategy selected for your Account, to keep a cash balance for operational and/or investment purposes as part of the investment strategy. The cash allocation for the Strategy is based on a number of factors, including the nature of the investment strategy being implemented, the types of investments being purchased for the strategy and the circumstances relating to the trading for those securities, market conditions as well as for trade execution facilitation, meeting operational contingencies and having funds available to pay the monthly fee charged for Program Services without generating trade activity in the Account. In certain circumstances, including periods of volatile or uncertain market conditions, any cash allocation may comprise all or a substantial portion of your Account assets based on, for example, concerns about the market or a decision to pursue a defensive investment strategy. Your Account’s uninvested cash balance is automatically swept with your consent to a cash sweep option for your Account under the terms of your underlying brokerage account agreement (the “Cash Sweep Program”). The automatic cash sweep option currently available for Merrill account types eligible for enrollment in the Program are the Merrill Lynch Bank Deposit Program (the “MLBD Program”) and, for retirement accounts, the Retirement Asset Savings Program (“RASP”). These programs provide for an automatic sweep of cash balances to bank deposits with BANA and other banks affiliated with us (“Bank Affiliates”). Please note that the available automatic cash sweep options under the Cash Sweep Program vary based on the Merrill account type and other criteria. Not all Merrill account types have the same cash sweep option. Please refer to your account agreement and related disclosures for additional information regarding the automatic sweep options for your type of account. The Sweep Program Guide for Merrill Clients, which can be found on mymerrill.com, provides an overview of the automatic cash sweep options and how they work and a chart of automatic cash sweep options by Merrill account type. The current rates and yields for the cash sweep options are available at mymerrill.com and from a Program Advisor. Your cash balance, like other investments, is subject to the Program Fee. As described earlier in this Brochure, any cash balances held as part of your Account assets can be invested as directed by the CIO in cash alternatives, including money market mutual funds, available through the Program. We discuss the treatment of cash balances and other considerations relating to cash in various parts of this Brochure, including: (1) Item 4 at the sections “Brokerage, Banking-Related and Custodial Arrangements and Services-Cash Sweep Program and Other Banking-Related Services,” “The Program Fee and other Charges-Determination of how the Program Fee is Charged,” and “Funding and Operation of Accounts-Cash Balances and (2) Item 9 at the sections “Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Account Reviews and Information An important part of the Program is providing you with the opportunity to engage in periodic reviews with a Program Advisor. These reviews provide updates on the progress of your Accounts and other important information about your investments. A periodic review of a Program Account should typically occur on an annual basis; however, we have the ability under our Program guidelines to extend or defer the timing of the review under certain circumstances and for certain periods of time. If you do not participate in your Account review, we may, in our discretion, terminate your Account from the Program. For more information about our communications and reporting to you, see “Item 9 Account Reviews and Reporting.” As an accommodation to you, we may agree, in our sole discretion, to include, in certain of our Program communications and reports, information about External Assets that you have provided to us in connection with your Goal Target. The Program Fee will not apply to these External Assets. Brokerage, Banking-Related and Custodial Arrangements and Services General. You are required to open a brokerage account with MLPF&S. The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance for your Account and access to Strategies and ongoing monitoring. The Program Fee you pay covers these Program Services and your payment for the trade execution, clearance and settlement services provided by Merrill and MAA. It also covers custody of assets. Note that certain fees unrelated to investment activity, like fees for banking related or cash transfer activities, wire transfer fees, foreign currency wire and conversion fees, account service fees, transaction fees and certain transactional costs, are not covered by the Program Fee, including those described in “Item 4 The Program Fee and Other Charges.” In addition, your brokerage account agreement and documents will provide you with information about certain brokerage services and related transaction and account fees for your Merrill account. Brokerage Trading Services Generally. In effecting transactions for your assets in the Program, Merrill and its Affiliates will be acting exclusively as a broker-dealer and can arrange for trades to be executed through Merrill or a Merrill Affiliate or through an Unaffiliated Trade Counterparty. If we or one of our Affiliates effect the transaction through an Unaffiliated Trade Counterparty, we will take into account various factors, such as the nature and quantity of the securities involved, the markets involved, the reputation and perceived soundness of the firm, the firm’s clearance and settlement capabilities and other factors relevant to the selection of a broker-dealer for the execution of client securities transactions. Trades will be handled by MLPF&S consistent with best execution and other regulatory obligations. Even in meeting these obligations, it is possible that you may be able to obtain better prices for transactions if such trades were executed with other broker-dealers or third parties, including having smaller spreads (the difference between the bid and the offer price) or at more favorable net prices. Merrill Guided Investing with Advisor Program Brochure | 13 MGI-A 032125 Merrill seeks to effect transactions correctly, promptly and in the best interests of clients. In the event an error occurs in our handling of client transactions, it seeks to identify and correct it as promptly as possible without disadvantaging you. Depending on the circumstances, corrective actions may include canceling a trade, adjusting an allocation, and/or reimbursing you. In general, in instances where Merrill is responsible for effecting the transaction, we may reimburse you for any losses directly resulting from trade errors, credit to you any profits directly resulting from such trade errors that are corrected after the settlement of the transaction or retain for ourselves any profits directly resulting from such trade errors that are corrected prior to the settlement of the transaction. We may, but are not required to, aggregate orders for the sale or purchase of securities for your Account with orders for the same securities for our other clients, for our own accounts or the accounts of our employees (including any Program Advisor) and/or Affiliates, without your prior authorization. In such cases, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro rata shares of any fees. MAA’s ability to implement the recommendations of the CIO as to a particular Strategy may be affected by the liquidity of the security, market volatility, and any price limits that may be imposed. This may in turn have a negative impact on the performance of a Strategy. In your Agreement, you appoint us to act as your agent and attorney-in-fact with power and authority to buy, sell or otherwise effect transactions in constituent Funds as part of the Strategy and any other securities or other property in your name for your Account. You also authorize and direct us to cause all transactions to be effected through MLPF&S or its Affiliates acting as agent or, where permitted by law, as principal. Principal transactions are only effected in accordance with Program guidelines and applicable regulations. You, and not we, will bear the cost of any fees that are not covered by the Program Fee and that are payable to Unaffiliated Trade Counterparties (including on fixed income or over-the-counter transactions in which Merrill and its Affiliates act as agent). Rules for Cash Accounts and Margin Transactions. As a broker-dealer, Merrill is responsible for compliance with federal margin rules. Accounts in the Program are set up only as cash Accounts. This account notation means that margin is not permitted, and purchases of securities must be fully paid for on the date of the trade. With a cash Account, if securities are sold before the payment for their purchase has settled, an event known as a “free- riding violation” has occurred. Free-riding is prohibited under margin rules and our Program guidelines. Having a “free-riding” violation may result in your Account being restricted for 90 days or “frozen.” The imposition of such a freeze could have a negative effect on your Account and performance. The risk of engaging in an inadvertent “free riding” violation and therefore freezing of your Account is enhanced: (1) when you change Strategies and reconstitute your investments or (2) when you withdraw cash from your Account when there is a pending order to purchase a security. Certain of your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through certain Affiliated loan programs (i.e., the Loan Management Account® and Mortgage 100®/Parent Power® mortgage programs) or through unaffiliated loan programs (together, the “Lending Programs”). The costs, risks and other features and conditions of a loan under the Affiliated Lending Programs are more fully described in the separate lending documentation you receive in connection with any such loan and are not described in this Brochure. There are risks, costs, and conflicts of interests associated with Lending Programs. The costs, including interest, associated with a loan through any Affiliated Lending Program are not included in the Program Fee and will result in additional compensation to us, our Affiliates, and our financial advisors. The interest charges on any such loan combined with the fees charged for Program Services may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. See ”Item 6 Investment Strategies and Risk of Loss-Securities-based Lending with your Account” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Participation in Affiliate Lending Programs and Margin.” Cash Sweep Program and Other Banking-Related Services. As provided in the relevant brokerage account agreement and documents you executed to open your account, unless you elected the “No Sweep” option, you have consented to having cash held in your account being treated as a cash balance and being automatically “swept” on the day following the cash deposit to the cash sweep option applicable to your underlying brokerage account under the Cash Sweep Program. The only automatic cash sweep option currently available for Merrill account types eligible for enrollment in the Program is the MLBD Program or the RASP (for retirement accounts), which provides for an automatic sweep of cash balances to bank deposits with our Bank Affiliates. For Strategies, unless the cash allocation is invested in a constituent Fund as directed by the CIO, the cash allocation will be treated as a cash balance in the Program Account subject to the automatic sweep functionality. Under the MLBD Program or RASP, an Account’s cash balance is swept to accounts held at our Bank Affiliates. Under each of these programs, Merrill as your agent establishes the bank deposit accounts on your behalf at the Bank Affiliate as provided for in your underlying brokerage account agreements. Bank deposits in the MLBD Program and RASP are insured by the Federal Deposit Insurance Corporation (“FDIC”). Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Certain conditions must be satisfied for deposit insurance coverage to apply when bank deposits are opened on your behalf in the name of Merrill as your agent. Merrill has in place business requirements and practices that are reasonably designed to satisfy those conditions, which include, but are not limited to, proper account titling and recordkeeping. The sweep deposit accounts at the Bank Affiliates are protected by FDIC insurance up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership category, per bank. FDIC insurance covers both principal and credited interest, up to applicable limits. Any deposits maintained with a Bank Affiliate in the same account ownership category, whether directly, through other Merrill accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If your total cash balances held at a Bank Affiliate in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of bank product exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Neither Merrill nor the Bank Affiliates manage or monitor the deposits swept under the MLBD Program or RASP for FDIC insurance limit purposes. Deposits are not aggregated or limited under the MLBD Program and/or RASP based on the FDIC limits for the same depositor in the same bank across Merrill accounts. Merrill does not undertake through the Program or the Agreement or the underlying brokerage agreement to provide you notice that cash balances in your Account or Accounts or in any of your brokerage accounts exceeds the FDIC coverage limit for any of our Bank Affiliates. Monitoring FDIC insurance coverage limits is expressly not a Program Service. You are responsible for monitoring the total amount of deposits held at the Bank Affiliates in order to determine the extent of FDIC insurance. The agreements and disclosures that you received in connection with establishing your underlying Merrill brokerage account and the Sweep Program Guide for Merrill Clients include additional information about FDIC insurance. A paper copy can be obtained from your Program Advisor. For additional information on FDIC insurance, visit fdic.gov. Merrill Guided Investing with Advisor Program Brochure | 14 MGI-A 032125 Cash balances swept under the Cash Sweep Program to a bank deposit account of our Bank Affiliates will bear a rate of interest that has been established for, and in light of the features of, the MLBD Program and RASP. The rate of interest for such deposit accounts will be periodically set and reset by the Bank Affiliates in their discretion. The rate is variable and may change at any time after the account is opened without notice or limit. Under the MLBD Program and RASP, interest rates are tiered based upon a client’s relationship with Merrill. Accounts with the MLBD Program and RASP as their Cash Sweep Program that are enrolled in the Program and in specified Merrill investment advisory programs receive the highest tier rate available under the Cash Sweep Program. The current rates and yields for the cash sweep options are available at mymerrill.com and from us. A brokerage account with cash swept into MLBD Program or RASP that enrolls in the Program will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. Please note that the interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. Certain account types have the option to select the “No Sweep” option under their underlying brokerage agreement which results in cash being held in the account as a cash balance and not ‘swept’ to any available sweep option under the Cash Sweep Program. The cash balance will not earn interest or dividends. The cash held in the Account will be covered by the Securities Investor Protection Corporation (“SIPC”) up to $500,000 per client, inclusive of $250,000 for cash. As a registered broker-dealer, Merrill benefits from the possession or use of cash balances, also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. The CIO determines whether to hold a cash balance and/or invest in a money market fund or other cash alternatives available for your Account through the Program. If no action is taken by the CIO to select a cash alternative, cash balances will automatically be swept under the Cash Sweep Program. There are conflicts of interest associated with the Cash Sweep Program which are discussed in “Item 9 Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest—Cash Balances and Cash Sweep Program.” Custodial Arrangements and Services. MLPF&S will act as the custodian for the assets held in the Program. Your assets will be maintained in an account established at MLPF&S through the applicable securities (brokerage) account you have opened. Any assets held in the Program in Retirement Accounts must be and remain free from any lien, charge or other encumbrance. Any assets held in the Program in Accounts other than Retirement Accounts must be and remain free from any lien, charge or other encumbrance (other than a lien, charge or other encumbrance in favor of us or our Affiliates), unless we agree otherwise or it is a lien, charge or other encumbrance in favor of us or our Affiliates through our securities account agreements. You must notify us in writing prior to effecting loans secured by securities in the Program (including loans by our Affiliates) (commonly referred to as “collateralizing”). No specific securities in your Account should be held as collateral to secure any loans you may have. We will not provide advice on or oversee any of your collateral arrangements. Unless we otherwise agree, the terms of the Agreement will prevail in the event of any conflict between the terms of the Agreement and your collateral arrangements. You must also disclose to any lender the terms of the Agreement. There are adverse effects of collateralizing your Account, including, but not limited to, the fact that the lending institution may require additional collateral or liquidation of securities to meet a call, as well as the related tax consequences. You must promptly notify us of any default or similar event under your collateral arrangements as defined in the respective collateral arrangements. From time to time, Merrill may offer to clients or potential clients certain promotions or rewards in connection with opening, maintaining or adding assets to a Merrill securities account. Such promotions or rewards may include, by way of example, the payment of a cash reward. The promotions may require a client to request to receive or participate in the promotion or reward, and/or require a client to meet various eligibility criteria. While these promotions or rewards may extend to a client’s Merrill securities account that holds assets in the Program, participation in the Program is not a condition for these promotions or rewards. Account Features Proxy Voting. You have the right to vote proxies for securities held in your Account. You will retain proxy voting authority for your Account. You cannot delegate to us and we do not accept or assume any proxy voting authority for securities held in your Account. We will promptly send you proxy ballots and related shareholder communications that we receive, as well as any other information intended for distribution to you. You are responsible for taking any actions. If Merrill, as custodian of your Account, does not receive voting instructions from you, we will comply with the rules of the SEC and applicable self- regulatory organizations relating to such matters, as required by law. As a broker dealer, Merrill uses a third-party service provider for certain proxy-related functions, including processing and forwarding proxy and other issuer related materials, and receives amounts collected by the vendor for the costs of these services as permitted by applicable securities regulations. Trade Confirmation Statements. You will receive trade-by-trade confirmation statements electronically for transactions in your Account. Electronic Delivery Service. By enrolling in the Program and signing the Agreement and consenting to electronic delivery, you have agreed to electronic delivery of Program materials, including this Brochure and the Agreement and any changes, supplements or amendments to these materials as well as other Program notices and materials. We will not send you paper versions of documents as part of the Program unless required by applicable law or in our sole discretion. Please see “Item 4 Electronic Accessibility Requirement.” Certain of our materials, including this Brochure, are compatible with various types of assistive devices, such as screen readers. Other Program materials have varying degrees of compatibility with different assistive devices. If you experience difficulty in accessing a Program document with an assistive device, please inform a Program Advisor and request that the document be made accessible. Optional Account Services for Growth-Focused Goals We offer you the ability to elect certain optional Services for an Account. Neither Merrill, nor our Affiliates, employees, or agents will be liable for any loss or expense that may result from your use of any of these optional Services except as otherwise provided in the Agreement. There may be current tax consequences with any transaction occurring under these optional Services. We do not provide tax, accounting or legal advice and you should review any planned financial transactions or arrangements with your professional tax or legal advisors for these matters. Merrill Guided Investing with Advisor Program Brochure | 15 MGI-A 032125 MAA Tax Efficient Management Overlay Services. Through the Program Website and a Program Advisor, you can elect tax efficient management overlay services from MAA (the “TEM Overlay Services”) for a taxable Account with a Growth-Focused Goal enrolled in the Program. TEM Overlay Services will only apply to eligible securities within the Account for which it was selected and therefore may not apply to all securities in the Account. The TEM Overlay Services are not available to you for an Account with an Income-Focused Goal or for a Retirement Account. TEM Overlay Services seek to help manage your electing Account’s investment and trading activity in a Total Return Strategy in a more tax-efficient manner as considered under U.S. tax rules and regulations. Through rules-based rebalancing, portfolio management and loss harvesting approaches, the TEM Overlay Services generally try to increase post-tax value for the electing Account by seeking to: • opportunistically sell securities that have a loss and invest proceeds in the underlying Total Return Strategy-aligned replacement securities for at least 30 days. • engage in tax lot management by prioritizing sales of securities that result in the lowest tax cost, as circumstances warrant. • defer short-term gains by restricting sales of short-term tax lots if the tax lot holding period will go long-term within 31 days or less. • engage in tax efficient management by realigning the Account’s portfolio to the underlying Total Return Strategy weights and giving a sell preference to depreciated securities. • overweight gains and underweight losses by not selling appreciated securities and selling depreciated securities relative to the underlying Total Return Strategy, as circumstances warrant. • avoid wash sales. The available TEM Overlay Services are tax efficient rebalancing and, depending upon your Account’s underlying Total Return Strategy, either dynamic tax loss harvesting or quarterly loss harvesting. Your Account’s Total Return Strategy determines the eligible TEM Overlay Services for the Account and that will be presented to you through the Program Website as part of considering the TEM Overlay Services. These TEM Overlay Services are described in greater detail in the respective term sheets and other materials available through the Program Website. Through the Program Website and a Program Advisor, you can elect the TEM Overlay Services for the eligible Account and authorize MAA to effect the TEM Overlay Services and the related securities transactions on an ongoing basis without making any additional contact with you. This authority will continue in effect until you change or cancel the TEM Overlay Services for the associated Account (which you may do at any time) or terminate the associated Account from the Program. As part of this election through the Program Website, you also acknowledge the risks and limitations associated with the TEM Overlay Services, which are summarized on the Program Website and described in other disclosures provided to you in connection with the TEM Overlay Services election, as well as in this Brochure in the sections “Item 4 Tax Matters” and “Item 6 Particular Risks Regarding the TEM Overlay Services.” The TEM Overlay Services will only take into consideration the trading activity that occurs in that electing Account. If there are any Reasonable Investment Restrictions in place for the electing Account, MAA will seek to take those investment restrictions into consideration when applying the TEM Overlay Services and identifying appropriate replacement securities (if any). MAA may make available additional TEM Overlay Services from time to time. There is no separate or additional fee that is charged by Merrill or MAA for providing the TEM Overlay Services to an eligible Account. MAA reserves the right to charge a fee for TEM Overlay Services upon prior written notice. Automatic Withdrawal Service for Growth-Focused Goals Through the Program Website, you may enroll at no additional cost in the Automatic Withdrawal Service available from Merrill as custodian of your Account. Through this service, you request scheduled withdrawals from your Account to an eligible account designated by you. By doing so, you authorize and instruct us to effect the chosen scheduled withdrawals and any related securities transactions for the withdrawals on an ongoing basis without making any additional contact with you. Your instructions will continue in effect until you change or cancel your instructions, your instructions expire by their stated terms, your Account is approaching and/or reaches the required minimum or your Account is terminated. Information relating to your schedule of automatic withdrawals will be displayed on the Program Website. You can change or cancel your scheduled instructions at any time. You should carefully review and understand the terms of Automatic Withdrawal Service on the Program Website and how the service affects your Account before enrolling. We may terminate the offering of this service at any time upon prior notice to you. We will attempt to process all withdrawal requests in a prompt manner. If your withdrawal request requires the liquidation of any securities, it may take up to 10 business days to process. Frequent withdrawals may affect the performance, asset allocation and achievement of your investment goal for your Account. Except as otherwise provided in the Agreement, none of Merrill, MAA, their Affiliates, employees, or agents will be liable for any loss or expense that may result from your use of any of this service. There may be current tax consequences with any transaction occurring under this service. Having an account (including your Account) with the Automatic Withdrawal Service may affect your Account that elects the TEM Overlay Services. We do not provide tax, accounting or legal advice and you should review any planned financial transactions or arrangements with your professional tax or legal advisors for these matters. See “Item 4 Tax Matters.” The Program Fee and Other Charges The Program Fee Rate. You agree to pay to us an annual asset-based fee (the “Program Fee”) at the rate of 0.85% (the “Program Fee Rate”) of the asset value of the Account for the Services provided in the Program under the Agreement. This Program Fee Rate is non-negotiable and payable monthly in advance. The Program Fee is subject to change from time to time, upon notice to you. Your continued use of our Services will constitute your agreement to any such change. Upon your request, and at no charge, you may contact us by telephone at 888.654.6837 to request information regarding your Program Fee and its calculation. The Program Fee does not include all of the charges that may apply to your Account. Please see the section “Fees and Expenses Not Covered by the Program Fee” for a list of other fees and expenses that you may be charged and that are not included in the Program Fee. You may be eligible for benefits such as Program Fee discounts, rebates or credits under certain promotional programs (“Bank programs”) that BANA offers from time to time for its banking product clients who also use the products or services of its Affiliates, including Merrill. In general, you must be a banking client of BANA, elect to participate in these Bank programs and meet certain eligibility criteria of the Bank programs in order to receive the benefits available to clients of Merrill under these Bank programs. For additional information on these Bank programs, please contact us at 888.654.6837 or visit the Program Website. Merrill Guided Investing with Advisor Program Brochure | 16 MGI-A 032125 The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance. The Program Fee you pay covers the Program’s Services, including investment advice and guidance under the Program, as well as brokerage and custodial services relating to your Account. Certain services that may normally be available in certain types of brokerage accounts will not be available to your Account while you are enrolled in the Program, including margin lending, check writing, Visa cards, and client order entry. The full amount of the Program Fee payable under the Agreement will be charged in accordance with the terms of the Agreement, regardless of the amount of transactions effected in your Account. We offer similar programs and/or investment strategies in different sales channels and at different fee levels. The Program Fee may be higher or lower than the fees for another investment advisory program and/or the cost of similar services offered through other financial firms. See “Ability to Obtain Certain Services Separately and for Different Fees” in this Item 4. Calculation and Payment of the Program Fee. Your Program Fee is payable monthly in advance and generally will be calculated based on the value of the assets in your Account as of the last business day of the prior month. In certain instances, and in our sole discretion, we can fully or partially waive or reduce your Account’s Program Fee for a particular month or as part of promotional activities. From time to time, Merrill may offer to clients or potential clients certain promotions in connection with newly enrolling an account in the Program. Such promotions can include, by way of example, the waiver of the Program fee for a time period. The promotions could require a client to request to receive or participate in the promotion, and/or require a client to meet eligibility criteria. For additional information on any current promotions relating to a Program Fee waiver, please contact a Program Advisor. When you enroll a new Account in the Program, an initial Program Fee will be assessed during the week following the date on which you have contributed the required minimum level of assets to the Account for the Strategy you select. The initial Program Fee will be calculated and paid to Merrill based on: (1) the market value of the assets in your Account as of the earlier to occur of the last business day of the week or the last business day of the month following required funding; and (2) one-twelfth of the annual Program Fee Rate applicable to such market value and prorated based on the number of days remaining in the month from the date of required funding. After the initial Program Fee, the monthly Program Fee is typically charged to your Account during the first week of the current calendar month. The Program Fee will be calculated and paid to Merrill based on: (1) the value of the assets in your Account as of the last business day of the previous calendar month; and (2) one-twelfth of the annual Program Fee Rate applicable to such value. If you or we terminate your Account, we will refund to you a pro rata portion of the Program Fee based on the number of calendar days remaining in the month. The refund, if any, will be applied to your Account typically during the week following Account termination. See “Item 4 Funding and Operation of Accounts—Termination of Enrollment in the Program” for further information. Deduction of the Program Fee from Your Account. You have agreed in the Agreement as follows: • Unless otherwise agreed to between you and Merrill in writing, the Program Fee and any other fees payable under the Agreement will be deducted directly from your Account. • Merrill is authorized to deduct the Program Fee (and any other fees payable) from the assets held in your Account, to the extent permitted by law, if full payment of such Fees has not been timely received or, if earlier, at the time the Account is terminated. • The Program Fee and any other fees for your Account will be payable, unless otherwise indicated, first from the withdrawal by Merrill of balances in the bank deposit account, as you authorize in the Agreement or other document, and second from free credit or cash balances, if any, in your Account. You will make timely payment of all amounts due to Merrill under the Agreement, and any unpaid Program Fees may result in the termination of your Account. • Unless this is a Retirement Account, all assets in your Account or otherwise held by Merrill or its Affiliates for you will be subject to a lien for the discharge of your obligation to make timely payment to Merrill of the Program Fee to the extent permitted by law (and any other fees payable under the Agreement), and Merrill will sell assets in your Account to satisfy this lien. • You can instruct us to deduct the Program Fee from an alternate account with us. If you wish to instruct us to collect the Program Fee from an alternate account, please download the form and instructions for selecting an alternate account at merrilledge.com/AltDebitForm. • If free credit or cash balances within the alternate account you have designated for your Program Fee to be deducted from are not available, the Program Fee will be deducted from your Account. Determination of how the Program Fee Is Charged. Except as noted, you will be charged the Program Fee on all assets in your Account, including cash and cash alternatives. Generally, all Account values used to determine the Program Fee are based on the value of the assets in your Account, as determined by Merrill. In calculating such Account values, we will use a variety of pricing sources, including our Affiliates. The Program Fee will apply to any cash and any cash alternatives held within your Account, including any cash and any cash alternatives held as part of the Income-Focused Strategies. This includes (1) money market funds and other cash alternatives held as part of the Strategy; (2) cash that is treated as a cash balance which is automatically swept into a cash sweep option applicable to your Account in accordance with the Cash Sweep Program; and (3) cash in your Account due to your having chosen the “No Sweep” option as provided for in the Merrill brokerage account agreement. The Program Fee is in addition to other compensation that we and our Affiliates will earn on cash and cash alternatives held in your Account, including a cash allocation for an Account with an Income-Focused Goal. Depending on interest rates and other market factors, the yield that you earn on cash balances and cash alternatives has been, and can be in the future, lower than the Program Fee that you may pay on assets held in your Account. As a result, depending on the interest rate environment, you may experience a negative overall investment return with respect to cash and cash alternatives and, in some situations, the effective return on cash held in a bank deposit account can be negative. For more information about the Cash Sweep Program, including compensation and benefits we and our Affiliates receive, see “Item 4 Funding and Operation of Accounts-Cash Balances” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Fees and Expenses Not Covered by the Program Fee. Your Program Fee does not cover the following expenses, charges and costs: • Dealer spread charges, mark-ups or mark-downs charged by executing broker-dealers or other over-the-counter transactions in which Merrill or its Affiliate acts as agent, or dealer spreads, mark-up or mark-down charges, underwriting discounts or selling concessions with respect to any principal transaction effected by MLPF&S or our Affiliate. Merrill Guided Investing with Advisor Program Brochure | 17 MGI-A 032125 • Transfer taxes. • Exchange fees, alternative trading system fees, required SEC fees or similar fees charged by third parties, including issuers. • Electronic fund, wire and other Account transfer fees, including any certain fees and charges relating to transfer and termination fees, banking-related services, such as banking, check writing services and money transfers, wire transfers, including foreign currency wire transfers and foreign exchange conversion fees and costs (including fees or mark-ups or mark-downs in connection with foreign currency exchange or conversions, either in or out of your Account) and certain corporate action fees. • Fees, expenses and charges charged by Funds or by the managers or sponsors of Funds, including Internal fees, expenses and charges of the constituent Funds used in the Strategies. • Any other charges imposed by law or otherwise agreed to with regard to the Account (including those charges payable to Merrill and/or third parties as described in the Brochure). The Strategies available in the Program primarily utilize ETFs and mutual funds, each of which has internal fees and expenses that are specified in the individual Fund prospectus or offering materials. For investments in constituent Funds that are part of the Strategy, you will bear your proportionate share of such constituent Funds’ fees and expenses including, but not limited to, management fees and performance-based compensation paid to such Funds’ investment managers or their Affiliates, fees payable to the constituent Funds’ professional and other service providers, transaction costs and other operating costs. All of these fees and costs may be material, and some may be paid to Merrill and its Affiliates as compensation for services rendered. Any Fund contingent deferred sales charge, redemption or other fees imposed by a Fund manager as a result of your redeeming the Fund to invest in a Strategy will be separate from, and, in addition to, the Program Fee. The Program Fee does not cover or offset any of the fees and expenses that any constituent Fund may incur for transactions occurring within the constituent Fund itself, including commissions and other transaction-related charges incurred by the constituent Fund, even if we effect these transactions for the constituent Fund or provide services to the Fund. When your Account invests in Funds, you generally will purchase shares that have no front-end sales load or contingent deferred sales charge, or for which such loads or charges are waived. However, as a Fund investor, you will bear your proportionate share of such Fund’s fees and expenses including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. Any Fund redemption or other fees imposed by a Fund manager as a result of you redeeming the Fund to invest in a particular Program Strategy will be separate from the Program Fee. The Program Fee does not cover or offset any of the fees and expenses that any Fund may incur for transactions occurring within the Fund itself, including commissions and other transaction- related charges incurred by the Fund, even if we effect these transactions for the Fund. Except as otherwise provided for Retirement Accounts, the Program Fee will not be reduced even if MLPF&S or its Affiliate effects transactions for the Funds or otherwise provides services to the Funds for compensation. The Program Fee does not include certain fees and charges relating to transfers and terminations, certain corporate actions and banking-related services, including banking, check-writing services and money transfers, wire transfers, foreign currency wire transfers and foreign currency conversions, where applicable. Certain of these fees and charges are detailed on the Merrill Guided Investing with Advisor Schedule of Account and Service Fees available at merrilledge.com/relationships. Please see the brokerage account agreement and account enrollment documents relating to brokerage services and related transactions and account fees for your Merrill account. If you have any questions about any charges or fees applicable to your Account, please consult with your Program Advisor. Ability to Obtain Certain Services Separately and for Different Fees You may be able to obtain some of the same or similar Program Services or types of investments through a brokerage account or other investment advisory programs and services offered by Merrill. Many of the tools and analytics that are used to support services provided through the Program are also available through Merrill without enrolling in the Program and paying the Program Fee. You should consider the brokerage and investment advisory services we make available to determine which may be most appropriate for you. You may also be able to obtain some of the same or similar Services, investment solutions, or types of investments through other programs or services (in either other investment advisory programs or in brokerage) offered by Merrill. These may be available at lower or higher fees than charged by the Program. You may also be able to obtain some or all these types of Services from other firms at a total cost that may be lower or higher than or the same as the fees charged for the Program. More broadly, when you compare the services, investment solutions, account types and programs and their relative costs, you should consider various factors, including, but not limited to: • Your preference for an investment advisory or brokerage relationship. • Your preference for a discretionary or a nondiscretionary relationship. • Your preference for a fee-based or commission-based relationship. • Your preference for having access to Program Advisors compared to having a dedicated financial advisor or an online-only (digital) relationship. • Your preference to work with a Program Advisor by utilizing an online interactive website or not. • The types of investment vehicles and solutions that are available in each Merrill program or service. • Whether a particular investment solution offered in one service is available through another Merrill program or service at a lower or higher cost. • How much of your assets you expect to be allocated to cash. • The frequency and type of client profiling reports, performance reporting and account reviews that are available in each program or service. We offer other investment advisory programs, including the Merrill Lynch Investment Advisory Program (“IAP”), Merrill Guided Investing (“MGI”) and Merrill Edge Advisory Account (“MEAA”). These investment advisory programs have different service models and have a different set of investment offerings than the Program. In the case of IAP, from a service model perspective, you have direct access to ongoing advice and guidance from a dedicated financial advisor, whom you personally select and chose to work with, to discuss the particular investment strategy and available alternatives. Through IAP, you have access to a much larger set of managed investment strategies and the ability to access investment approaches and investment products and solutions that Merrill Guided Investing with Advisor Program Brochure | 18 MGI-A 032125 are unavailable in the Program, MGI or in MEAA. The Program only offers access to a limited list of Strategies constructed by the CIO and not the fuller complement of Strategies available in IAP. Depending on the IAP fee agreed to with a Merrill financial advisor chosen by you, the Strategies, as well as other managed strategies that are similar to those available in the Program, could be available at a higher or lower cost than is charged in this Program. With MGI, you may access certain of the Strategies available in the Program through an online self-guided interactive website for a fee that is lower than the Program Fee. You receive no recommendations from a financial advisor. With MEAA, you may access a selected list of investment strategies, including certain of those available in this Program, and access to a Program Advisor for investment advice and guidance for a fee that is the same as the Program but it does not have the same available services as this Program. We have provided you with materials that help to explain the various platforms and programs we offer, including our Form CRS and Summary of Programs and Services available at merrilledge.com/relationships. These documents are available on the Program Website. You should discuss with your Program Advisor the investment solutions, services and Program Advisor access to determine which may be most appropriate for you. Funding and Operation of Accounts Opening and Funding your Account. By signing the Agreement, you can open an account and enroll in the Program electronically. You may need to sign a separate agreement if you want to open an account, including in any other account ownership capacity, such as a trustee of a trust, a custodian of an account for a minor or as a joint account owner. The effective date of the Agreement for your Account will be the date of its acceptance by us and will be indicated in the Program Report for the Account. The Agreement will not apply to any accounts not reflected in the Program Report. As discussed above, you must provide us with a valid email address to enroll in the Program. Our advisory relationship begins upon the effective date of the Agreement with you. Any preliminary discussions or recommendations provided to you before we accept the Agreement do not constitute investment advice under the Advisers Act and should not be relied on as fiduciary investment advice. A Client request to enroll in the Program or to initiate a Strategy change is not considered a market order due to the requirements for enrollment including funding as well as the administrative processing time needed to implement enrollment instructions. We will initiate Program Services for new Accounts after your execution of any required Account documentation, approvals and funding of the Account and expect such enrollment to occur promptly. The investment of assets of an Account will only occur when all operational requirements have been met. Account acceptance may be delayed or rejected if the account is underfunded or funded with ineligible assets. You may fund your Account by depositing cash and/or securities acceptable to us. Contributions of cash and securities to your Account may be made at any time. There may be a delay between the date that cash and securities are contributed to an Account and the date that MAA invests such cash (or liquidates contributed securities if applicable). Except as otherwise provided in the Agreement, we will not be liable for any lost opportunity profits that may result from a delay in investing or liquidating any contributed securities in order to invest the proceeds into a Strategy. We may determine in our sole discretion that certain assets, including securities or pending orders relating to securities, are ineligible for the Program or otherwise unacceptable. If we determine in our sole discretion that any contributed investments are not eligible or are unacceptable, by your execution of the Agreement, you are authorizing us to sell those investments promptly and charge you a commission for the sale of these assets. We also may request that you take action to transfer the ineligible assets out of an Account. Failure to comply with the request to transfer such assets out of an Account enrolled in the Program may result in that Account’s termination from the Program. We will as a general matter sell any assets you have in your Account in order to invest in accordance with the particular Strategy that you select for your Account. If we determine not to sell the particular asset, are unable to sell the asset or if you specifically direct us in writing to not liquidate the asset (before it has been liquidated), we have the right to transfer the asset to a securities brokerage account. You are responsible for all tax liabilities arising from any sale of such ineligible or unacceptable assets. If we are unable to process sell orders to liquidate investments transferred for the purpose of funding your Account, we will not be able to enroll your Account in the Program. If your Account is already enrolled in the Program, your enrollment may be terminated. In such cases, we will notify you of your options, which may include transferring securities to a new or existing securities (brokerage) account (not part of this Program) or sending the securities back to the originating firm or account. Special Note about Funding your Account with Mutual Fund Shares. Before contributing mutual fund shares to the Program, you should consider the fact that you may have paid a front-end sales charge or may be obligated to pay a contingent deferred sales charge or redemption fee if the mutual fund shares are redeemed by us in order to invest in the Program Strategy you have selected; these fees, where applicable, will remain your responsibility and will be in addition to the Program Fee. Each mutual fund has its own system of share classes for certain types of clients and accounts. The Program-eligible mutual fund share classes vary depending on the mutual fund, its roster of share classes and our agreements with the mutual fund. In general, the share classes that are eligible for the Program do not have any sales loads or annual asset-based fees. Annual asset-based fees include “service fees” or “Rule 12b-1 fees” charged by the mutual funds. There are some mutual funds available in the Program that have such annual asset-based fees due to share class availability. If you contribute or hold mutual fund shares that we deem to be ineligible for the Program, we will either sell them and purchase the share class eligible for the Program if consistent with the Strategy model or we will exchange them, under the authority provided to us under the Agreement, mutual fund prospectus rules and our own policies, into the Program-eligible share class as promptly as practicable if consistent with the Strategy model. We may also require you to remove them from your Account. We may not elect to exchange particular share classes of a mutual fund if, for example, there is no equivalent class eligible for the Program or if other circumstances exist. Prior to contributing any mutual fund shares to your Account, you should discuss the impact of the sale or exchange of these holdings with a Program Advisor. By contributing mutual fund shares to your Account in the Program, you could be subject to higher expenses overall once the shares are exchanged into a class we deem to be eligible or if you held them in your brokerage account. Withdrawal Requests. For withdrawal requests, the liquidation of certain securities will be required. Withdrawal requests will be implemented as promptly as practicable, although implementation of the withdrawal may be delayed in certain instances, such as during periods of extreme market volatility. The following will apply to our handling of a withdrawal request: Merrill Guided Investing with Advisor Program Brochure | 19 MGI-A 032125 • You can make a request to withdraw your assets by calling us at 888.654.6837 or as directed on the Program Website. If you have questions or would like information relating to a withdrawal request, you can also call us at this number. • We require at least five business days’ prior notice to withdraw assets from your Account. In certain situations, it may take longer than five business days before you can access your requested funds. Our ability to liquidate securities may be impacted by market conditions and events or pending rebalancing actions being taken for the Account. • Withdrawal requests will be handled as promptly as practicable given other activities that may be occurring at the same time in an Account, like changes to a Strategy, any rebalancing transactions in process and other activity affecting the Account. • Funds must be withdrawn from the Account by you as soon as practicable after settlement date and if the requested funds are not withdrawn from the Account within fifteen calendar days after the proceeds from the liquidation have settled in the Account, we may then reinvest the proceeds back into the applicable Strategy without notifying you. • We reserve the right to liquidate, redeem or exchange Funds and other securities that are transferred from an Account to a brokerage account. • Taxable gains and losses may be realized as a result of your withdrawal instructions. • If your account balance is not sufficient to fully implement the Strategy for your Account, we may request additional funds or terminate your Account’s enrollment in the Program. • We reserve the right to terminate any Account that falls below (1) for the Total Return-Focused Strategies, the required minimum asset size of $1,000 and (2) for the Income-Focused Strategies, the required minimum asset levels as we determine from time to time; or, in either case, as otherwise reflected in the applicable Profile for the Strategy. • We will charge the Program Fee on the value of your investments in an Account until the sale or redemption of such securities is settled and the proceeds are moved out of the Account. • Your Account’s trading activity may impact available funds for an Account under margin rules. Please see “Item 4 Custodial Arrangements and Services” for additional information. Required Withdrawals for Income-Focused Goals. Recurring withdrawals for your Income-Focused Goals have special processing guidelines. Each year the total amount needed to meet the annual withdrawal amount will be allocated to cash and/or cash alternatives (the “Cash Withdrawal Allocation”) in the Account until the scheduled withdrawal date(s). The scheduled recurring withdrawal amount for the initial year will be calculated (if applicable) and processed to an Account’s Cash Withdrawal Allocation once instructions are provided to us during or shortly following the enrollment of your Account in the Program. The scheduled recurring withdrawal amount for each subsequent calendar year will be calculated (if applicable) and processed to an Account’s Cash Withdrawal Allocation by the beginning of that calendar year. As part of your instructions, you can elect to withdraw the full amount of the Cash Withdrawal Allocation in your Account as a one-time withdrawal request at the beginning of, or at any time throughout, the year. One-time withdrawal requests in an Account will be processed in accordance with our standard withdrawal request guidelines described above. You can also elect to withdraw partial amounts of the Cash Withdrawal Allocation in your Account over the course of the year at a set frequency we make available (e.g., monthly). You will be charged a Program Fee on the Cash Withdrawal Allocation amount held in your Account until amounts are withdrawn from the Account. You can instruct that the withdrawal amounts be directed to a separate brokerage account or in a deposit account at a Bank Affiliate or at other banking institution. Since these types of accounts are not Program Accounts, the cash in these accounts will not be subject to the Program Fee and will not receive any Program Services. We will not be an investment adviser or fiduciary with respect to such cash in these accounts. If you take withdrawals from your Account that exceed the actual income, it will impact future recurring cash withdrawals. Your instructions will continue in effect until you change or cancel your instructions, your instructions expire by their stated terms, your Account is approaching and/or reaches the required minimum or your Account is terminated. It is important to understand that changes you make to the amount of recurring withdrawals and any unscheduled cash withdrawals will result in changes to the amount of recurring withdrawals that you will receive over the term of your Account in the Strategy. Choosing an amount of recurring withdrawals that is higher than the hypothetical projections or actual income received or making unscheduled withdrawals will result in lower hypothetical projections in future years and reduce the amount of future recurring withdrawals over the term of your Account in the Strategy. Unless the CIO directs that your Account’s Cash Withdrawal Allocation be invested in a cash alternative, like a money market fund, your Account’s Cash Withdrawal Allocation will be treated as a cash balance in your Account that will be automatically swept to the cash sweep option applicable to your Account under the Cash Sweep Program. Other than for Retirement Accounts, there is also a “No Sweep” option. You will be charged a Program Fee on any cash balances and cash alternatives held in your Account. For additional information on cash balances and the Cash Sweep Program, see Item 4 at the sections “Treatment of Cash Balances in your Account” and “Brokerage, Banking-Related and Custodial Arrangements and Services-Cash Sweep Program and Other Banking-Related Services.” Any cash allocations invested in a money market fund are subject to such money market fund’s management, distribution, transfer agent, and other expenses. These fees and expenses are in addition to, and will not reduce, your Program Fee, except as required by law. We receive compensation in connection with any such money market fund holdings. See “Item 4 The Program Fee and Other Charges-Determination of how the Program Fee is Charged” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest.” We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See “Item 9 Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Changes to Your Strategy. We will implement any approved change to the Strategy that you select as soon as reasonably possible. Termination of Enrollment in the Program. The Agreement may be terminated at any time by either us or you, by providing verbal or written notice. The termination of the Agreement will terminate enrollment of the Account in the Program. You can request to terminate your Account’s enrollment either online via the Program Website or by phone at 888.654.6837. Termination of the Agreement will not affect or preclude the consummation of any transaction initiated prior to termination. Merrill Guided Investing with Advisor Program Brochure | 20 MGI-A 032125 Your termination of a particular Account will not automatically terminate any of your other Accounts. Termination of your Account will be effective following the completion of processes that may be required to terminate the Account, including any required liquidations. If you would like to liquidate all or part of your positions when terminating your enrollment in the Program, you may do so by calling us at 888.654.6837. We will attempt to process your requests in a prompt manner. Termination of a Program Advisor’s employment with Merrill or a change in the role of any of our Program Advisors who assisted you with your Account will not automatically terminate the Agreement. We reserve the right to assign Program Advisors who will be available to provide you Program Services for your Account. We will not be responsible for market fluctuations in your Account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient liquidation of an Account include, but are not limited to, size and types of securities, liquidity of the markets and market-makers’ abilities. Due to the administrative processing time needed to terminate an Account, termination requests cannot be considered market orders. It could take up to several business days under normal market conditions to process your request. Upon termination of an Account, a pro-rata adjustment to the Program Fee for the remainder of the billing period will be made, which may result in your receiving a refund of a portion of the Program Fee monthly payment. In addition, your Account will be converted to, and designated as, a brokerage account that will be subject solely to the terms and conditions of the Merrill brokerage account agreement. Depending on the nature of the account, brokerage services and activities in the brokerage account may be limited. Merrill reserves the right to take action under its Program guidelines to terminate the Account from the Program if we are unable to obtain instructions from you as to your Account in a timely manner. For certain mutual funds, the advisory share class of such funds are not eligible to be held in an account that is not enrolled in the Program. Upon Account termination or if you or we move or transfer the mutual fund shares from your Account to a brokerage account, we will automatically liquidate, redeem or exchange these shares into another appropriate share or unit class in accordance with the applicable offering materials and our own policies without providing prior notice. Additional fees and expenses may apply upon such liquidation, redemption or exchange. Any liquidation, redemption or exchange will generally be effected as soon as practicable, which may be as soon as the close of the next business day following a termination or transfer. Brokerage share classes generally will have higher operating expenses than advisory share classes that are eligible for the Program and will charge sales loads and annual asset-based fees (which includes “service fees” or “12b-1 fees”). These fees will be used to compensate Merrill or one of its Affiliates. Cash Balances. Your Account will have an allocation to cash depending on the Strategy selected, including any amount of cash set aside for recurring withdrawals, and the asset allocation and investment determinations that the CIO has made. The CIO determines whether to keep a cash balance for operational and/or investment purposes as part of the Strategy. Unless the CIO directs that your Account’s cash allocation be invested in a cash alternative, like a money market fund, your Account’s cash allocation will be treated as a cash balance in your Account that will be automatically swept to the cash sweep option applicable to your Account under the Cash Sweep Program. Other than for Retirement Accounts, there is also a “No Sweep” option. You will be charged a Program Fee on any cash balances and cash alternatives held in your Account. We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See “Item 9 Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” The CIO can invest cash balances in money market funds which have a one-day settlement period. Any cash allocations invested in a money market fund are subject to such money market fund’s management, distribution, transfer agent, and other expenses. These fees and expenses are in addition to, and will not reduce, your Program Fee, except as required by law. We receive compensation in connection with any such money market fund holdings. See “Item 4 The Program Fee and Other Charges-Determination of how the Program Fee is Charged” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest.” Legal Matters and Related Services. We will not advise or act for you with respect to any legal matters for securities held in your Account, including bankruptcies or class actions and as your broker dealer, Merrill will endeavor to send you any documents received with respect to such matters. We will respond to corporate actions for securities in the Account. Corporate actions for a client’s account can include any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. Your Responsibilities for Account Operation and Management. You must notify us through a Program Advisor or through the Program Website promptly of any material change in financial circumstances, investment objectives or investment restrictions that may affect the nature of the investment advice and services provided to Program Accounts. You are responsible for monitoring the total amount of deposits held at any one bank, including at any of our Bank Affiliates, for FDIC insurance limits. See “Item 4 Brokerage, Banking-Related and Custodial Arrangements and Services-Cash Sweep Program and Other Banking-Related Services.” There is more detailed information about FDIC insurance and limits in the Sweep Program Guide for Merrill Clients. Tax Matters General Tax Matters. You are responsible for all tax liabilities and tax-return filing obligations arising from the transactions in your Account enrolled in the Program. We do not, and will not, offer tax advice to you and we strongly encourage you to seek the advice of a qualified tax professional. We are not responsible for attempting to obtain any tax credit or similar item or preparing and filing of any legal document on your behalf. You should be aware that tax consequences may arise when Strategy changes occur in your Account such as rebalancing, liquidations and redemptions, and as a result of any action undertaken as part of the TEM Overlay Services if elected for an eligible Account. Except to the limited extent described in this section, we specifically disclaim any undertaking of tax management of your Account or investments and assume no responsibility for any resulting tax consequences. Additionally, if you direct us by contacting a Program Advisor (or by contacting us by telephone at 888.654.6837) to take certain actions for tax-related reasons, there is no assurance that your desired tax effect will be realized. Merrill Guided Investing with Advisor Program Brochure | 21 MGI-A 032125 For example, if you direct us to realize gains in your Account, when we resume normal trading activity, such activity could generate new taxable losses or gains, and the same or similar securities may be repurchased. Similarly, if you direct us to realize losses in your Account, when we resume normal trading activity in your Account, such activity could generate new taxable losses or gains. Upon your request to realize losses within an Account and not as part of the TEM Overlay Services, we will attempt to undertake the following: (1) restrict purchases of substantially identical securities in the Account for a minimum of thirty-one calendar days following the sale of securities at a loss in the Account; (2) restrict sales of substantially identical securities in the Account that are currently at a loss for a period of thirty-one calendar days following the purchase of securities in the Account; and (3) at our discretion, engage in strategies to invest the available proceeds for varying time periods in substitute securities, current holdings, and/or alternative securities such as ETFs. We could also determine to hold cash in certain circumstances. We do not make any guarantee that these actions will be successful in recognizing these losses. We are not providing any tax advice with respect to the effects of these transactions including whether a loss has been disallowed under the wash sale rules under the Code. We do not take into account the trading activity in any of your other accounts, including your other Accounts in the Program or any accounts you have with Merrill or its Affiliates or third parties. You should consult your own professional tax advisor regarding the tax consequences of these transactions. You should be aware that as a result of these transactions, a higher than normal cash allocation may result for a period of time. In addition, this type of transactional activity may adversely affect Account performance and may increase the volatility of its results. Special Risks and Limitations associated with the TEM Overlay Services. We make available to eligible Accounts the TEM Overlay Services provided by MAA. There are risks and limitations associated with the TEM Overlay Services and these limitations may result in tax inefficient trades and wash sales. The TEM Overlay Services are designed to effect tax efficient management under U.S. tax rules and regulations. You should consult your tax and/or legal advisor prior to electing the TEM Overlay Services, as well as on an ongoing basis, to determine whether the wash sale rules, the straddle rules, or other special tax rules could apply to your trading activity. Generally, under the wash sale rules, if a security is sold for a loss and the same (or a substantially identical) security is repurchased either 30 days before or 30 days after the date of sale, the loss is disallowed. In addition, other tax treatment rules, such as the straddle rules, may disallow losses. There is little authority governing whether an ETF or mutual fund replacement security is “substantially identical” to another ETF or mutual fund security for purposes of the wash sale rules. As such, no assurances can be provided that if we choose an ETF or mutual fund security as a replacement security to the sold security, the replacement ETF or mutual fund security will not be deemed “substantially identical” for purposes of the wash sale rules. The TEM Overlay Services apply on a per-Account basis only and only to the Account that has selected the TEM Overlay Services. Please note, however, that the wash sale rules apply to securities transactions in not only that Account but also to securities transactions in all other accounts held by you, your spouse and certain entities controlled by you and your spouse. The accounts covered under the wash sale rules include all taxable accounts and retirement accounts held at Merrill or its Affiliate that are brokerage accounts and/ or accounts enrolled in investment advisory programs, and all securities accounts of any type held with third parties in each case, held by you, your spouse and certain entities controlled by you and your spouse (collectively, “securities accounts”). The TEM Overlay Services will not take into account trading activity in any of these other securities accounts. The sale of a security for a loss in an Account with the TEM Overlay Services elected will not generate a loss for tax purposes if the security or position was part of a wash sale or straddle as a result of trading activity or securities in any other of your securities accounts. In addition, the purchase of a replacement security in an Account with the TEM Overlay Services elected may give rise to a wash sale with respect to a security or position in any of your securities accounts (including those of your spouse and certain of your spouse’s controlled entities). Similarly, other trades executed in any securities account may also result in a wash sale in the Account with TEM Overlay Services elected. If you have elected to participate in the optional Automatic Withdrawal Service offered through the Program for certain eligible Accounts, the transactions that occur as a result of the TEM Overlay Services could result in wash sales, even in the Account that has elected TEM Overlay Services. In applying the TEM Overlay Services to an Account that includes selling securities and investing in the underlying Total Return Strategy-aligned replacements, the performance of any replacement security selected will not be the same as that of the security sold and, in fact, the replacement security may perform worse than the security sold. Any tax-related benefits that result from the TEM Overlay Services may be negated or outweighed by investment losses and/or missed gains (realized and unrealized) that also may result. An Account that elects TEM Overlay Services will generally trade more frequently than an account which has not elected the TEM Overlay Services. There are implicit trading opportunity costs associated with the additional turnover which may affect the returns on your Account. Electing the TEM Overlay Services may not be appropriate for your financial situation. If you are taxed at lower aggregate marginal income tax rates, you may be less likely to benefit from the TEM Overlay Services than would an investor taxed at higher aggregate marginal income tax rates. Because you may use capital losses only to offset certain amounts of capital gains that you might have, and possibly, to a limited extent, ordinary income, if you have net capital losses in excess of the applicable threshold, you may not realize as many immediate tax benefits through the application of the TEM Overlay Services to your Account. When selling a security that is held in two or more tax lots, TEM Overlay Services may seek to minimize the capital gains tax consequences of the sale and in doing so may consider the holding periods (long-term or short-term) of the securities sold. It is your obligation to monitor transactions across all of your accounts to identify any wash sales or straddles and you are responsible for all tax liabilities attributable to the disallowance of any losses pursuant to the wash sale rules or of any deferral under the straddle rules. Merrill and MAA cannot provide any assurances that losses will not be disallowed pursuant to the wash sale rules or deferred under the straddle rules. If you elect the TEM Overlay Services, you should consider monitoring trade-by-trade confirmations and, to the extent any security is sold for a loss, refraining from acquiring the same (or a substantially identical) security in your Account or any of your securities accounts. Despite this, it is possible that you may still be subject to the wash sale or straddle rules in any given tax year. Item 5. Account Requirements and Types of Clients Merrill requires that all clients who wish to enroll in the Program enter into the Agreement through the Program Website as described in the Agreement and Brochure. The Agreement sets forth the terms and conditions that govern the handling of the client’s Account and defines the investment advisory relationship between the client and Merrill and MAA in providing Program Services. A separate Account is required for each Strategy selected by the client. Merrill Guided Investing with Advisor Program Brochure | 22 MGI-A 032125 Merrill and MAA can decline to accept a particular client or account in the Program at any time and for any reason at their sole discretion. Not all Merrill account types are eligible for enrollment in the Program. Investors generally eligible to participate in the Program include individuals, trusts, Retirement Accounts, joint account owners and custodians for an account for minors. As a requirement, you must establish an Account and enroll in the Program electronically through the use of the Program Website as described in the Agreement and this Brochure. There is a minimum asset requirement of $20,000 to enroll into the Program. We may waive or alter this minimum at our discretion. Certain Services, such as the optional Automatic Withdrawal Service and the optional TEM Overlay Services, are only available for eligible Accounts. Total Return-Focused Strategy Minimum. The minimum initial investment requirement for your Account is $1,000, $5,000 or $20,000 or as otherwise provided on the Profile for the Strategy. We may waive or change this minimum at any time. Income-Focused Strategy Minimum. The minimum initial investment requirement for your Account is $50,000 or as otherwise provided on the Profile for the Strategy. We may waive or change this minimum at any time. Following enrollment, an Account must maintain a minimum asset amount set by us in our discretion in order for us to provide Program Services. If your Account’s assets do not meet this minimum, we may request that you contribute additional funds to your Account. If you decide not to take the requested action, we reserve the right to terminate your Account from the Program, which converts the Account to a brokerage account type. We may change these minimums at any time. Item 6. Portfolio Manager Selection and Evaluation Review and Selection of Strategies and Funds Available in the Program General. Through the Program, we make available Strategies with various investment styles and corresponding risk levels, in each case that we decide in our discretion to make available in the Program. The determination to include the Strategies selected in, or to remove them from, the Program is made by us based on a variety of factors, including client needs, investment styles available in the marketplace, platform capacity, client demand and the outcome of reviews conducted by or under the auspices of Merrill, including through the CIO. The CIO is a Merrill business group providing investment solutions, portfolio construction advice and wealth management guidance to Program Advisors and clients, and is separate from MAA and from the Merrill business group that administers the Program. CIO Review Process. We perform, through our product teams’ internal business processes, initial and periodic reviews of Strategies and constituent Funds that comprise the Strategies. In addition to these business processes, we have in place an investment review (“CIO Review Process”) conducted by or under the auspices of personnel of the CIO of Funds, including those included in the Strategies constructed by the CIO. All constituent Funds included in the Strategies are subject to the CIO Review Process. The CIO Review Process consists of proprietary processes conducted by CIO and those processes and reviews provided by third-party reviewers that we have engaged for this purpose. The third-party reviewer services are generally consistent with the multi-factor processes that the CIO deploys but they are not identical. We, through the CIO, have reviewed such third-party reviewers’ processes and believe they are reasonable and appropriate in light of the objectives of the Program. Once we identify a need for a particular investment management style, or strategy, a quantitative and qualitative due diligence process is employed, including but not limited to, the organizational structure and stability of the investment manager or Fund manager or sponsor, adherence to investment style, including sustainability or ESG attributes, where relevant, evaluation of risk and volatility, investment professional and strategy resources, investment philosophy and process, portfolio construction, performance, and operating and administrative capability. Based on these factors and using the information collected, the CIO Review Process involves quantitative and qualitative analytical methods, some of which may be subjective. Generally no single factor will be determinative. Our reviews may involve in-person visits, telephone conference calls, reviews of performance, and updates of certain Fund manager prepared materials or Fund documents and information. We may also conduct periodic analysis of composite performance data; however, we do not perform audits of Funds or Fund managers or sponsors to verify past performance information provided to us. There is no assurance that the CIO Review Process or our internal reviews will identify the best performing Funds. For each Strategy, we will periodically evaluate factors related to the Strategy and constituent Fund investments that we deem appropriate. For each Fund available at Merrill, including the constituent Funds, we will periodically evaluate factors related to the Fund investments that we deem appropriate. In addition, we may initiate reviews based on various factors determined by us and the CIO to be appropriate, including the level of assets in a Strategy or constituent Funds in client accounts at Merrill or an Affiliate, the number or percentage of Merrill or Affiliate clients in a Strategy or constituent Funds and the asset class involved. If we identify concerns regarding a Strategy or a constituent Fund that we find significant or important, we may choose not to accept any new investments in that Strategy or the constituent Fund. A drift or variation of the style of management of a particular Strategy or constituent Fund from the stated style does not require a removal from our Program offering. Our product teams’ internal business review and the CIO Review Process form the basis for Merrill determining whether to make ETFs available for use in the Program. In addition, the CIO Review Process determines whether ETFs will be included in a Strategy constructed and implemented by the CIO. The CIO Review Process and conclusions from that process do not rely on or otherwise use the research reports and ratings related to certain ETFs of the BofA Global Research Group (“Research Ratings”) as an input or factor. The CIO, BofA Global Research and other business units of BofA Corp. apply different methodologies in their review of ETFs and may arrive at different or inconsistent conclusions. Note that Fund managers include as part of their investment portfolios individual equity and fixed income securities based on their own review and portfolio management processes and determinations. These individual securities may not be covered, and are not required to be subject to, the CIO Review Process. Merrill retains the decision-making authority to add or remove a Strategy or constituent Fund from the Program. Our review, including through the CIO Review Process, of the Strategies and constituent Funds does not substitute for your ongoing monitoring of your Account and the performance of your investments. Merrill Guided Investing with Advisor Program Brochure | 23 MGI-A 032125 Strategy Construction Through the Program, we, through the CIO, will construct the Strategies and select the Funds and the allocations or allocation ranges for each Strategy. In general, we develop the Strategies in an effort to seek to strike a balance between current income and growth for Total-Return Focused Strategies and to seek to obtain a continuing stream of income from investments and that changes over time and for recurring Account withdrawals through a stated end year for Income-Focused Strategies, as described in the Profile for the particular Strategy. The CIO selects the constituent Funds for the particular Strategy and, when doing so, selects only those subject to the CIO Review Process and those that are considered to have sufficient assets under management and to meet minimum trading volume parameters. In addition, it considers and evaluates their share price or net asset value, along with the corresponding allocation weighting, in light of the Strategy’s investment minimum. The CIO determines the allocations or allocation ranges for the Strategies. It develops the strategic asset allocations for the Strategies based on its long-term expected return, risk and correlation assumptions for each asset class (“capital market assumptions”), its view of the appropriate long term allocation guidelines to follow in light of market conditions, expected trends and, as applicable, corresponding tactical asset allocation adjustments. The tactical asset allocation adjustments are applied to those long-term asset allocations based on the CIO’s near-term market, economic, and asset class expectations. These tactical adjustments overweight or underweight specific asset classes, incorporating its investment views on how market dynamics, phases of the economic or business cycle, and particular investment themes may affect the Strategies. In order to determine tactical asset allocations, the CIO utilizes internal as well as third-party research and data at both the macro and micro levels. Once the Strategies are constructed, the CIO regularly monitors and reviews them and makes adjustments based on asset allocation changes. The Funds used in the Strategies are also periodically reviewed to ensure they continue to meet the criteria for inclusion. The Strategies are also subject to internal governance and oversight processes on a periodic basis, which may include a review of Strategy performance against expectations as well as any applicable investment or regulatory restrictions. In addition, for Income-Focused Strategies, the CIO provides estimates of projected income amounts (e.g., baseline and variable) based on your initial investment, withdrawal start year and the Strategy that you select. The projected income amounts for the future years are based on your investment amount, your Target Asset Allocation and a U.S. Treasury Yield Curve. A U.S. Treasury Yield Curve is a collection of yields of U.S. Treasury bills, notes, and bonds with different maturities. The projected income amounts are calculated to increase by applying a cost-of-living adjustment that assumes a constant inflation rate for your Time Horizon. The projected income amounts may be adjusted to higher amounts in future years based on the performance of the portfolio and based on the previous projected income amounts. The projected income amounts additionally depend on the capital market assumptions set by CIO. The capital market assumptions are long-term views of major asset classes—including stocks, bonds, cash, and alternative investments. More specifically, they are estimates, for a 25-year planning horizon of the expected returns, volatility, and correlations of a set of asset classes that is broadly representative of the investment universe. The projected income amounts will be adjusted based on the capital market assumptions of the asset classes, prior withdrawals and the performance of the portfolio. They are hypothetical estimates and are intended for illustration purposes only. For more information about how these projections are calculated, how the information you provide is used, the assumptions used and limitations of these projections, please consult “Hypothetical Income Projections Tool“ document available on the Program Website. HYPOTHETICAL PROJECTED INCOME IS NOT GUARANTEED AND DOES NOT PREDICT ACTUAL FUTURE PERFORMANCE. The Program does not currently offer any Funds sponsored or advised by us or any of our Affiliates (a “Related Fund”). However, we may determine in the future to include Related Funds in a Strategy. The conflicts of interest and other considerations arising from the use of Strategies constructed, implemented and managed by Merrill or any of its Affiliates are discussed at “Item 9 Compensation, Conflicts of Interest and Material Relationships.” Available Information Regarding Strategies and Funds For the Strategies, we make available to you a document that contains a description of the Strategy you select, referred to as a “Profile.” The Profile for each Strategy is also available on the Program Website. You should carefully read the Profile provided and understand the relevant objectives, styles and risks. The Profiles for the Strategies include performance information from MAA. No claim is made that performance information contained in the Profile has been calculated according to any industry standards. Your investment performance for any Strategy in your Account may differ from the information presented in the Profile for that Strategy for a variety of other reasons, including timing of enrollment in the Program, client-imposed Reasonable Investment Restrictions and other considerations. Please note that any past performance shown on the Profile is not indicative of future results and your investment performance for any Strategy in your Account will differ from the information presented in the Profile for that Strategy. We make available guidance to Program Advisors through regular or ad hoc publications, including those from the CIO that reflect our internal opinions and views with respect to a Strategy or constituent Fund. You should discuss with your Program Advisor any questions you may have about our views with respect to a particular Strategy or constituent Fund or review material available at the Program Website. We will also make available on the Program Website the applicable Prospectus and/or disclosure documents for the constituent Funds included in your Account, in our discretion and/ or as required by law. These disclosure documents will describe the relevant objectives, styles and risks of the constituent Fund. For an eligible Account, you will be provided with documents that contain descriptions of the TEM Overlay Services (“Term Sheets”) on the Program Website. You should carefully read the Term Sheets provided and understand the relevant approaches of the TEM Overlay Services and the risks and limitations. Additionally, the TEM Overlay Services are subject to internal governance processes. Advisory Services Provided by Merrill and Certain Affiliates Merrill and MAA will generally act as the portfolio manager for your Account as described in “Item 4 Investment and Trading Authority; MAA’s Role.” We act as both the wrap fee program sponsor and portfolio manager for the Strategies offered through the Program. Merrill receives the Program Fee as described in this Brochure. We also act as the portfolio manager in other wrap fee programs sponsored by us. We act as an investment adviser in certain investment advisory programs, like MGI and MEAA, which provide investment advisory services that are similar to the Program Services but are not the same. Additional information is available in “About Us and the Program” and in “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Merrill Guided Investing with Advisor Program Brochure | 24 MGI-A 032125 The CIO releases information and analyses used in the Program to Merrill, MAA, our Affiliates and financial advisors at the same time. It is possible that our Affiliates and other investors will act on that information before Merrill or MAA has had the chance to evaluate and act on those changes. Accounts participating in Merrill programs that commence trading after those of other Affiliates may be subject to price movements, particularly with large orders or where securities are thinly traded, that would cause them to receive prices that are less favorable than those potentially obtained by Affiliates or other investors. Performance-Based Fees The Program does not charge performance-based fees. Certain Funds that may be constituent investments as part of the Strategy you select, however, may be subject to performance-based fees or varying Fund expense charges that are imposed by the Fund’s manager, adviser or other party that are based on performance of the Fund. Methods of Analysis The implementation and management of any Strategy will be dependent upon the CIO’s investment expertise, philosophy and process and will be supplemented by the Program Advisor understanding the Strategies and providing advice and guidance to you. To assist your Program Advisor, we have made available various resources, including: (1) investment guidance and management research and publications from the CIO covering macroeconomic and market events and Strategies and Funds and (2) information and assistance from other Merrill internal specialists and support teams. Any use of such guidance and proprietary model portfolios does not assure or guarantee that investment performance will necessarily be profitable or consistent with the proprietary model portfolio. Tailored Investment Advice Under the Program, you set a Target Asset Allocation for your Account based on certain factors provided by you and select a Strategy for each Account in the Program. You also may request that we impose Reasonable Investment Restrictions on an Account. A Program Advisor and the Program Website will help you select Strategies consistent with your Target Asset Allocation, and other information you provide to us. If you have an investment policy statement or other investment guidelines (“IPS”), it is your responsibility to ensure that the IPS is properly reflected in your responses inputted into the Online Profiling Process and to the Program Advisor, including any investment restrictions. We do not have any responsibility to review, monitor or adhere to any IPS relating to your Account. Adherence to your IPS is solely your responsibility. To the extent the terms of such IPS conflict with a Strategy you select under the Program, by signing the Agreement, you have agreed that the terms of such IPS were amended to incorporate by reference such investment or Strategy. Investment Strategies and Risk of Loss Set forth below is a summary description of material risks related to the Services provided in the Program and investment strategies and products that have significant or unusual risks. The information provided below is meant to summarize certain risks and is not inclusive of each and every potential risk associated with each investment type or applicable to a particular Account. Therefore, you should not rely solely on the descriptions provided below and are urged to speak with your Program Advisor and ask questions regarding risk factors applicable to a particular Strategy, read all risk disclosures and determine whether a particular Strategy is suitable for your account in light of your specific circumstances, investment objectives and financial situation. General Risks Associated with Investments in your Account. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed and the values of your assets will fluctuate due to market conditions and other factors. Investments made, and the actions taken, for your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi- governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Strategies that consist of constituent Funds that invest in equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, the selected sectors or industries or the securities market as a whole, such as changes in economic or political conditions. Constituent Funds can also invest in fixed income securities. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain Strategies consist of constituent Funds that have invested in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments by constituent Funds in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the constituent Fund may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. You should review the offering materials and other disclosure available for each relevant Strategy and/or Funds to get an appreciation of its associated risks and fees. We make no representations or warranties with respect to the present or future level of risk or volatility in your Account or the Strategy or investment’s future performance or activities. You are assuming the risks involved with investing in the Strategies and the constituent Funds. You could lose all or a portion of the amount held in the Program. There is no assurance that the performance results of any benchmark or index used in connection with a Strategy, including those shown in a Profile, can be attained. Market movements and other factors may result in significant differences between the performance of your Account, your Account’s Target Asset Allocation and the Strategy selected for your Account. Merrill Guided Investing with Advisor Program Brochure | 25 MGI-A 032125 Target Asset Allocation and Monitoring. Any target asset allocations (including your Target Asset Allocation) or benchmarks, as applicable, referred to in connection with your Strategy or Account are not intended to be an assurance or guarantee of the performance of any investments in the Strategy or of the Account itself. There is no assurance that the performance results of any benchmark or index used in connection with a Strategy, including those shown in a Profile can be attained. Market movements and other factors (including withdrawals from an Account) may result in significant differences between the performance of your Strategy and any Target Asset Allocation for your Account. Particular Risks Regarding the Income-Focused Goal. The hypothetical projected income amount is based on the information you provide to us and the methodology, assumptions and limitations of the tool we use to calculate the hypothetical projections. The assumptions used to derive the hypothetical projected income amount involve a significant element of subjective judgment. In all cases, hypothetical projected income is only an estimate of future results that is based upon assumptions made at the time the projection is developed and other factors as discussed herein. There can be no assurance that the hypothetical projected income will be obtained, and actual income received over the course of the Strategy may vary significantly from the projections. You should expect that the amount of income and recurring withdrawals received each year will change. The hypothetical projected income assumes that your stated Risk Tolerance does not change over the course of the Strategy. If you change this or other information such as your time horizon or the amount of your initial contribution, the projections will change. The hypothetical projections are presented as of the date on which they are provided. If you perform the calculation on a different date, the results may be different due to the difference in time or if any of the underlying assumptions change, even if your information hasn’t changed. Your investment returns and the amount of income and recurring withdrawals received over the course of your time horizon are subject to changes due to general economic conditions, general market fluctuations, and the risks inherent in securities markets. Investment markets can be volatile and prices of investments can change substantially due to various factors. You may experience losses or the Strategy may result in you not receiving adequate income, or income consistent with your hypothetical projected income, at and through retirement. This may be due to any of the risks discussed herein and, in particular, any of the following factors, the scope and magnitude of which cannot be predicted with any level of certainty: (1) market fluctuations; (2) economic growth or recession; (3) local, regional, or global events; (4) changes in interest rates; (5) changes in inflation rates; (6) national or international political changes; (7) changes in the actual or perceived creditworthiness of issuers; (8) general market liquidity; and (9) changes in the Internal Revenue Code. The Income-Focused Goal does not ensure that you will have assets in your account sufficient to cover your retirement expenses; this will depend on, among other things, the amount of money you have invested in the Strategy, the returns of the markets over time, the amount you spend in retirement, and your other assets and income sources. The Income-Focused Goal and Strategies do not take into account any assets, investments or income you have (such as pension, Social Security benefits or other retirement income) other than your stated initial investment or current investment balance. WE DO NOT PROVIDE A GUARANTEE THAT SUFFICIENT INCOME WILL BE ACHIEVED TO PROVIDE ADEQUATE INCOME THROUGH YOUR STATED END YEAR OR THROUGHOUT RETIREMENT. If you request that we change your Goal or Strategy, stop or modify the amount or duration of any recurring withdrawals, the likelihood of meeting your Goal may decrease. In particular, if your withdrawal amount is more than the actual income amount, your future annual withdrawal amounts for the rest of your withdrawal period could be reduced significantly. Certain mutual funds or other products may pursue a similar strategy to the Income-Focused Strategies and may charge lower fees than your Account. The Income-Focused Goal is not an annuity and you should consider whether an annuity product is more appropriate for you. Particular Risks Regarding the TEM Overlay Services. If you elect the TEM Overlay Services on your eligible Account, you assume the risks associated with MAA’s investment decisions and trading activity. You also acknowledge that MAA may sell all or a portion of the securities in your Account, either initially or during the course of providing the TEM Overlay Services to your Account and that you understand the risks and limitations associated with the TEM Overlay Services which are summarized in this Brochure, including in the “Item 4 MAA Tax Efficient Management Overlay Services” and “Item 4 Tax Matters” sections and the Program Website. You are responsible for all tax liabilities arising from these transactions. We will not offer tax advice to you on these or other issues. Use of Strategies Where Merrill Is the Manager. The Strategies currently available in the Program are those that are constructedand managed by MLPF&S (through the CIO) and implemented for Accounts by MAA. These Strategies are not subject to the same level of review that is applicable to third- party manager strategies that Merrill offers in its other investment advisory programs. Information and Cyber Security Risks. With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly, BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities, the Funds and Fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents directed at BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents as well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we or our service providers, will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as Merrill Guided Investing with Advisor Program Brochure | 26 MGI-A 032125 the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory and operational and reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. ESG themed Strategies or Funds. There is an increasing number of products and services that purport to offer environmental, social, and governance (“ESG”) investment related strategies. The variability and imprecision of industry ESG definitions and terms can create confusion. Fund managers and sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. You should review the offering materials and Profiles to gain an understanding of how they define and use ESG screens and restrictions in connection with their investment products. Merrill and MAA generally do not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the Fund manager) other than as part of the CIO Review Process. ESG Strategies, including ESG-related Funds, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by the CIO or fund manager, will align with your ESG-related beliefs or values. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the CIO’s or Fund manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities and, as a result, investment performance could suffer. When evaluating investments for an ESG Strategy, the CIO or Fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment of an investment’s ESG or sustainable attributes. Neither Merrill nor MAA guarantees or validates any third-party data, ratings, screenings or processes. ETFs. The Strategies you select generally consist of shares of, or interests in, ETFs. Below is a summary of certain risks relating to investing in ETFs that may apply to all or certain types of ETFs included in a Strategy. Please refer to the particular ETF prospectus for more information about the risks applicable for a particular ETF. If you would like a copy of a particular ETF prospectus, you may obtain one, free of charge, by contacting us at 888.654.6837 or via the Program Website. ETFs are subject to risks relating to market trading that include the potential lack of an active market for ETF shares and disruptions in the creation and redemption process. Although ETF shares are listed on a national securities exchange, it is possible that an active trading market in the shares of a particular ETF may not develop or be maintained, particularly during times of severe market disruption. If ETF shares need to be sold when trading markets are not properly functioning, the ETF shares may be sold at a significant discount to their Net Asset Value (“NAV”) or it may not be possible to sell them in the secondary market. Market and other disruptions also make it difficult for the ETF manager to accurately price its investments, thereby potentially affecting the ETF’s price and performance. Similarly, an exchange or other markets may issue trading halts on specific securities or derivatives, which will affect the ability of the ETF to buy or sell certain securities or derivatives. In such circumstances, the ETF may be unable to rebalance its portfolio or accurately price its investments and may incur substantial trading losses. ETFs that seek to track the performance of a specified underlying index (“Index ETFs”) are not actively managed and the investment advisers of such ETFs do not attempt to take defensive positions in declining markets. Therefore, Index ETFs may be subject to greater losses in a declining market than a fund that is actively managed. A number of factors may affect an Index ETF’s ability to achieve a high degree of correlation with its underlying index, and there can be no guarantee that an ETF will achieve a high degree of correlation with its underlying index either on a single trading day or for a longer time period. Factors such as ETF expenses, imperfect correlation between the ETF’s investments and the components of the underlying index, rounding of share prices, changes to the composition of the underlying index, regulatory policies, a high portfolio turnover rate, and the use of leverage all contribute to tracking error and correlation risk. Failure to achieve a high degree of correlation may prevent an ETF from achieving its investment objective and cause the ETF’s performance to be less than you expect. As an ETF shareholder, you, along with other shareholders of the ETF, will bear a proportionate share of the ETF’s expenses, including, as permitted by applicable law, certain management and other fees, which may be payable to us or an Affiliate. An ETF’s prospectus Merrill Guided Investing with Advisor Program Brochure | 27 MGI-A 032125 contains a description of its fees and expenses. When you invest in an ETF, you will indirectly pay a proportionate share of the ETF’s costs for services that may be similar to, or duplicative of, services rendered as part of the Program and paid for directly through the Program Fees. Mutual Funds and Non-traditional Funds. The Strategies you select may invest in shares of, or interests in, mutual funds. Please refer to the particular mutual fund prospectus for more information about the risks applicable for that mutual fund. If you would like a copy of a particular mutual fund prospectus, you may obtain one, free of charge, by contacting us at 888.654.6837 or via the Program Website. As a constituent Fund shareholder, you, along with other shareholders of the Fund, will bear a proportionate share of the constituent Fund’s expenses, including, as permitted by applicable law, certain management and other fees which may be payable to us or an Affiliate. The constituent Fund’s prospectus or other disclosure document contains a description of its fees and expenses. Not all constituent Fund fees and expenses are applicable to every Strategy offered. If you invest in a Fund, you will indirectly pay, through the Fund’s net asset value, a proportionate share of the Fund’s costs for services that may be similar to, or duplicative of, services rendered as part of the Program and paid for directly through the Program Fees. The CIO may determine to invest in shares of or interests in Non-traditional Funds (“NTFs”). NTFs are mutual funds and ETFs registered with the SEC that we classify as “Alternative Investments” as an asset class because their principal investment strategies utilize alternative investment strategies (including short selling, leverage and derivatives as principal investment strategies) or provide for alternative asset exposure as the means to seek their investment objectives. NTFs may not have the same type of non-market returns as other types of Alternative Investments since NTFs have a relatively liquid and accessible structure with daily pricing and liquidity, are subject to a more structured regulatory regime and offer lower initial and subsequent investment minimums. The fees and expenses incurred by any constituent Fund purchased for you through the Program may be in addition to certain of the expenses covered by the Program Fee. Among other services provided, we or our Affiliates may effect transactions for any of these constituent Funds, and any compensation paid to us or our Affiliates by the mutual funds, or their Affiliates, is in addition to the Program Fee. Due to the additional economic benefit to us or our Affiliates when assets in your Account are invested in a mutual fund, a conflict of interest exists. See Item 9 at “Offering of Investments or Programs Managed by Us or our Affiliates.” Securities-based Lending with your Account. You may take action to make Account assets “pledged” or used as collateral (if we consent) in connection with loans you obtain through certain Affiliated or unaffiliated loan programs, such as, the securities-based lending Loan Management Account® and Mortgage 100®/Parent Power® mortgage programs (“Lending Programs”). Risks to your Account may be heightened in the event you pledge your Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. The lender has the right to protect its own commercial interests and to take actions that adversely affect the management of your Account and related performance. Regardless of whether the lender is us or our Affiliate or a third-party lender, the lender’s lien is senior to any rights we may have on the assets in the Account. As such, the lender has the right to sell securities in the Account that serve as collateral, if needed. Neither you nor any of us (including our Affiliates), if applicable, may be provided with prior notice of a liquidation of securities or transfer of interests in your pledged Account. Furthermore, neither you nor we are entitled to choose the securities which are to be liquidated or transferred by the lender. Voting Client Securities You have the right to vote proxies for securities held in your Account and will retain proxy voting authority for such securities. You cannot delegate to us and we do not accept or assume any proxy voting authority for securities held in your Account. Item 7. Client Information Provided to Portfolio Managers As part of the enrollment process, we elicit information about your financial circumstances, risk tolerance, time horizon and other relevant information relating to your Account. In managing your assets, we rely on information you provide, and it is your responsibility to notify us promptly of any updates to such information. You can do this by updating your Account information through the Program Website or by phone at 888.654.6837. In the Agreement, you represent to us that you have provided us and will provide us with information that is accurate and complete. It is your responsibility to notify us promptly of any material changes to the information you furnish to us. Failure to do so could affect the suitability of the services being provided under the Program. We are not required to verify the accuracy of the information. Item 8. Client Contact with Portfolio Managers We will make one or more of our advisory or investment personnel reasonably available for consultation with you if you request. Item 9. Additional Information Disciplinary Information The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part1 of Merrill’s Form ADV at: adviserinfo. sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program Merrill Guided Investing with Advisor Program Brochure | 28 MGI-A 032125 and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease- and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self- reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’ remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease- and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. Other Financial Industry Activities and Affiliations Merrill, an indirect wholly owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through its Affiliate, BofA Securities, Inc., it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. MAA, an indirect wholly owned subsidiary of BofA Corp., is a registered investment adviser that provides investment advisory services to clients that enroll in the Program and other investment advisory programs, including the IAP, MEAA and MGI. As registered investment advisers, Merrill and MAA complete Form ADVs, which they publicly file with the SEC (available at adviserinfo.sec.gov). For purposes of Form ADV Part 2, certain MLPF&S and/or MAA management persons are registered as registered representatives or associated persons of Merrill. In the future, certain MLPF&S and/or MAA personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of Merrill to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, including us, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include: (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning, asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit- taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research, including about global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act, and additional information about BofA Corp. can be found in publicly available filings with the SEC. Conflicts of Interest and Information Walls Merrill, MAA and their parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. Merrill Guided Investing with Advisor Program Brochure | 29 MGI-A 032125 organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflict arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within the BofA Corp. organization possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., BofAS, MLPF&S and MAA and their Affiliates evaluates its respective business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. Code of Ethics Each of MLPF&S and MAA has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering its personnel who are involved in the operation and offering of investment advisory services under the various investment advisory programs for which they are a registered investment adviser. Each Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that each of MLPF&S and MAA follows in conducting its respective business with integrity and professionalism. Each Code of Ethics covers requirements relating to employees complying with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. Covered personnel must certify to the receipt of the Code of Ethics. The Merrill Investment Adviser Code of Ethics is available at mymerrill.com/ ADV/materials or we will provide a copy of each Code of Ethics to you upon request. MLPF&S and MAA have each imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions, as well as those of all our employees. Our requirements impose certain responsibilities on Program Advisors and their trading. They are permitted to participate in block trades along with their clients and/or other Program clients. Compensation, Conflicts of Interest and Material Relationships Compensation and Benefits to Merrill, Program Advisors and Merrill Management Personnel. Merrill earns revenue from the Program Fee you pay. Merrill also earns revenue from other fees and payments you may make, including commissions, mark-ups and mark-downs, up-front sales charges and other sales charges and fees paid in connection with brokerage transactions (collectively, “Sales Charges”) and from what it receives from Affiliates and from third-party investment managers, fund managers and product distributors and sponsors (“Third-Party Firms”) related to transactions in your Account. We (including our Affiliates) and the Program Advisors whom you interact with and other of our employees benefit from the fees and charges paid by you and other clients for the Services described in this Brochure. In addition, we earn revenue from the referrals to Affiliates (including referring to an Affiliate for banking products or services). The revenue Merrill receives from Third-Party Firms is not part of the Program Advisor’s compensation. Separate and apart from the Program, we through our Program Advisors, may suggest or recommend that clients, including Program clients, use our brokerage account, execution and custody or other services for investment activity, or such services of an Affiliate. Similarly, our Program Advisors may suggest or recommend that you purchase our products or our Affiliates’ products. When you engage in brokerage activities and/or you use or purchase Merrill’s or our Affiliate’s services or products, you pay Sales Charges that compensate us and/or our Affiliates. Opening a brokerage account and engaging in transactions generates Sales Charges that result in revenues to us and compensation and/or benefit to our financial advisors including Program Advisors. Note, as described below, Program Advisors are not compensated based on transaction-based revenues. The more trades that you make in your brokerage account, the more we get paid, creating a financial incentive to recommend transactions in your brokerage account. The amount of revenue we receive varies depending on the type of account relationship you have with us—whether your Account is enrolled in the Program or is a brokerage account and the investment products in which you invest and the services you use. These differences create a conflict of interest in that there is a potential financial incentive for a Program Advisor to recommend certain investment advisory programs, services or products based on the revenues to Merrill. The revenue we receive from your enrollment in the Program may also be more or less than the revenues that would be received if you had instead participated in our other of our investment advisory programs or if you had engaged in the investment activities in a brokerage account. If there are higher revenues to us, a Program Advisor has a financial incentive to recommend certain investment strategies to you or recommend this Program over other programs or other services offered by us or our Affiliates. The more assets there are in your Account, the more you will pay in fees, creating a financial incentive for us to recommend that you increase the assets in your Account. In the Program, we make more revenue based on the level of assets in the Account as well as the level of the Program Fee. Program Advisors receive compensation from MLPF&S in the form of a base salary and certain incentive awards related to the amount invested in the Program and in other advisory accounts. Having Accounts enrolled in the Program helps Program Advisors meet certain performance goals. However, Program Advisors do not receive a portion of the Program Fee as compensation and do not receive transaction-based compensation. As Merrill revenue increases, there is a potential that a Program Advisor’s compensation will be positively impacted. This means that a Program Advisor has a financial interest in recommendations about your relationship that generate higher amounts of revenue for Merrill, rather than those transactions that generate lower amounts of revenue. Program Advisors are eligible to participate in incentive and recognition programs that are based on meeting certain performance and service goals and such other criteria as Merrill may establish from time to time. Merrill considers and approves its compensation program from year to year and its compensation criteria can change that will impact compensation paid to Program Advisors. Having a compensation award based on meeting criteria based on client investment activity and engaging with Merrill’s or its Affiliate’s financial and banking-related services presents a conflict of interest between the Program Advisor and you because it could lead to such activity being promoted by your Program Advisor to qualify for the compensation award or to avoid the reduction in their incentive compensation. Merrill Guided Investing with Advisor Program Brochure | 30 MGI-A 032125 Our Program Advisors may recommend that you utilize the banking products and lending services of BANA or purchase products or services of our Affiliates. In addition, they may refer clients to BANA and other Affiliates for financial services that they provide, including transaction execution and investment banking services and products (including banking products). Similarly, employees of BANA, BofAS and other Affiliates may refer clients to Merrill for brokerage and investment advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. If a Program Advisor refers a client to BANA or other Bank Affiliates to establish a bank account directly with the bank, Merrill receives a payment directly from each Bank Affiliate based on the daily deposit balance held by the Bank Affiliate. The amount of the payment made to Merrill varies from time to time and varies based on the Bank Affiliate. We may waive all or part of this payment. These referrals result in a conflict of interest because Merrill and our Program Advisors are incentivized to introduce products or financial, banking and lending services that provide us or our Affiliates additional compensation. Program Advisors have a financial incentive to recommend or complete the rolling over assets (a “rollover”) from an employer-sponsored retirement plan (such as a 401(k) plan) or from a retirement account at another firm into an Individual Retirement Account (IRA) or other similar account. This is because transactions in the rollover IRA will generate either investment advisory fees if that account is enrolling the Program, Sales Charges if a brokerage account and other compensation that benefits Merrill and the Program Advisor. Program Advisors have a financial incentive to recommend a rollover because the subsequent or related enrollment into the Program will increase the number of accounts serviced by the Program Advisor and help them achieve certain performance goals. Elements of our field management compensation are based on revenues to Merrill and based on the Program Advisors whom they manage meeting performance and service goals and such other criteria as Merrill may establish from time to time. Management personnel and other employees of Merrill, MAA and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is an incentive for our field management team to encourage Program Advisors to meet their performance and service goals that can result in more revenue to Merrill. There is a financial incentive for management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. We address conflicts of interest related to Merrill benefits and Program Advisor compensation and other financial incentives described in this section and throughout the Brochure in a variety of ways, including by requiring clients to affirm their interest for the Program and products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices and account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, Program Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest – both those arising between and among Accounts as well as between Accounts and our business. We maintain policies and procedures and supervisory and review processes, including governance approval requirements, that are designed to review and mitigate any financial incentive or conflict to favor any one security type or investment product or service. We also provide disclosures of these conflicts in the Brochure and other client documents. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. Account and Program Choice Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Clients have the ability to enroll accounts in the Program holding some or all of their investment assets and to have brokerage accounts for some or all of their assets. The various programs we offer and ways to interact with Merrill are outlined in our Form CRS, this Brochure and in the Summary of Programs and Services. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. There are differences among the programs and account relationships. You may be able to obtain the same or similar Services or types of investments you obtain in the program through a brokerage account or other investment advisory programs and services offered by Merrill. These may be available at lower, higher or the same fee that you pay in the Program. You may also be able to obtain some or all Services from other firms and at fees that may be lower or higher than the Program Fee we charge. A recommendation of the type of account relationship creates a conflict of interest for us. The amount of revenue we receive depends on the type of account and relationship you choose. In the Program, you will pay the Program Fee. The Program Services include ongoing investment advice and guidance for your Account, access to investment strategies and ongoing monitoring as described in this Brochure, as well as the services of trade execution, clearance and settlement of transactions and custody of assets. In the Program, the amount of compensation paid to us depends on the level of assets in your Account and the Program Fee, as well as certain indirect compensation outlined in this Brochure. In a brokerage account, you will pay per trade Sales Charges to purchase and sell securities. The amount of brokerage revenues we receive depends on the level of trading activity in the Account, the applicable Sales Charges as well as other indirect compensation. Your brokerage account agreement and documents will provide you with information about certain brokerage services and related transaction and account fees for your Merrill account. You could pay higher or lower fees in a brokerage account than from an account enrolled in the Program depending on the Sales Charges, frequency of trading and the investment products for investment and other factors. Certain Strategies are available to you outside of the Program for more or less than you would pay in the Program. When you compare the account types and investment advisory programs and their relative costs with what is available in the Program, you should consider the various factors outlined in “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Certain of these factors relate to your preferences regarding the relationship, whether you are seeking ongoing monitoring services provided for in the Program, how you want to pay for investment services, the Program Fee, the level of service and the managed investment solutions you are interested in investing in. A recommendation of the type of account relationship creates a conflict of interest for us and a Program Advisor. We address the conflicts of interest regarding program and account choice through our account profiling and enrollment process, through the disclosure in this Brochure and the Agreement and by providing clients with upfront information about our available programs. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Merrill Guided Investing with Advisor Program Brochure | 31 MGI-A 032125 Moreover, our Program Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. Variable Compensation by Product and Service We select the investment solutions that are available in the Program and the investment products and solutions that are available in a brokerage account based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and consistency of the execution of their strategy within the respective arrangement. The revenues we receive from a securities transaction vary based on the type of security or investment product and its terms. For certain securities or investment products, Third-Party Firms make payments to us as compensation for various services and support. These payments also vary depending on the type of security or investment product. Not all securities and investment products make payments to us or our Affiliates and not every investment solution is available in the Program. The variable nature of third-party payments creates a conflict of interest because it provides an incentive to utilize products for which Merrill receives third- party payments or is more highly compensated by the product provider over those where we do not receive such payments or higher compensation. We address this conflict through the disclosure in this Brochure and by selecting Funds based on the investment merits of the particular investment products and not based on the compensation from Third-Party Firms. Program Advisors do not have an incentive to recommend certain Strategies over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we select investment products and solutions that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. For additional information, please review the sections “Compensation Received by Us for Sub-accounting Services,” “Mutual Fund Arrangements and Compensation,” “Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Other Compensation Received by Us and Our Affiliates” below. Offering of Investments or Programs Managed by Us or Our Affiliates We and our Affiliates offer their own managed products or wrap programs that are similar to this Program or other Merrill programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including as to recommendations and review determinations. This is due to, among other things, the differing nature of our Affiliate’s investment advisory services and differing processes and criteria upon which determinations are made. We and our Affiliates may provide some or all of the same services offered in the Program through other firms, affiliated or unaffiliated with us, which offer programs similar to the Program at fee rates that may differ from the Program Fee. We do not currently offer any Related Funds; however, we may include Related Funds as an investment product available in the Program in the future. If a Related Fund is offered as an eligible investment in the Program, we would benefit from our economic interest in such Strategy or Related Fund. We would address these conflicts by disclosing them in this Brochure. Separate and apart from the Program, a Program Advisor may suggest or recommend that you use the Merrill brokerage account and our execution and custody or other services for other of your investment activity or use the services of our Affiliates. Similarly, a Program Advisor may suggest or recommend that you purchase our products or those of our Affiliates. Where you use or purchase our or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Our personnel will, as permitted by applicable law and our policies, receive compensation (the amount of which varies) in connection with these products and services. We address the conflicts of interest presented by these Affiliate transactions by having in place various policies and procedures reasonably designed to prevent the receipt of compensation by Merrill and its Affiliates and other business arrangements from affecting the nature of the advice we provide, although such policies and procedures do not eliminate such conflicts of interest. Compensation Received by Us for Sub-accounting Services We only make available in the Program mutual funds and money market funds (each, a “fund”) that pay us to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges, dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under agreements with each of these funds (or their respective principal underwriter or other agent), we provide daily sub accounting services to the holders of these funds maintaining shares in an Account as well as in other Merrill securities accounts and receive the agreed-upon sub-accounting services fee. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by fund types, fund and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. Due to applicable regulation, we do not retain compensation for sub-accounting services for funds held in Retirement Accounts. The sub- accounting service or distribution fees received from the mutual fund or a fund service provider or its Affiliate relating to mutual fund or other securities holdings in a Retirement Account will be credited to the Retirement Account on a periodic basis. Depending on the specific arrangements, we will receive sub-accounting services fees from or on behalf of the mutual fund of either an asset-based fee up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For money market mutual funds, the sub-accounting services asset-based fee is generally 0.005% per annum. We have a conflict of interest in selecting certain fund products (or share classes) for inclusion as part of the Strategies available to you. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of the Strategies but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting services fees that we charge will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the sub- accounting services fees paid for these services varies among funds and, in certain instances, between share classes of individual funds. This results in a conflict of interest because it creates an incentive for us to recommend that you invest in funds and share classes that pay higher fees. We will receive higher sub-accounting fee payments from fund families that have higher fund assets held in our clients’ accounts because the service fee calculation is based off of the level of the asset holdings. Additionally, there is a benefit to us because the aggregate Merrill Guided Investing with Advisor Program Brochure | 32 MGI-A 032125 amount of the sub-accounting fees exceeds the costs to provide these services. We address these conflicts of interest in the following ways. We disclose the nature of our sub-accounting service arrangements. We also determine the compensation paid to our Program Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Program Advisors do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we and our Affiliates select funds that are available through the Program as well as in our brokerage accounts and in other of our investment advisory programs based primarily on the CIO Review Process and business reviews. Mutual Fund Arrangements and Compensation For constituent mutual funds that are part of a Strategy, your assets are generally invested in the lowest cost share class available to you for a mutual fund available in the Program. The Program-eligible fund share classes vary depending on the fund, its roster of share classes and our agreements with the funds. In general, the share classes that are eligible for the Program do not have annual asset based fees like Rule 12b-1 fees, although there are some mutual funds available in the Program that have such fees due to share class availability or legacy positions that are pending conversion to an eligible share class. Certain mutual funds offer a fund share class that does not include a sub-accounting services fee. Accordingly, you should not assume that you will be invested in the share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. In addition, the share class of money market funds available will not necessarily be the lowest cost share class available from the money market fund. It is generally in your best interest to purchase lower-fee share classes because your returns are not reduced by additional fees and expenses. For clients in the Program, neither the CIO who manages the Strategies’ models nor the Program Advisor has an incentive to recommend or select share classes that have higher expense ratios because their compensation is not affected by the share class selected. From time to time a fund may authorize us to make available to clients participating in the Program a class of shares of such fund with a lower fee structure that we believe is more beneficial to you than the class of shares previously made available in the Program. Where such exchange is available, under the authority provided to us under the Agreement, we will effectuate an exchange to the other class of shares of this Fund with the lower fee structure as promptly as practicable. For additional information on mutual funds and money market funds you can review our “Mutual Fund Investing at Merrill” document which is accessible on the Program Website or at ml.com/funds or upon request. Cash Sweep Program Compensation Received by Us and Our Affiliates Merrill benefits financially when your cash balances are held in the bank deposit accounts affiliated with the Cash Sweep Program. Merrill receives payments from our Bank Affiliates on a per account basis for each account that sweeps to one of our Bank Affiliates relating to offering and supporting the Cash Sweep Program. The fees we receive from the Bank Affiliates is one of many factors that affect the interest rate paid by the Bank Affiliates on your swept cash balances under the Cash Sweep Program. If you choose the “No Sweep” option, we also benefit from the custody or use of uninvested cash balances also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. For deposits unrelated to the Cash Sweep Program to our Bank Affiliates relating to referrals from a financial advisor, we are entitled to receive a fee directly from each Bank Affiliate based on the daily deposit balance, which fee can be waived in whole or in part. For referrals made by a Program Advisor resulting in a bank deposit account with a Bank Affiliate, we are entitled to receive a fee directly from each Bank Affiliate based on the daily deposit balance, which fee can be waived in whole or in part. The Bank Affiliates benefit financially from the Cash Sweep Program. Through the Cash Sweep Program, they receive a stable, cost-effective source of funding. They use the cash funds deposited in the bank deposits to fund their current and future lending, investment and other business activities. The participation of the Bank Affiliates in the Cash Sweep Program increases their respective deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” they earn on the deposits—the difference between the interest paid on the bank deposits and other amounts paid to Merrill related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in your Account (a result of a recommendation from the CIO) that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more our Bank Affiliates benefit. Cash balances swept to a bank deposit account of our Bank Affiliates under the Cash Sweep Program will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts is periodically set and reset by the Bank Affiliates in their discretion. Interest rates for the MLBD Program and RASP are tiered based upon your relationship with Merrill and Accounts that enroll in the Program and in specified Merrill investment advisory programs receive the highest tier rate available under the Cash Sweep Program. The interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. We address the conflicts of interests associated with the Cash Sweep Program and the deposit accounts in a variety of ways, including through disclosure in this Brochure, by requiring clients to affirm their interest for the Cash Sweep Program options in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to your participation in the Cash Sweep Program. We have adopted various policies and procedures reasonably designed to prevent the cash sweep arrangement compensation and other business arrangements from affecting the nature of the advice we and our financial advisors provide. Other Compensation Received by Us and Our Affiliates Where permitted by law, Merrill may execute certain transactions on a principal basis through itself or its Affiliates. Transactions that are considered principal transactions include those trades executed in a principal capacity whereby our Affiliate acts as your trade counterparty and/or acts as a market maker for, or has a proprietary position in, the securities that are the subject of the transaction. We and our Affiliates receive compensation in connection with principal transactions, including markups, markdowns, underwriting discounts, selling concessions and other compensation. We can profit from transacting as your counterparty or having proprietary positions in the subject securities. Moreover, we have an incentive to recommend a transaction in a security that our Affiliate maintains in inventory that is otherwise difficult to sell. Where not prohibited by law, Merrill may engage in agency cross transactions when it acts as agent for both buyer and seller in a transaction. If this type of trading execution occurs, since Merrill generally receives Merrill Guided Investing with Advisor Program Brochure | 33 MGI-A 032125 compensation from each party to an agency cross transaction, there is a conflict of interest between our obligations to you and to the other party to the transaction. Third-Party Firm Business Relationships and Support We and our Affiliates have business relationships with Third-Party Firms. We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for funds and product vehicles managed or sponsored by them (e.g., mutual funds and ETFs). We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates by a Third-Party Firm is additional compensation to us for services we and our Affiliates provide. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Program Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our Program Advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, we select Strategies and Funds that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our financial advisors provide. Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (“Conferences”) for invited Merrill financial professionals. These financial professionals include financial advisors including Program Advisors, employees who work for a Merrill branch, market or division to support the financial advisors (Field Management Employees) and employees who cover product, CIO and home office support functions (Non- Field Employees). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third-Party Firms participate (“Client Events”). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending financial advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with holding such Conferences and Client Events in the amount of approximately $21 million from participating Third-Party Firms. Certain Third-Party Firms periodically host or participate in meetings (“Manager Meetings”) where they provide certain financial advisors (which can include Program Advisors), Field Management Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending financial advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third- Party Firms in support of charitable events and causes that we requested or initiated with the Third-Party Managers in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives to recommend products of participating Third-Party Firms. They give those participating in Conferences, Client Meetings, Manager Meetings and charitable events with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for Field Management Employees to approve those recommendations and for non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our financial advisors, including Program Advisors, to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Management Employees to approve their financial advisors’ (including Program Advisors) recommendations of products and services of those participating Third-Party Firms. Furthermore, we do not incentivize Non-Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. Third-Party Firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs of Conference and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Representatives of Third-Party Firms will, from time to time, meet and work with our financial advisors and other employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third- Party Firms from providing or paying for, and our financial advisors and other employees, from receiving, gifts and entertainment (including meals) other than as permitted by and subject to the limits established under Merrill internal policies. In general, they may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Merrill Guided Investing with Advisor Program Brochure | 34 MGI-A 032125 Permitting Third-Party Firm representatives access to our financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to take certain action in favor of the investment products of those Third-Party Firms. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. Provision of Diversified Financial Services by Us and our Affiliates BofA Corp. is a diversified financial services company that generally seeks to provide a wide range of services to retail and institutional clients for which it receives compensation. As a result, we, BofA Corp. and our Affiliates can be expected to pursue additional business opportunities with the entities whose investments Merrill and its Affiliates make available through the Program. Consistent with industry regulations, these services that we and our Affiliates provide include banking and lending services, sponsorship of deferred compensation and retirement plans, recordkeeping services, investment banking, securities research, institutional trading and prime brokerage services, custody services, investment advisory services, licensing arrangements involving indices and effecting portfolio securities transactions for our clients. In addition, from time to time, BofA Securities, Inc. and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships is publicly available in Regulation NMS Rule 606 reports we file with the SEC. From time to time, Merrill may offer to clients or potential clients certain promotions or rewards in connection with opening, maintaining or adding assets to a Merrill securities account. Such promotions or rewards may include, by way of example, the payment of a cash reward. The promotions may require a client to request to receive or participate in the promotion or reward, and/or require a client to meet various eligibility criteria. While these promotions or rewards may extend to a client’s Merrill securities account that holds assets in the Program, participation in the Program is not a condition for these promotions or rewards. Participation or Interest in Client Transactions and Conflicts of Interest There are various ways that we can be viewed as participating or having an interest in client transactions. These situations and any conflicts of interest arising from such activities, execution approach or other capabilities we offer in the Program are discussed in this section and throughout the Brochure. Cash Balances and Cash Sweep Program. The Sweep Program Guide for Merrill Clients provides information on the fees that Merrill receives from the Bank Affiliates for each account, including a Program Account, that sweeps to the MLBD Program and the RASP Program. These fees are up to $100 per year for each account received from the Bank Affiliates. This compensation is subject to change from time to time, and Merrill may waive all or part of it. Merrill may benefit from the possession or use of cash balances, also known as free credit balances, in your accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. As further described in “Item 4 Funding and Operation of Accounts-Cash Balances,” cash balances may be held in your Account for a number of different reasons, including as part of a Strategy’s asset allocation to cash or to support recurring withdrawals, including Cash Withdrawal Allocation for an Account with an Income-Focused Goal. To the extent Merrill through its CIO does not select a cash alternative for your Account’s cash allocation, there is a conflict of interest between you and us because the cash allocation will be maintained in your Account as a cash balance and automatically swept to the bank deposit account of our Bank Affiliates. Please see “Item 9 Compensation, Conflicts of Interest and Material Relationships-Cash Sweep Program Compensation Received by Us and Our Affiliates.” Participation in Affiliate Lending Programs and Margin. There are conflicts of interest when you use a loan from Merrill or one of its Affiliates secured by your Account assets as collateral. These conflicts exist with any of our Affiliate lending programs that may be available to you from our Affiliate lender in the case of a loan from our Affiliate, including but not limited to the Loan Management Account® product (“LMA® account”), the Affiliate lender intends to derive a profit as lender based on interest and/ or fees, if any, charged on the loan. The lender, whether it be Merrill or its Affiliate, has a lien on your Account assets that are used as collateral for the loan. The lender will act to protect itself as lender in connection with the loan, and this may be contrary to your interests and/or investment objectives. Please refer to “Item 6 Investment Strategies and Risk of Loss” for additional information. Activity by Merrill, Affiliates and Personnel. As part of a global financial services firm, Merrill will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by Merrill or any of its Affiliates, its or its Affiliates’ roles in connection with other clients and in the capital markets, its internal policies, and/or potential reputational risk. As a result, client accounts managed by Merrill may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by BoA Corp. We and our Affiliates act in a variety of capacities to a wide range of clients. From time to time in the course of those duties, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. See”Conflicts of Interest and Information Walls” in this Item 9. Similarly, we may give advice or take action with regard to certain clients, including clients in the Program, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken for certain securities, mutual funds, ETFs or investment managers. In some instances, the actions taken by our Affiliates for similar services and programs may conflict with the actions taken by us. This is due to, among other things, the differing nature of our Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. In addition, potential conflicts of interest also exist when Merrill maintains certain overall investment limitations on positions in securities, Funds or other financial instruments due to, among other things, investment restrictions imposed upon Merrill or its Affiliates by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude, the inclusion of particular securities, Funds, or financial instruments in a client’s Account where Merrill or MAA provide discretionary management services, even if the securities or financial instruments would otherwise meet the investment objectives of such Account. We and our Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs by us, our Affiliates and those of our clients that have granted discretion to us, our Affiliates and/or Merrill financial advisors (“discretionary clients”) Merrill Guided Investing with Advisor Program Brochure | 35 MGI-A 032125 to avoid potential restrictions on our ability and our Affiliate’s ability to engage in principal trading and other transactions with such funds. Registered Funds identified by us for these limitations from time to time are referred to as “In-Scope Funds.” A portion of the aggregate ownership limit is attributed to our Affiliates. When we and our Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to us, or our Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because our and our Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest for us in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. From time to time, however, a Fund selected for a Strategy may invest in securities issued by BofA Corp. or its Affiliates in seeking to achieve its investment objective. Any such investments by a Fund are required to comply with the applicable provisions of the Investment Company Act, including limitations on investments in securities-related businesses, and will not be influenced by MLPF&S or MAA. From time to time, a shareholder of BofA Corp. could acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Account, such as buying or selling securities issued by the shareholder or its Affiliates, will be limited. The CIO releases information and analyses about a Strategy or a constituent Fund covered under its CIO Review Process to Merrill, MAA, and our Affiliates at the same time and BofA Global Research releases its research opinions and research reports to the public at the same time as Merrill, MAA and our Affiliates receive it. It is possible that our Affiliates and other investors act on that information before Merrill or MAA have had the chance to evaluate and act on those changes. Accounts that commence trading after the release of such information will be subject to price movements that would cause them to receive prices that are less favorable than those potentially obtained by our Affiliates or other investors. We address these conflicts in a variety of ways. We disclose these arrangements and conflicts in this Brochure. In addition, we have our policies that require our Program Advisors to recommend investment advisory programs, investment products and securities that are suitable for each client based upon investment objectives, risk tolerance and financial situation and needs. We also have a variety of restrictions, procedures and disclosures designed to address actual or potential conflicts of interest – both those arising between and among Accounts as well as between Accounts and our business (e.g., personal trading preapprovals, self-reporting, restrictions on our personnel detailed in our policies and procedures and Code of Ethics). We have also adopted various policies and procedures reasonably designed to prevent the receipt of any referral compensation and other business arrangements from affecting the nature of the advice we and our Program Advisors provide, although such policies and procedures do not eliminate such conflicts of interest. Trade Execution. We or our Affiliate may execute transactions in your Account on a principal basis (that is, when we or our Affiliate sell a security to you, or buy a security from you, for our own account) as permitted by law, and upon your consent (when required by applicable regulations). Principal transactions may give you access to investment opportunities or trade executions that might not otherwise be available to you, such as trading of fractional shares within your Account. Principal transactions may not be effected for Retirement Accounts, except in accordance with applicable law. There are conflicts of interest present when we execute transactions in your Account on a principal basis. If Merrill effects a principal transaction for your Account, then in addition to the Program Fee, we or our Affiliates receive a commission, markup or markdown, underwriting fee or selling concession, or other compensation with respect to the transaction, which would result in additional compensation or other benefit to us or our Affiliate. We also receive a commission, markup or markdown, underwriting fee or selling concession, or other compensation with respect to the transaction, which would result in additional compensation or other benefit to us or our Affiliate. We also benefit from the “spread” or the difference between the price we pay for a security and the price at which we sell it to you, or between the price we may pay for a security that we may buy from you and the price for which we may later sell it. In addition, we have an incentive to recommend a transaction in a security that we maintain in our inventory that is otherwise difficult for us to sell. The receipt of additional compensation and an incentive to recommend a transaction involving our inventory present conflicts between our interest and yours. The types of securities that may be purchased or sold on a principal basis in your Account pursuant to the terms of your Agreement may change in the future and could become more limited. We may, at times, have the opportunity to act as agent for both buyer and seller in a transaction for your Account. This is called an agency-cross transaction. Since we generally will receive compensation from each party to an agency-cross transaction, there is a potential conflict between our responsibilities and loyalties to you and to the other party to the transaction. Any compensation we receive will be in addition to the Program Fee. The Agreement generally gives us permission to engage in agency-cross transactions for your Account, except where prohibited by law. You may revoke your consent at any time by notifying us in writing. At times, we may consider a security being sold by one investment advisory client to be appropriate for purchase by another investment advisory client account. In such cases, we may arrange to transfer or “cross” the security directly between the affected accounts. Any cross transactions in your Account would be effected in accordance with applicable law and your Agreement. Cross transactions generally will be effected at an independently determined market price and will not result in any additional compensation to us. For a Retirement Account that is subject to ERISA or the Code’s prohibited transaction rules, transactions, including agency-cross transactions, will be effected by or through Merrill or our Affiliates in compliance with ERISA Section 408(b)(19), U.S. Department of Labor Prohibited Transaction Exemption 86-128, or otherwise in a manner that is not prohibited by ERISA or the Code. We do not receive payment for order flow from liquidity providers to which we route our customer orders in equity securities. We directly or indirectly (through our Affiliates) receive rebates from, and pay fees to, certain registered securities exchanges for providing or taking liquidity on those exchanges, according to those exchanges’ published fee schedules filed with the SEC. In some cases, the rebates received by us from an exchange will, over a period of time, exceed the fees paid to the exchange. The rebates and payments from these third parties vary depending on the order and the exchange to which orders are directed and create a conflict of interest because we are incentivized to recommend transactions that provide us with greater rebates or payments from these exchanges. Covered Entities under the Volcker Rule. We may provide certain entity clients that qualify as “family wealth management vehicles,” or FWMV clients, with both the Program Services as well as lending services and engage, where permitted, in principal transactions. In doing so, we rely on the exception under the Volcker Rule implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Agreement. For certain entity clients that are deemed”covered fund” clients under the Volcker Rule, we are not permitted Merrill Guided Investing with Advisor Program Brochure | 36 MGI-A 032125 to offer both Program Services and the availability of margin, lending or other extensions of credit from us or any of our Affiliates, including BANA, or engage in certain principal transactions. Certain other transactions between BANA or its Affiliates and the entity client will also be prohibited. Account Reviews and Reporting An important part of the Program relationship involves providing you with the opportunity to engage in periodic reviews with your Program Advisor by means of the Program Website. These reviews provide updates on the progress of your Account, performance of your Account’s portfolio and other important information about your investments. This review is also an opportunity to ensure that the information you provide is complete, accurate and reflects your financial situation and objectives for the Accounts enrolled in the Program. We will contact you to request that you review your information for each of the Accounts in the Program and ensure that it is up to date. As noted above, if there are multiple owners on this Account, the information you provide should reflect the views and circumstances of all owners on the Account. If you are the fiduciary of this Account for the benefit of the account owner or account holder (e.g., the trustee for a trust or custodian for an UTMA), please keep in mind that these assets will be invested for the benefit of such account owner or account holder. A periodic review of your Account should typically occur on an annual basis; however, under our Program guidelines, we have the ability to extend or defer the timing of the review under certain circumstances and for certain periods of time. You will be required to perform your review through the Program Website with a Program Advisor. You may receive additional reminders through other means to complete your review through use of the Program Website. Because these reviews provide you with important and necessary information relating to your Account, you are required to take advantage of these opportunities to participate in Account reviews. If you do not participate in your Account review, we may, in our discretion, terminate your Account from the Program. We will periodically communicate to you important information about how we are managing your Account and assets in the Program. The primary means through which we will communicate with you and memorialize in writing the important terms, conditions and information about your Account and Strategy is through a Program Report which will be available on the Program Website. You will receive a Program Report from us after we accept your enrollment in the Program, when you make a Strategy change and when your Target Asset Allocation for your Account is changed. The information set forth in the initial and each subsequent Program Report is how we reflect the Services that we will provide to you with respect to the assets in your Account pursuant to the Agreement. You should review each Program Report we send to you carefully to ensure that the information reflected therein is accurate and you should contact us or update your information via the Program Website by contacting a Program Advisor if you believe any of the information is, or becomes, inaccurate. In addition to the Program Report, we will send you periodic updates that contain information about your Account, including trade confirmation information and account statements. We will also provide you with performance information online through the Program Website to help you monitor and assess the performance of your Account and the Strategy you select. This includes information regarding investment return, risk and selected benchmark comparisons for your Account assets in the Strategy you select. You should review all such materials carefully and promptly report any discrepancies to us. Referrals and other Arrangements Our Program Advisors are not permitted to give to you or accept from you any fee, kickback, or other thing of value, including a Program Fee Rate reduction, gifts, meals, or entertainment pursuant to any agreement or understanding, oral or otherwise, for receiving or referring business. Our employees may refer advisory clients to BANA, BofAS and other of our Affiliates for products and services. Similarly, employees of BANA and its Affiliates may refer clients to MLPF&S for brokerage and investment advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. Merrill financial advisors may receive compensation for referrals to the Program. We have entered or may enter into marketing arrangements with third parties who, for compensation, will provide consulting or other services to us in connection with marketing our various advisory programs. Each such marketing arrangement is or will be governed by a written agreement between us and the third party, and will be disclosed to you, as required by law. Financial Information Not applicable because (1) Merrill is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act (2) Merrill and MAA do not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (3) there is no financial condition of which we are aware that is reasonably likely to impair Merrill’s or MAA’s ability to meet contractual commitments to its clients; and (4) Merrill or MAA each has not been the subject of a bankruptcy petition at any time during the past 10 years. Merrill Guided Investing with Advisor Program Brochure | 37 MGI-A 032125 Glossary “Account” means the securities account to which the Agreement applies and that is enrolled in the Program, as set forth in the Program Report. “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Affiliate” means a company that is controlled by, in control of, or under common control with another company. “Agreement” means the Agreement for the Program among the client, MAA and MLPF&S, as it may be amended from time to time. “Allocation Profile” means the allocation of assets to one or more asset classes that is based on certain information you provide for your Account as part of the Online Profiling Process and through the Program Website. Hypothetical projections are calculated based on a goal’s Allocation Profile. “Bank Affiliate” means Bank of America, National Association (BANA) or other banks that are affiliated with us. “BofAS” means BofA Securities, Inc., an Affiliate of Merrill. “Cash Sweep Program” means the program provided as part of your brokerage account agreement whereby cash balances in your Account are automatically swept into a cash sweep option available for your Account type. “CIO” means the Chief Investment Office of MLPF&S. “Code” means the Internal Revenue Code of 1986. G L O S S A R Y “Constituent Fund” or “constituent Fund” means a registered investment company, including a mutual fund and an ETF that comprise a Strategy. “Effective Date” means the date the account’s enrollment in the Program is accepted by Merrill. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “FDIC” means the Federal Deposit Insurance Corporation. “FINRA” means the Financial Industry Regulatory Authority, Inc. “Investment Company Act” means the Investment Company Act of 1940, as amended. “MGI” means Merrill Guided Investing, an investment advisory program with online self-guided interactive website access. “MLBD Program” means the Merrill Lynch Bank Deposit Program. “NTF” means a nontraditional mutual fund or ETF registered with the SEC that is classified as an Alternative Investment by us because its principal investment strategies utilize alternative investment strategies or provide for alternative asset exposure as the means to seek to meet its investment objectives. “Program” means Merrill Guided Investing with Advisor, the investment advisory program described in this Brochure. “Program Report” (also referred to as a Portfolio Summary) means a periodic communication sent to you electronically that contains important terms, conditions and information about your Account and Strategy. “Program Website” means merrilledge.com/guided-investing. “RASP” means the Retirement Asset Savings Program. “Reasonable Investment Restrictions” means one or more reasonable investment restrictions accepted by us that you would like to impose for your Account, such as identifying a mutual fund or ETF that should not be purchased. “Registered Fund” means a fund registered under the Investment Company Act. “Related Fund” means any Fund sponsored, managed, or advised by us or any of our Affiliates. “Retirement Account” means an individual retirement account within the meaning of Section 408(a) of the Code, a simplified employee pension within the meaning of Section 408(k) of the Code, a simple retirement account within the meaning of Section 408(p) of the Code, and a Roth IRA within the meaning of Section 408A of the Code. “SEC” means the U.S. Securities and Exchange Commission. “Services” means the services provided through the Program described in this Brochure. “Strategy” means an investment strategy developed by the CIO to align to a particular Target Asset Allocation. “Third-Party Firms” means third-party investment managers, fund managers, product distributors and sponsors, insurance companies and other product providers. “Unaffiliated Trade Counterparty” means a bank, broker or dealer other than Merrill or a Merrill Affiliate. L-03-25 Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. ©2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated. Printed in the U.S.A. Merrill Guided Investing with Advisor Program Brochure | 38 MGI-A 032125

Managed Account Advisors LLC Merrill Lynch, Pierce, Fenner & Smith Incorporated FORM ADV PART 2A BROCHURE Managed Account Advisors LLC 101 Hudson Street Jersey City, NJ 07302 201.557.0504 Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 800.637.7455 ml.com This Brochure provides information about the qualifications and business practices of Managed Account Advisors LLC (“MAA”) and Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or “Merrill”). If you have any questions about the contents of this Brochure, please contact us at 201-557-0504. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about MAA and Merrill also is available on the SEC’s website at www.adviserinfo.sec.gov. , MLPF&S , Bank of America, N.A , or Bank of America Corporation (“ BofA The advisory services described in this Brochure are not insured or otherwise protected by the Federal Deposit Insurance Corporation or any other government agency; are not a deposit or other obligation of or guaranteed by MAA Corp.”) or any of their affiliates; and involve investment risk, including possible loss of principal. March 21, 2025 Investment products: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value MAA-MerrillSPS-03-2025 ITEM 2 MATERIAL CHANGES On March 22 2024, Managed Account Advisors LLC filed its last annual update for its Form ADV Part 2A brochure. This summary of material changes is designed to make clients aware of information that has changed since the brochure’s last annual update or that may be important to them. It also sets forth changes as well as enhancements made in this annual update. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We have amended the disclosure to add Merrill Lynch, Pierce, Fenner and Smith Incorporated as an investment adviser with MAA covered by this Form ADV Part 2A brochure (the “Brochure”). As described in the Brochure, these changes relate to the role of the CIO and Merrill investment professionals in providing to MAA investment recommendations for certain Related Strategies in the form of model portfolios or other investment guidelines and/or instructions. We have made changes throughout the Brochure to refer to Merrill and its advisory services, including the cover page, “Item 4 Advisory Business,” “Item 6 Performance-based Fees and Side-by-Side Management,” “Item 8 Methods of Analysis, Investment Strategies and Risk of Loss,” “Item 9 Disciplinary Information,” “Item 10 Other Financial Industry Activities and Affiliations,” “Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading,” “Item 15 Custody,” “Item 17 Voting Client Securities” and “Item 18 Financial Information.” Information regarding the changes made to Items 9 and 11 is also included below. The Brochure relates to MAA and Merrill with these updates. • We have amended “Item 9 Disciplinary Information” to provide a summary of certain disciplinary events relating to Merrill as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a mark-up or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total 2 MAA-MerrillSPS-03-2025 advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’ remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. On June 16, 2014, MLPF&S, without admitting or denying the findings, entered into a FINRA settlement relating to its failure to have an adequate supervisory system to ensure that certain clients received sales charge waivers for purchases of certain mutual funds’ Class A shares, which affected certain retirement accounts and certain clients with a particular type of brokerage account. This settlement resulted from MLPF&S self-identifying certain of these issues. MLPF&S consented to the imposition of a censure and a fine of $8 million and agreed to provide additional reimbursement to the agreed upon impacted clients. It has reimbursed all such impacted clients.” • We updated “Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” to create a new subsection entitled “Offering of Related Strategies and Use of a Related Strategy in a Client’s Account” to consolidate existing disclosure related to the offering of Related Strategies in the Program. • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to financial professionals, including Representatives and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading—Relationship with Asset Managers, Sponsors and Style Managers.” • We have updated disclosure to describe that MAA is the Style Manager for a suite of equity Related Strategies that are developed based on investment models and lists published by its Affiliate, BofA Global Research. Additional information about each of these Related Strategies is available in the applicable Related Strategy Profile available upon request from a Representative. • Additionally, we periodically review the Brochure and enhance existing disclosures about the Program, its Services and other important information. This version of the Brochure has been revised to clarify the presentation of information about the Program. We have also made the enhancements and clarifications outlined above. Clients should review the text of the enhanced disclosures in this Brochure. 3 MAA-MerrillSPS-03-2025 ITEM 3. TABLE OF CONTENTS ITEM 4. ADVISORY BUSINESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 The Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Available Strategies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Reasonable Investment Restrictions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 MAA’s Role and Authority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Replacing a Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Treatment of Cash Balances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ITEM 5. FEES AND COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Account Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 IM&T Fee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Style Manager Expense. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 How the Account Fee is Determined . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Deduction of Account Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 Ability to Obtain the Program Services Separately . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 ITEM 7. TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Client Eligibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Account Minimums . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Closing a Program Account and/or Terminating Participation in the Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Methods of Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Investment Strategies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Investment Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 ITEM 9. DISCIPLINARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING. . . . . . . .16 Conflicts of Interest and Information Walls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 Code of Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 Agency-Cross and Other Cross Transactions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 Funds and Fund Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 Offering of Related Strategies and Use of a Related Strategy in a Client’s Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 Affiliated Investments of a Style Manager . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Provision of Diversified Financial Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 Other Relationships and Interests; Activity by MAA, Merrill and their Personnel and Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 Cash Balances and the Cash Sweep Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 Relationship with Asset Managers, Sponsors and Style Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 Offering of Investments or Programs Managed by Us or Our Affiliates. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 ITEM 12. BROKERAGE PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 Transactions in Program Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 ITEM 13. REVIEW OF ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 Program Account Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 Client Reports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 Trade Confirmations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 ITEM 15. CUSTODY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 ITEM 16. INVESTMENT DISCRETION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 ITEM 17. VOTING CLIENT SECURITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 ITEM 18. FINANCIAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 ADDITIONAL INFORMATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 Covered Entities under the Volcker Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 GLOSSARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27 4 MAA-MerrillSPS-03-2025 ITEM 4. ADVISORY BUSINESS This Brochure relates to Managed Account Advisors LLC (“MAA”) and Merrill Lynch, Pierce, Fenner & Smith, Incorporated (“Merrill” or “MLPF&S”). MAA is a direct wholly-owned subsidiary of Merrill and both Merrill and MAA are indirect wholly owned subsidiaries of Bank of America Corporation (“BofA Corp.”). MAA provides investment advisory services to Bank of America, N.A. (the “Bank”) in connection with investment management and trust services offered by the Bank to the Bank’s fiduciary account clients under its Select Portfolio Solutions (the “Program”) as discussed in this Brochure. MAA is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser and began providing advisory services in 2007. As of December 31, 2024, MAA manages $829.74 billion in client assets on a discretionary basis and no client assets on a non-discretionary basis. Merrill provides non-discretionary investment advisory services to the Bank by providing certain managed investment strategies that the Bank makes available in the Program. These strategies are constructed by Merrill investment professionals in the Chief Investment Office (“CIO”) and implemented by MAA as further discussed below. Merrill is a global financial services firm that offers a broad range of brokerage, investment advisory, retail and other services. Merrill is registered with the SEC as a broker-dealer and has been registered as an investment adviser since 1978. It acts as an investment adviser to its clients in other managed account programs it sponsors, including with MAA. As of December 31. 2024, Merrill had assets under management of $1,511.09 billion, of which $388.43 billion was managed on a discretionary basis and $1,122.66 billion was managed on a non-discretionary basis. As further described in this Brochure, transactions in a Program Account (except as otherwise provided) are effected by or through Merrill or its Affiliates, acting as agent, and in doing so, Merrill and its Affiliates will be acting exclusively as broker-dealer. The Bank pays an asset-based fee for these and other services provided by Merrill through the Program. Both MAA and Merrill also provide investment advisory services to clients primarily through managed account programs they sponsor. Information pertaining to the investment advisory programs through which MAA and Merrill either separately or together provide investment advisory services that are similar to the Program can be found in separate brochures for each program, which are available from each client’s representative (“Representative”) from Bank of America Private Bank or Bank of America Workplace Benefits, each a division of the Bank, or on the SEC’s website at adviserinfo.sec.gov. This Brochure relates solely to the advisory services MAA and Merrill provide to the Bank in connection with the Program. Additional information about the Program can be found in the Bank’s Select Portfolios Solutions Disclosure Statement (“SPS Disclosure Statement”) provided to clients by their Representative. Capitalized terms that are not defined in this Brochure have the meanings provided in the Glossary. The Program The Program is an investment service offered and administered by the Bank that is designed to help its fiduciary account clients meet their investment objectives by offering managed investment strategies (“Strategies”) as described below. To participate in the Program, a client must maintain an investment management, trust or similar relationship directly with the Bank, such as when the Bank serves as trustee for a trust on a client’s behalf or when the Bank provides investment management or other services in connection with a client’s account. Clients are required to enter into a Client Agreement with the Bank (or provide to the Bank other relevant documentation governing that relationship) prior to the investment of client assets in an account through the Program (an “Account” or “Program Account”). Typically, each Account will consist of a single Strategy selected by the Bank for its client. The Bank through the client’s Representative collects information about the client’s financial circumstances, investment objectives, tax situation, time horizon, risk tolerance and other relevant information to help the Bank determine the appropriate selection of Strategies. Available Strategies Each Strategy available through the Program has been identified and approved by the Bank for the Program. Each Strategy is constructed or managed by an investment manager (a “Style Manager”) which includes third party investment managers and Affiliates of BofA Corp. or an entity in which BofA Corp. or its Affiliate has a material ownership interest (“Related Entities”), such as BANA Merrill and MAA. Strategies of Related Entities are referred to as “Related Strategies.” Each third party Style Manager files its own Form ADV Part 2A brochure or has an equivalent document that describes their strategy and role and each Style Manager (including those that are Related Entities), where required and, as applicable, makes available Form ADV Part 2B-Brochure Supplements for its investment professionals providing portfolio management services for the Strategies. We make these materials available to clients through their Representative. Related Strategies available in the Program include those constructed by the CIO. Certain of the Related Strategies are constructed by Bank-employed CIO investment professionals. There are also available Related Strategies that are constructed by Merrill-employed CIO investment personnel. In addition, MAA is the Style Manager for a suite of equity Related Strategies that are developed based on investment models and lists published by the BofA Global Research Group (“BofA Research”), a division of BofA Securities, Inc. (“BofAS”), an Affiliate of MAA. Additional information about each of these types of Related Strategies and which Related Entity is acting as a Style Manager is available in the applicable Related Strategy Profile available upon request from a Representative. 5 MAA-MerrillSPS-03-2025 Strategies are generally organized according to a shared characteristic such as asset class or investment style. The Style Manager, including a Style Manager that is a Related Entity, constructs, implements and/or manages its respective managed portfolios and determines the asset classes, security holdings and weightings in the Strategy. Depending on the nature of the Strategy and the determination made by the Style Manager, a Strategy consists of individual securities (e.g., equities, fixed-income securities, mutual funds, money market mutual funds, exchange traded funds and nontraditional mutual funds), other Strategies and/or cash and/or cash alternatives (a “cash allocation”). The cash allocation is held as a cash balance and/or invested in cash alternatives such as money market funds as determined by the Style Manager. If no action is taken by a Style Manager, cash balances will automatically be swept pursuant to the cash sweep option for the client’s Account under the terms of the client’s account agreement or other arrangements with the Bank (“Cash Sweep Program”). The available automatic cash sweep options under the Cash Sweep Program vary based on the account type. The cash allocation can be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations, rebalancing, market conditions and the Style Manager’s cash management approach and market view and concerns. Some types of Strategies include investments that take an extended period of time to purchase due to the types of security, market availability and selection criteria. Until invested, the cash for these investments is typically held in the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the Style Manager as a temporary investment pending purchase of the individual security. For more information on the treatment of cash balances, see “Treatment of Cash Balances” in this Item 4. The Program offers model-based Strategies and discretionary Strategies. The Program’s Strategy Profiles contain information relating to the Strategy and Style Manager. For a model-based Strategy, the Style Manager provides advisory services by furnishing to MAA investment recommendations for the Strategy in the form of model portfolios or other investment guidelines and/or instructions. MAA will generally implement the Style Manager’s recommendations without change, subject to the application of any Reasonable Investment Restrictions (as defined below) which MAA has determined to accept as reasonable, cash commitments and other operational or investment considerations, including frequency of rebalancing. MAA may determine, in light of operational or investment considerations in its sole discretion, to deviate from the model portfolio on a limited basis (i.e., to select another security or increase the cash allocation within a model portfolio). Through the selection of a model-based Strategy, MAA is granted investment discretion and trading authority for investments occurring in that Strategy. Through this authority, MAA has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. This authority will remain in place until MAA has received and accepted instructions from the Bank to either change the Strategy or terminate the Account from the Program. For a discretionary Strategy, MAA arranges for investments to be implemented within the Account directly by such Discretionary Manager. MAA does not exercise investment or trading discretion or responsibility for implementing investment or trade execution decisions other than enforcing any Reasonable Investment Restrictions in the Account. Through the selection of a Strategy with a Discretionary Manager for an Account, the Discretionary Manager is granted investment discretion and trading authority for investments occurring in the Strategy in the Account. Through this authority, the Discretionary Manager has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. The Discretionary Manager executes trades through Merrill or a Merrill Affiliate or through a broker or dealer other than Merrill or a Merrill Affiliate (an “Unaffiliated Trade Counterparty”). The investment discretion and trading authority will remain in place until MAA receives and accepts instructions from the Bank to either change the Strategy or terminate the Account from the Program. The Discretionary Manager has the authority to determine whether a requested restriction is reasonable for their Discretionary Strategy. MAA and Discretionary Managers may use different vendors and/ or providers in considering whether restrictions requested by clients are reasonable. Certain Style Managers will respond to requests for customization such as state specific or state preference, credit quality maturity or duration and sector and employ those on a best efforts basis and subject to certain limitations as described in the Strategy Profile. MAA is not responsible for implementing any such customization requests. A Style Manager may construct or provide model recommendations for a Strategy that utilizes mutual funds, money market funds, exchange traded funds (“ETFs”), closed-end funds and non-traditional mutual funds (collectively, “Funds”). Any securities issued by a Style Manager or its affiliates will generally not be eligible for investment through the Program other than Manager-Related Funds. Manager-Related Funds are those Funds that are sponsored or advised by the Style Manager or its affiliates designed to only be utilized in investment advisory programs like the Program, have no internal advisory or distribution fees (but do have certain ongoing expenses) and may not be held outside of the particular Strategy. The Style Manager typically views these as an integral part of its investment strategy with no appropriate substitutions that can be utilized as replacements. Therefore, MAA, the Bank or their Affiliates do not decide whether this type of Manager-Related Fund should be removed or replaced through redemptions from the Strategy or the Program. MAA implements the investment advice from the Style Manager as to the inclusion of these types of Manager-Related Funds in model-based Strategies without change other than as a result of withdrawal requests and rebalancing. To the extent that a Style Manager utilizes a Manager-Related Fund that is charged a Fund management fee by the Style Manager or its affiliate, the Bank, Merrill and MAA will work with the Style Manager to provide a rebate of the Fund management fees paid in respect of the Manager- Related Fund holdings as against the Style Manager Expense. Typically, Strategies have a Style Manager Expense that is charged by the Style Manager. Certain Related Strategies have a Style Manager Expense and there are those that do not. Any fee paid to a Style Manager will vary depending on, among other factors, the particular investment style or approach and the type of securities included in the investment strategy. Generally, clients will pay 6 MAA-MerrillSPS-03-2025 the Style Manager Expense as part of the Account Fee which will be used to compensate the Style Manager. See “Item 5 Fees and Compensation” for information about the Account Fee and fee information. Reasonable Investment Restrictions Clients may request that certain investment restrictions be imposed on the management of the assets in their Account. For a restriction to be acceptable under the Program, it must first be determined to be “reasonable” (a “Reasonable Investment Restriction”). If accepted, the Reasonable Investment Restrictions that MAA is responsible for managing or implementing in the client’s Account will be applied until: (1) the client takes action to change, withdraw or waive the restriction; (2) MAA determines that it is no longer a Reasonable Investment Restriction based on factors it deems relevant in its discretion, including for example, the level of the security holding percentage in the Strategy; or (3) MAA is no longer able to implement the restriction in its systems due to changes in its systems or changes in the security identifier or symbol, corporate action events, or otherwise. MAA reserves the right to modify its practices regarding investment restrictions in its sole discretion at any time without notice. Further, MAA reserves the right to deem any requested investment restriction to be unreasonable and to not accept the requested investment restriction. If one or more investment restrictions are determined to be unreasonable, the restriction will not be applied and the client should consider whether to remain in the Program or consider other investment strategies. Please note that Reasonable Investment Restrictions will not apply to securities that are part of a Fund purchased for the Account. Along these lines, a client’s Reasonable Investment Restriction other than with respect to the purchase of a particular Fund itself would likely not have any practical effect on an Account comprised primarily of Funds. The termination or removal of an Account from the Program will terminate Reasonable Investment Restrictions for that account, and such Restrictions will not be applicable to the account outside of the Program. Implementing certain Reasonable Investment Restrictions result in securities being sold which could result in taxable events. If a client elects to impose Reasonable Investment Restrictions, they accept any effect that such Reasonable Investment Restrictions may have on the investment performance and diversification of the Account. The performance of an Account with a Reasonable Investment Restriction will differ from, and may be lower than the performance of, an Account without such restrictions. In addition, a client’s decision to impose a Reasonable Investment Restriction that alters the allocation of any Strategy exposes the client to additional (and potentially unforeseeable) risks that are inconsistent with the objective of the Strategy. Depending on the Strategy selected, MAA or the Discretionary Manager for the Strategy selected for the Account will determine whether a restriction request is reasonable and how to allocate investments based on an accepted Reasonable Investment Restriction. MAA will allocate the assets that would have been invested in the security impacted by the Reasonable Investment Restriction in one of the following ways: (1) pro-rata across other investments that are part of the Strategy; (2) using one or more replacement securities which could include ETFs; and (3) remaining uninvested in cash. A client can request that MAA or a Discretionary Manager implement available investment screens to restrict investments with a specific identifier (such as a security number or ticker symbol), in certain security types, in companies in certain sectors or industries, in companies that do not meet certain environmental, social and governance (“ESG”) characteristics, and/or in fixed income securities that have certain credit ratings and maturities. MAA relies on analyses by third-party providers of investment screens, including those offering sector and industry classification and industry grouping data and ESG screens. MAA does not guarantee or validate third- party screening or processes nor does it conduct an independent review of the underlying nature of the companies’ businesses or ESG characteristics. The screening and processes to implement category investment restrictions are not absolute, may change at any time and could result in investments in companies that derive revenue from the restricted category. MAA and the Discretionary Manager may use different vendors and/or providers in considering whether restrictions requested by clients are reasonable. MAA’s Role and Authority Under the Program, MAA provides a variety of investment advisory services. Specifically, MAA has authority to make certain investment and trading decisions including: • Implementing, as applicable, the model-based recommendations or other investment guidelines and/or instructions of the Style Manager for a model-based Strategy. • Processing all contributions, including initial and any subsequent cash deposited in the Account, withdrawal requests and Account terminations. • Periodically rebalancing the Accounts for a Strategy as further described below. • Implementing a client’s Reasonable Investment Restrictions, if any, as described in the section “Reasonable Investment Restrictions.” • Implementing a client’s tax-selling instructions (if any) where acceptable to MAA. MAA will sell promptly any investments a client contributes that are not eligible or not acceptable for a Strategy. 7 MAA-MerrillSPS-03-2025 Certain Strategies have target allocations and are subject to automatic rebalancing on a periodic basis. Others are dynamically managed and are not subject to periodic rebalancing in the same manner. In light of other considerations in an Account, MAA can effect rebalancing and other transactions even though they may generate tax liabilities, including short-term taxable income. In its discretion, MAA may decide not to process certain rebalancing transactions. Delays in the processing of any rebalancing activities that MAA undertakes can occur from time to time, based on, among other things, market conditions, illiquid securities or those with limited subscription and redemption schedules, as well as the availability of Funds and other factors. MAA arranges for trades to be executed through Merrill and its Affiliates and may arrange for trades to be executed through an Unaffiliated Trade Counterparty. In its discretion and subject to legal requirements, MAA may utilize its Affiliates and third party vendors for investment, trading and administrative support. MAA generally takes necessary actions consistent with implementing a Strategy, including for any investments subject to regulatory limitations and restrictions and related internal policies applicable to MAA and its Affiliates’ overall investment activities described further in the section “Other Relationships and Interest: Activity by MAA, its Personnel and Affiliates.” Replacing a Strategy Changes to a previously selected Style Manager or Strategy can occur due to: (1) the Bank’s and/or the client’s instruction to replace a Strategy; (2) a Strategy being closed to new investments and/or additional contributions or otherwise; or (3) the termination of a Style Manager from the Program. Where there is a determination to close a Strategy or otherwise require a Strategy held by investors to be replaced, MAA may (1) replace the identified Strategy with another Strategy the Bank selects; (2) maintain current positions in the identified Strategy and invest any new contributions and sale or redemption proceeds in a replacement Strategy the Bank selects; or (3) maintain in cash any new contributions or sale or redemption proceeds relating to the identified Strategy until a replacement is chosen by the Bank. MAA is responsible for implementing the Bank’s decisions and related actions. If the Bank determines to replace the identified Strategy, it will endeavor to choose a replacement with an investment style that is consistent with the identified Strategy. The replacement may be subject to higher fees. The client’s continued participation in the Program after any such replacement or other action will be considered their consent to the action, if necessary based on the Bank’s arrangement with the client. If clients hold the identified Strategy, the client will be provided with written notice (if necessary based on the Bank’s arrangement with the client) of any discontinuation, closing or replacement event prior to it taking place; however, they may be notified of such event after action has already been taken. Having the flexibility to act quickly helps the Bank and MAA take action where they believe the replacement and its timing are in clients’ best interest. Treatment of Cash Balances As described in the relevant account agreement and documents that govern a client’s Account, clients consent to having cash held in the Account being treated as a cash balance and being automatically “swept” to the Cash Sweep Program. Unless the cash allocation is invested, either in a cash alternative or in other securities, the cash allocation will be treated as a cash balance in the Account subject to the automatic sweep functionality. Cash held in Accounts with a custodian other than the Bank are not covered by the Cash Sweep Program and will not be subject to the Cash Sweep Program. Cash balances swept to a deposit account of the Bank under the Cash Sweep Program will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts will be periodically set and reset by the Bank in its discretion. The rate is variable and may change at any time after the Account is opened without notice or limit. The interest rate earned in the bank deposit account affiliated with the Cash Sweep Program can be lower than yields on certain money market funds and other cash alternatives. An Account’s cash balance swept to bank deposits of the Bank is insured by the Federal Deposit Insurance Corporation (“FDIC”), up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership category, per bank. FDIC insurance covers both principal and credited interest, up to applicable limits. Any bank deposits maintained with the Bank or a banking Affiliate in the same account ownership category, whether directly, through other accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If a client’s total cash balances held at the Bank in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of bank product exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. For additional information on FDIC insurance, visit fdic.gov. Neither MAA nor the Bank manages or monitors the deposits swept under the Cash Sweep Program for FDIC insurance limit purposes. Deposits are not aggregated or limited based on the FDIC limits for the same depositor in the same bank across accounts. MAA does not undertake through the Program to provide a client with notice that cash balances in an Account or Accounts or in any other relevant accounts exceeds the FDIC coverage limit. Monitoring FDIC insurance coverage limits is expressly not a Program service. Clients are responsible for monitoring the total amount of deposits held at the Bank in order to determine the extent of FDIC insurance. If a client’s total cash balances held at the Bank in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of Bank product exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Third-party money market funds are available as a sweep option. These money market funds have certain internal expenses and costs and clients will bear the proportionate share of the 8 MAA-MerrillSPS-03-2025 sweep money market fund’s fees and expenses including, but not limited to, management fees paid to the Fund’s investment managers or their affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. The Account Fee does not cover or offset any fees and expenses that the sweep money market fund incurs for transactions occurring within the Fund itself. Please consult the prospectuses and offering material for the sweep money market funds. For additional information and related conflicts of interest related to cash balances and the Cash Sweep Program, see the Bank’s SPS Disclosure Statement and this Brochure at Item 11 “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” at the section “Cash Balances and the Cash Sweep Program.” ITEM 5. FEES AND COMPENSATION Account Fees The Account Fee for the Program is comprised of: (1) the fee the client currently pays the Bank for its services, as that fee is set forth in the Client Agreement or other relevant fee documentation governing that relationship with the Bank (the “IM&T Fee”) and (2) the fee the client pays for a particular Strategy (“Style Manager Expense”), if applicable. The Account Fee is payable in advance and will be based on the value of assets, including cash and cash alternatives, in a client’s Account. For the advisory services MAA provides through the Program, the Bank pays MAA an asset-based fee. IM&T Fee. The IM&T Fee rates and terms of payment are set forth in the Client Agreement or other relevant account documentation and are subject to change. Clients should consult their Representatives with any questions about the terms of their existing relationship with the Bank. The IM&T Fee clients pay may be negotiable depending on a number of factors. Such factors include, but are not limited to the: • Market value and asset allocation of a client’s assets. • Number and size of a client’s related accounts maintained at the Bank and its Affiliates. • Range and extent of services provided or to be provided to a client. • Representative assisting the client. Other pricing arrangements, typically involving multiple accounts, products or services, may also be available to clients. While clients entering into such arrangements may pay higher fees for any particular component being offered, the pricing arrangement as a whole will generally result either in the same or lower fees in the aggregate for all the accounts, products or services provided or for the inclusion of additional products and services. From time to time, MAA and the Bank also may enter into specialized agreements to provide particular or unique services to certain clients, subject to negotiated fees. In addition, the Program may be offered through other lines of business of BofA Corp. Clients of these lines of business may have a limited or different selection of Style Managers, Strategies and/or Funds. Certain additional services also may be provided to such clients. The fees for certain of the services described in this Brochure may be reduced for employees of the Bank and its Affiliates, or such employees and Affiliates may be subject to prior fee schedules. Additional information about Account Fees and other fees and expenses that a client may incur when participating in the Program are discussed in greater detail in the Bank’s Disclosure Statement for the Program. Style Manager Expense. The Style Manager Expense rate for each Strategy is listed in the Style Manager Expense Rate Supplement to the Bank’s SPS Disclosure Statement. Any fee paid to a Style Manager will vary depending on, among other factors, the particular investment style or approach and the type of securities included in the investment strategy. The Style Manager Expense rates generally range from 0.00% to 0.50%. The Style Manager Expense rate applicable to a client’s Program Account does not change based upon the value of assets in a client’s Program Account. The Style Manager Expense rate is stated on the Strategy Profile. Clients that invest in a Related Strategy will not be charged a Style Manager Expense. The selection of the Strategy with no Style Manager Expense results in the client paying only the IM&T fee which is paid to the Bank for the Program Services. This presents an opportunity for the Bank to benefit as the client will not be paying a separate Style Manager Expense from account assets, resulting in more assets and higher fees to the Bank than if the client accounts had a Style Manager Expense. Additionally, the opportunity to negotiate a higher IM&T Fee rate provides the Representatives with an incentive to recommend Strategies with no Style Manager Expense rate over those that do. The ability to negotiate a higher IM&T Fee rates benefits the Bank as well as a Representative since the Bank retains the IM&T Fee. If a new or different Strategy is selected for a client’s Account, the change in Style Manager Expense rate will be processed for the next monthly billing cycle. The Style Manager Expense rate applicable to the former Strategy will apply through the remainder of that calendar month, after which the new Style Manager Expense rate(s) for the new Strategy will automatically be applied. How the Account Fee is Determined Account assets will be valued in a manner determined by the Bank and MAA in their sole discretion, and in some cases may be based on prices and/or estimates obtained from various sources, including their Affiliates. Values may vary from prices achieved in actual 9 MAA-MerrillSPS-03-2025 transactions, especially for thinly traded securities, and are not firm bids or offers or guarantees of any type about the value of assets in a client’s Account. For fixed-income securities, the values assume no unusual market conditions and are generally for transactions of $1 million or more, which may produce values that are higher than the prices that would be achieved in the sale of fewer securities. As a result, the Account Fee may be calculated based on values for some securities that are greater than the amount the client would receive if the securities were sold from the client’s Program Account. The Program Account value used for the calculation of the Account Fee may differ from that shown on a client’s monthly securities account statement and the performance measurement report due to a variety of factors, including trade date or settlement date accounting, the treatment of accrued income, round lot valuation and other considerations. The valuation of Program Account securities reported in the performance measurement report also may be subject to occasional repricing in reasonable and appropriate circumstances, but such repricing will not affect, or result in the adjustment of, previously calculated Account Fees. Deduction of Account Fees Clients or their authorized representatives generally have agreed to the following: • Unless otherwise agreed to between the client and the Bank, the IM&T Fee (and any other fees payable under the Client Agreement, if applicable, or other relevant documentation, including any Style Manager Expense) will be deducted directly from a client’s Account. • The Bank is authorized to deduct the Account Fee from the assets held in a client’s Account, to the extent permitted by applicable law, if full payment of the Account Fee has not been timely received or, if earlier, at the time the Account is terminated. • The Account Fee for a client’s Account will be payable, unless otherwise indicated, first from the liquidation or withdrawal by the Bank and to the extent permitted by applicable law, of the client’s shares of any money market fund or balances in any money market or bank deposit account, and second from free credit balances, if any, in the client’s Account, and to the extent that such assets are insufficient to satisfy payment of such fees, the client will be billed by the Bank. • Timely payment of all amounts due to the Bank. • To the extent permitted by law, all assets in a client’s Account or otherwise held by the Bank or its Affiliates for the client (other than retirement accounts guaranteeing the obligations of non-retirement accounts and vice versa) will be subject to a lien for the discharge of client obligations to make timely payment to the Bank of the Account Fee (and any other fees the client is obligated to pay), and the Bank and its Affiliates, subject to applicable law, may sell assets in the client’s Account to satisfy this lien. A client is responsible for paying the full amount of the Account Fee, regardless of whether the client uses all of the services provided or described herein and in the Bank’s SPS Disclosure Statement. Clients may be able to pay the Account Fees from assets held outside of their Account. Clients should contact their Representatives for additional information. Ability to Obtain the Program Services Separately Clients may be able to obtain some of the same or similar services or Strategies available through the Program separately from the Bank, Merrill, MAA and their Affiliates on a separate or combined basis, subject to certain restrictions, including the type of account for which clients are seeking these types of services. Depending upon the factors below, the Program may cost clients more or less than purchasing the services separately. Clients may also be able to obtain some or all of the types of services available through the Program from other firms and account fees may be higher or lower than the fees charged by other firms for comparable services, assuming such services are available. It is the client’s responsibility to review the other services or investments available through the Bank and its Affiliates with a Representative to determine whether the other services or investments may be more appropriate than the Program. In comparing the account types and programs and their relative costs, clients should consider various factors, including, but not limited to: • Client preference for an adviser, brokerage, bank trustee or bank investment management relationship. • Client preference for a discretionary or a non-discretionary relationship. • Client preference for a fee-based or commission-based relationship. • The types of investment products that are available in each program or service. • Whether a particular investment strategy offered in one program or service is available through another Bank or Merrill program or service. • How much trading activity a client expects to take place in his or her Program Account. • How much of a client’s assets are expected to be allocated to cash. • Whether a client wishes to invest in mutual funds, and which mutual funds (if any) are available in particular programs. 10 MAA-MerrillSPS-03-2025 • The frequency and type of client profiling reports, performance reporting and account reviews that are available in each program or service. • The scope of ancillary services that may be available to a client in a brokerage account, but that are not available in the Program. ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Both Merrill and MAA may manage multiple accounts with different investment objectives, guidelines and policies, and with different fee structures. While neither MAA nor Merrill presently accept performance-based fees, either firm may enter into performance fee arrangements with qualified clients in the future. Such performance fee arrangements would be subject to individualized negotiation with each such client and structured so as to comply with Rule 205-3 under the Advisers Act. Certain Funds available in the Program may be subject to performance-based fees or varying Fund expense charges that are imposed by the manager, adviser or other party that are based on performance of the Fund. ITEM 7. TYPES OF CLIENTS Client Eligibility To participate in the Program, a client must maintain an investment management, trust or similar relationship with Bank of America Private Bank or Bank of America Workplace Benefits and establish an account with BANA. Investors eligible to participate in the Program generally may include individuals, trusts, estates, charitable organizations, corporations, retirement plans, pension and profit sharing plans. As indicated in the Strategy Profile for each Strategy, not all types of investors are eligible for each Strategy. Account Minimums The minimum initial investment in the Program varies depending on the Strategy selected by the Bank for the client’s Program Account. The minimum initial investment for a particular Strategy is generally included in the applicable Strategy Profile. Closing an Account and/or Terminating Participation in the Program Clients have the ability to terminate their participation in the Program which may result in a refund or require the client to pay the Bank any remaining fees due for the partial billing period. See the Bank’s SPS Disclosure Statement for more information. Upon termination of the Account enrollment into the Program, MAA will have no responsibility for the investment of assets in the client’s Account. Notwithstanding a client’s instructions to the contrary, certain Funds and other securities held in the client’s Account pursuant to a certain Strategy will be automatically liquidated or redeemed, as described in the applicable prospectus or disclosure document upon termination of an Account’s enrollment in the Program. Liquidation or redemption will generally be effected by the close of the next business day following termination, although for certain securities, such as those traded on a when-issued basis or as odd lots, the liquidation or redemption process may take longer. The termination of a Representative’s employment with the Bank will not automatically terminate the Client Agreement or an Account. If a client’s Representative is no longer able to service the client’s Account, the Bank may transfer that Account to a different Representative and the client will be notified of any such changes. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis For the Strategies, a number of investment techniques, including fundamental analysis, may be used. A variety of sources of information may be used to facilitate such analysis. The Strategies or Portfolios also may be invested in a wide range of investments depending on a particular client’s objectives, strategies, policies, applicable law and other relevant factors. General descriptions of the Strategies are included in the Strategy Profiles provided or made available to clients. Clients also may receive brochures of any Discretionary Manager selected to manage their Account or a portion thereof. MAA reserves the right to limit the availability of any particular Strategy at any given time based on factors including, but not limited to, asset class capacity, pre-existing relationships, minimum account sizes, fees and distribution channels. Investment Strategies Strategies are generally organized according to a shared characteristic such as asset class or investment style. The Style Manager will construct the particular investment strategy and select the securities, including, in certain cases, Funds and other types of investment strategies. They also set the allocations or allocation ranges. Please refer to the Profile for additional information about the Strategy, including further details with respect to the strategy description, portfolio construction and due diligence. The Strategies available in the Program include Related Strategies. The Program offers Related Strategies that are constructed by CIO investment professionals. The Related Strategies constructed by Merrill-employed CIO portfolio teams consist of mutual funds, ETFs and other Strategies that they select and provide to MAA as a model-based Strategy. Other Related Strategies are those that are constructed by CIO portfolio teams employed by the Bank and can consist of equity and fixed income securities as well as Funds. 11 MAA-MerrillSPS-03-2025 The Related Strategy Profile will indicate which Related Entity is acting as the Style Manager for the Related Strategy. In addition, certain of the Related Strategies are those constructed and implemented by MAA based on BofA Global Research investment models or lists. These investment models or lists include exchange traded products that are covered by research reports and ratings of the BofA Global Research Group (“Research Ratings”). The CIO, BofA Global Research and other business units of BofA Corp. apply different methodologies in their review of exchange traded products and may arrive at different or inconsistent conclusions. It is possible that certain of the exchange traded products included in the Related Strategies based on the BofA Global Research-based models or lists may not have been reviewed under the CIO Review Process as described below and such review is not required. For its Related Strategies, the CIO determines the allocations or allocation ranges for Related Strategies based on its long-term expected return, risk and correlation assumptions for each asset class (capital market assumptions), its view of the appropriate long term allocation guidelines to follow in light of market conditions, expected trends and, as applicable, corresponding tactical asset allocation adjustments. Tactical asset allocation adjustments are applied to those long-term asset allocations based on the CIO’s near- term market, economic, and asset class expectations. These tactical adjustments overweight or underweight specific asset classes, incorporating its investment views on how market dynamics, phases of the economic or business cycle, and particular investment themes may affect the Related Strategies. To determine tactical asset allocations, the CIO utilizes internal as well as third-party research and data at both the macro and micro levels. Once the Related Strategies are constructed, the CIO regularly monitors and reviews them and makes adjustments based on asset allocation changes. The individual securities are also periodically reviewed to ensure they continue to meet the criteria for inclusion. The Related Strategies are also subject to internal governance and oversight processes on a periodic basis, which may include a review of performance against expectations as well as any applicable investment or regulatory restrictions. In constructing the Related Strategies that consist of Funds and/or other Strategies, the CIO portfolio teams select those Funds and other Strategies that are subject to the “CIO Review Process,” an investment review conducted by or under the auspices of personnel of the CIO of investment solutions. The CIO Review Process consists of proprietary processes conducted by the CIO and those processes and reviews provided by third-party reviewers that engaged for this purpose. The third-party reviewer processes and reviews are generally consistent with the review processes that the CIO deploys but they are not identical. The CIO has reviewed such third-party reviewers’ processes and believe they are reasonable and appropriate in light of the objectives of the Program. The CIO Review Process considers whether Funds and/or other Strategies have sufficient assets under management and meet minimum trading volume parameters. In addition, it considers and evaluates their share price or net asset value, along with the corresponding allocation weighting, in light of a Strategy’s investment minimum. Note that Style Managers include as part of their Strategies’ investment portfolios individual equity and fixed income securities, investment strategies and Funds based on their own review and portfolio management processes and determinations. These individual securities, including Funds, may not be covered, and are not required to be subject to, the CIO Review Process. The Program does not currently offer any Funds sponsored by a Related Entity (“Related Funds”). However, to the extent any Related Funds become available, we may determine to include them in a Strategy constructed by a Related Entity. The Bank offers other investment strategies outside of the Program. Certain strategies may be available only in certain channels or through a purchase of shares of Funds. Investment Risks As with any investment in securities, investments through the Program involves a risk of loss. Clients may lose money by participating in the Program. The Account is not insured or otherwise protected by the FDIC or any other government agency; are not obligations of the Bank, MAA, Merrill or any of their Affiliates; and are not endorsed or guaranteed by the Bank, MAA, Merrill or any bank or any Affiliate of the Bank. In addition to the risks discussed in this section, clients are encouraged to review the “Risk and Tax Disclosure” section in the Bank’s SPS Disclosure Statement. General Risks Associated with Investments Available in the Program. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed and the value of a client’s assets will fluctuate due to market conditions and other factors. Investments made and the actions taken respecting Account assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. There is equity risk in that stock prices may fluctuate over short or extended periods of time. 12 MAA-MerrillSPS-03-2025 Fixed income securities have interest rate risk in that they will increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. In general, if interest rates rise, bond prices fall, and if interest rates fall, bond prices rise. These securities also have credit risk where changes in the financial condition of an issuer or guarantor of a fixed-income security or a counterparty to a contractual obligation and changes in general economic conditions may impact the actual or perceived willingness or ability of an issuer, guarantor or counterparty to make timely payments of interest or principal or to otherwise honor its obligations. Such changes may result in a loss. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. Investing in securities exposes the client to market risk, where security prices in a market, sector or industry may fall, reducing the value of a client’s Program Account(s). These securities also bear inflation risk, where returns on fixed-income securities may not keep pace with inflation. Foreign securities are subject to special risks, including, without limitation, limited liquidity, delays in settlement, less publicly available information about companies, the impact of political, social or diplomatic events, taxation, possible seizure, expropriation or nationalization of a company or its assets, and possible imposition of currency exchange controls. Foreign markets may be extremely volatile. Clients should review the offering materials and other disclosure available for each relevant investment security or transaction, including any prospectuses and other offering material produced by issuers and sponsors of investment products, to get an appreciation of its associated risks and fees. Clients are assuming the risks involved with investing in securities and other investment products, and could lose all or a portion of the amount held in the Program. For a discussion of conflicts of interest with the use of certain investments and securities, please review the information in this section and in “Offering of Investments or Programs Managed by Us or Our Affiliates.” Management Risk. Investment decisions might produce losses or cause a client’s Program Account to underperform relative to a relevant benchmark or peer group. The Bank’s decisions or recommendations with respect to Style Managers and Strategies also may cause underperformance of a client’s Account(s) relative to either the client’s expectations or similar programs, and there is no guarantee that the selected or recommended Style Manager(s) and/or Strategies will produce the desired results. ESG-themed Strategies or Funds. There are an increasing number of products and services that purport to offer environmental, social, and governance (ESG) or sustainable investing strategies (“ESG Strategies”). The variability and imprecision of industry ESG definitions and terms can create confusion. Investment managers and product sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. Generally, none of MAA, Merrill and the Bank undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the manager) other than as part of the CIO Review Process. The client should review the offering materials and Profiles to gain an understanding of how these managers and product sponsors describe their investment approach. Investment managers and investment advisers can have a different approach to ESG or sustainable investing and can offer ESG Strategies that differ from the ESG Strategies offered by the CIO with respect to the same theme or topic. ESG Strategies, including ESG-related mutual funds and ETFs, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made a Style Manager, will align with the beliefs or values of the client. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the Style Manager assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities that may be available to clients that do not choose similar restrictions and, as a result, investment performance could suffer. On the other hand, category restrictions that aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category may not exclude all companies with any tie or revenue derived from such restricted category and require assumptions, opinions and the 13 MAA-MerrillSPS-03-2025 subjective judgment of the data provider that might not reflect the views or values of the client. If a client holds an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event for the client. For client accounts that can hold Funds, clients cannot prohibit or restrict a portfolio manager of a Fund from investing in specific securities or types of securities that are held within any Fund. Category restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that client restrictions would not have any practical effect on an account comprised primarily of Fund investments. When evaluating investments for an ESG Strategy, a Style Manager or Fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment an investment’s ESG or sustainable attributes. None of MAA, Merrill or the Bank guarantees or validates any third-party data, ratings, screenings or processes. Moreover the screenings and processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in an Account holding investments in companies that derive revenue from the restricted category. Regulatory Risk. The overall investment activities of the Bank, MAA, Merrill and their Affiliates may limit the investment opportunities for a client’s Program Account(s) in certain markets in which limitations are imposed by regulators upon the amount of investment by affiliated investors, in the aggregate or in individual issuers. From time to time, a client’s Program Account’s activities also may be restricted because of regulatory restrictions applicable to the Bank, MAA, Merrill or their Affiliates, and/or their internal policies. Information and Cybersecurity Risks. With the increased use of technologies to conduct business, like all companies, MAA, Merrill, the Bank and BofA Corp., its Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. All are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly. BofA Corp. and the Bank, as well as MAA and Merrill, devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, Style Managers, Funds and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. MAA and Merrill, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents directed at BofA Corp. and its Affiliates and its third-party service providers. While MAA, Merrill, the Bank and its third-party providers have experienced cybersecurity incidents and well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that they will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. The focus on information security includes cybersecurity incidents perpetrated against BofA Corp. and its Affiliates, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (“AI”) and machine learning. BofA Corp. and its Affiliates, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject them to fines, judgments and/or settlements and involve reputational losses. BofA Corp. and its Affiliates continue to adjust business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, BofA Corp. and its Affiliates expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that certain assumptions be made with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in business planning and strategies. MAA, Merrill and the Bank rely on their ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While policies, programs, processes and practices are continually updated and emerging technologies, such as automation, AI, machine learning and robotics, implemented, data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and the ability to manage current and emerging risk, 14 MAA-MerrillSPS-03-2025 produce accurate financial and/or nonfinancial, regulatory and operational reporting, detect or surveil potential misconduct or non- compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact the ability to develop products and relationships with MAA, Merrill and Bank customers, increase regulatory risk and operational losses, and damage our reputation. ITEM 9. DISCIPLINARY INFORMATION There are no legal or disciplinary events that MAA believes are material to a client’s or prospective client’s evaluation of MAA’s advisory business or the integrity of MAA’s management. In the past, the Bank and other of its Affiliates, including MLPF&S, have entered into certain settlements with regulators and other third parties and have been the subject of adverse legal and disciplinary events. The following is a summary of certain disciplinary events of Merrill. Clients can find information regarding these settlements in MLPF&S’ Form ADV Part 1A and ADV 2A brochure at adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a mark-up or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’ remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. On June 16, 2014, MLPF&S, without admitting or denying the findings, entered into a FINRA settlement relating to its failure to have an adequate supervisory system to ensure that certain clients received sales charge waivers for purchases of certain mutual funds’ Class A shares, which affected certain retirement accounts and certain clients with a particular type of brokerage account. This 15 MAA-MerrillSPS-03-2025 settlement resulted from MLPF&S self-identifying certain of these issues. MLPF&S consented to the imposition of a censure and a fine of $8 million and agreed to provide additional reimbursement to the agreed upon impacted clients. It has reimbursed all such impacted clients. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS MAA, a direct wholly-owned subsidiary of Merrill and an indirect wholly-owned subsidiary of BofA Corp., is an SEC-registered investment adviser that provides investment advisory services to clients that establish accounts under various investment advisory programs and the Program. Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through Affiliates, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. Merrill also acts as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high- yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As registered investment advisers, MAA and MLPF&S complete Form ADVs which they publicly file with the SEC (available at adviserinfo.sec.gov). For purposes of Form ADV, certain MLPF&S and/or MAA management persons are registered as registered representatives or associated persons of MLPF&S. In the future, certain MLPF&S and MAA personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of MLPF&S to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning, asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research including global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act and additional information about BofA Corp. can be found in publicly available filings with the SEC. The Bank’s Representatives may suggest or recommend that Program clients use its Affiliate’s securities account, execution and custody or other services for the client’s investment activity or use the services of its Affiliate. Similarly, Representatives may suggest or recommend that clients utilize MAA’s, Merrill’s or Affiliates’ products. Where a client uses their services or products, they will receive fees and compensation. Representatives typically do not, but may, as permitted by applicable law, receive compensation (the amount of which varies) in connection with these products and services. The Bank does not currently offer any Related Funds in the Program. The Bank may, however, include Related Funds as an investment product available in the Program in the future. To the extent permitted by applicable law, Merrill and/or its Affiliates would receive compensation with respect to shares of Related Funds in which a Program Account may be invested. MAA, Merrill and the Bank address conflicts from compensation described in this section and throughout this Brochure in a variety of ways, including through disclosure of the conflicts in this Brochure and the Bank’s SPS Disclosure Statement. Moreover, Representatives are required to recommend, investment products and securities and services that are appropriate for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. In addition, MAA and Merrill have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest – both those arising between and among Program Accounts as well as between Program Accounts and their business. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Conflicts of Interest and Information Walls The Bank, MAA, Merrill and BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within BofA Corp. possess material nonpublic information. 16 MAA-MerrillSPS-03-2025 Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., the Bank, Merrill and MAA evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide clients with full and clear disclosure or to take action to avoid or manage the conflict. Code of Ethics Each of Merrill and MAA has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering its personnel who are involved in the operation and offering of investment advisory services under the various investment advisory programs for which they are a registered investment adviser. Each Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that each of MAA and Merrill follows in conducting its business with integrity and professionalism. Each Code of Ethics covers requirements relating to employees complying with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. Covered personnel must certify receipt of the Code of Ethics. MAA and Merrill will provide a copy of their Code of Ethics to clients upon request to a Representative. MAA and Merrill each has imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, both have special policies requiring that certain personnel obtain specific approval of their securities transactions and have implemented procedures for monitoring these transactions, as well as those of all their employees. Agency-Cross and Other Cross Transactions At times, MAA or a Discretionary Manager may consider a security being sold by one investment advisory client to be appropriate for purchase by another investment advisory client account. In such cases, MAA or a Discretionary Manager may arrange to transfer or “cross” the security directly between the affected accounts. Any cross transactions in Accounts would be effected in accordance with applicable law and the Client Agreement, and only when the transaction is in the best interest of each party. Cross transactions generally will be effected at an independently determined market price and will not result in any additional compensation to MAA, the Bank or their Affiliates. There may be instances in which Merrill or its Affiliates has the opportunity to act as agent for both buyer and seller in a transaction for a client’s Account, in accordance with applicable law. This is called an “agency-cross” transaction. Since Merrill or its Affiliate generally will receive compensation from each party to an agency-cross transaction, there is a conflict between Merrill’s or its Affiliates’ responsibilities and loyalties to a Program client and to the other party to the transaction. Compensation received by Merrill or its Affiliate from the other party in an agency-cross transaction would be in addition to the fees described in this Brochure. Funds and Fund Compensation The Style Managers may recommend for purchase or purchase Funds, including Manager-Related Funds, for a client’s Account. The fees and expenses, if any, of these Funds, are in addition to Account Fees, unless such fees and expenses are credited to the Account. Each of the Funds pays investment management fees to its investment adviser and incurs other expenses. More complete information about the Funds, including risks, management fees and other charges and expenses, is contained in each Fund’s prospectus or other applicable disclosure document. Merrill, earns additional compensation for services rendered in connection with Funds. For example, Merrill or its Affiliate may execute brokerage transactions for a Fund included in a client’s Account or provide shareholder sub-accounting services to a constituent Fund used in a Strategy, for which it will be paid. Mutual funds purchased in a client’s Account will generally consist only of classes of shares with no contingent deferred sales charge (“CDSC”), or front-end sales loads (or with such charges waived). In addition, from time to time, a Fund may authorize Merrill or its Affiliates to make available to clients participating in the Program a class of shares of a Fund with a fee that is more beneficial to clients than the class of shares previously made available. In such circumstances, Merrill will effectuate the exchange to the other class of shares of the same mutual fund. As a general rule, the constituent mutual funds, and share classes that are part of a Strategy offered in the Program pay Merrill to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under Merrill agreements with each mutual fund (or its respective principal underwriter or other agent), Merrill provides daily sub-accounting services (either directly or through a subsidiary) to the holders of these types of mutual funds maintaining shares in Accounts as well as in Merrill securities accounts and receives the agreed-upon sub-accounting services fee. This cost is either borne by the mutual fund (like other fund expenses) as part of its 17 MAA-MerrillSPS-03-2025 operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of compensation vary by type of mutual funds, the mutual fund itself and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. For U.S. mutual funds, depending on the specific arrangements, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market mutual funds, the sub-accounting services asset-based fee is generally 0.005% per annum. Merrill does not retain compensation for sub-accounting services for funds held in Retirement Accounts and for Accounts enrolled in the Program. An Account will be credited with the Account’s pro rata share of any sub-accounting services fees paid by a Fund to Merrill related to shares of the Fund held in a client’s Account. Merrill, MAA and the Bank have direct or indirect conflicts of interest in selecting certain Fund products (or share classes) for inclusion as part of their product offering available to clients. Certain mutual funds or share classes that would otherwise meet their criteria for inclusion as part of their product menu but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting services fees that Merrill charges will not be selected, thereby limiting the available universe of funds (and share classes) available. In addition, the amount of the sub-accounting services fees varies among funds and, in certain instances, between share classes of individual funds. Merrill receives higher sub-accounting fee payments from mutual fund families that have higher fund assets held in its clients’ accounts because the service fee calculation is based off of the level of the asset holdings. Additionally, there is a benefit to Merrill because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. Merrill, MAA and the Bank address these conflicts of interest in the following ways. They disclose the nature of these sub-accounting service arrangements. The Bank also determines the compensation paid to Representatives on the same basis for all Program assets without regard to the amount of compensation it or its Affiliates receive. Representatives do not have an incentive to recommend certain Funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, the Bank and Merrill select Funds that are available and offered through the Program as well as in Merrill brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Furthermore, an Account will be credited with the Account’s pro rata share of any sub-accounting services fees paid by a Fund to Merrill related to shares of the Fund held in a client’s Account. Certain mutual funds offer a fund share class that does not include a sub-accounting services fee. Accordingly, clients should not assume that they will be invested in the share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. It is generally in a client’s best interest to purchase lower-fee share classes because the client’s returns are not reduced by additional fees and expenses. Representatives do not have an incentive to recommend or select share classes that have higher expense ratios because their compensation is not affected by the share class selected. Certain ETFs engage an Affiliate as an authorized participant. In that role, the Affiliate engages in creation and redemption transactions directly with the ETF and is compensated through its market making activities in the secondary market. To the extent that a Style Manager utilizes a Manager-Related Fund that is charged a fund management fee by the Style Manager or its affiliate, Merrill, MAA or the Bank will work with the Style Manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Style Manager Expense. The Bank, Merrill and MAA may in the future offer Related Funds in the Program. To the extent permitted by applicable law, MAA’s Affiliates would receive compensation with respect to shares of Related Funds in which a Account may be invested. Offering of Related Strategies and Use of a Related Strategy in a Client’s Account The Bank has approved of offering of certain Related Strategies. A client’s Representative can recommend a Related Strategy. In addition, in constructing a Related Strategy, the CIO as the Style Manager may include in its strategy model or recommendations to MAA a Related Strategy with a Style Manager Expense. Representatives do not have an incentive to recommend certain Strategies over others because they do not receive additional compensation. Merrill earns revenue from fees and payments from what it receives from Affiliates and from third-party investment managers, fund managers distributors and sponsors and other product providers (“Third-party Firms”) related to certain investments that are part of a Strategy in a client’s Account. Merrill does not retain compensation for Fund fees and expenses paid by Third-Party Firms for Accounts enrolled in the Program and an Account will be credited with the Account’s pro rata share of any such fees paid by a Fund to Merrill related to shares of the Fund held in a client’s Account. Elements of our management compensation are based on revenues to Merrill and management personnel of Merrill and other employees of Merrill, MAA and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is a financial incentive for Merrill management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. 18 MAA-MerrillSPS-03-2025 Related Entities may provide advisory services for one or more Strategies available for a client’s selection. To the extent the Bank or its Affiliate is a significant stockholder in a Related Entity, this fact will be disclosed in the relevant Strategy Profile. If a Related Strategy is selected, MAA and its Affiliates can receive an additional economic benefit. For this reason, a conflict of interest exists when the Bank or its Representative selects or assists clients in the selection of, as applicable, a Related Strategy (or replacement Related Strategy, if applicable). Affiliated Investments of a Style Manager Certain Strategies include Manager-Related Funds. The use of Manager-Related Funds creates a conflict of interest for the Style Manager relating to the Style Manager’s selection of Funds for the investment strategy and the receipt of potentially higher compensation or benefit based on the selection. The Style Manager has an incentive to select Manager-Related Funds over other Funds with lower expenses because the fees received for client Account assets in the Manager-Related Funds are their compensation. The Bank selects investment products, Strategies and Funds based on the investment merits of the particular investment products. Style Managers that use Manager-Related Funds have an obligation under their fiduciary duties to select investments that are based on the investment merits of the particular investment products. As to the use of Manager-Related Funds, we obtain the agreement of the Style Manager that any fees or expenses with respect to a Manager-Related Investment, other than certain costs incurred within such product and reflected in its returns, will be borne by the Style Manager. In addition, where a Style Manager uses a Manager-Related Fund that is charged fund management fees by the Style Manager or its affiliates, Merrill will work with the Style Manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Style Manager Expense. Provision of Diversified Financial Services BofA Corp. is a diversified financial services company that generally seeks to provide a wide range of services to retail and institutional clients for which it receives compensation. As a result, BofA Corp., Merrill, the Bank and their Affiliates can be expected to pursue additional business opportunities with the entities whose investments Merrill, the Bank and its Affiliates recommend or make available to clients. Consistent with industry regulations, these services could include: banking and lending services, sponsorship of deferred compensation and retirement plans, recordkeeping services, investment banking, securities research, institutional trading and prime brokerage services, custody services, investment advisory services, licensing arrangements involving indices and effecting portfolio securities transactions for clients. Firm professionals involved with the offering of Funds to individual investor clients may introduce Fund distributors, sponsors, service providers or their affiliates to other services that BofA Corp., Merrill, the Bank and their other Affiliates provide and earn additional compensation for the services. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for an Account. Additional information regarding these relationships are publicly available in Regulation NMS Rule 606 reports that Merrill files with the SEC. Other Relationships and Interests; Activity by MAA, Merrill and their Personnel and Affiliates MAA, Merrill, the Bank and their Affiliates have business relationships with the officers, directors or employees of a variety of clients, including corporations, pension and retirement plans, and other entities. These business arrangements create a conflict of interest to the extent that these individuals have any role or influence in the hiring or retention of MAA, Merrill, the Bank and their Affiliates. The Bank, Merrill and other of their Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs (“In-Scope Funds”) by the Bank, Merrill, their Affiliates and those of their clients that have granted discretion to MAA, the Bank, Merrill, their Affiliates, Bank Representatives, and/or Merrill financial advisors (“discretionary clients”) to avoid potential restrictions on the ability of their Affiliates to engage in principal trading and other transactions with In-Scope Funds. A portion of the aggregate ownership limit is attributed to their Affiliates. When their Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to the Bank, Merrill or their Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because the Bank’s, Merrill’s and their Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. From time to time, a shareholder of BofA Corp. could acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within an Account, such as buying or selling securities issued by the shareholder or its Affiliates, will be limited. Cash Balances and the Cash Sweep Program MAA, Merrill, the Bank or their Affiliates receive additional economic benefits from cash held in clients’ Accounts. A Strategy includes a cash allocation for operational and implementation and/or investment purposes as directed by the Style Manager. The cash allocation will be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations or rebalancing being made and market conditions. Until invested, the cash for these investments is typically held in a cash balance and 19 MAA-MerrillSPS-03-2025 subject to the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the Style Manager as a temporary investment pending purchase of the individual security. To the extent that a cash alternative vehicle is not selected for the Account’s cash allocation by the Style Manager, there is a conflict of interest between the client and Merrill and/or MAA and the Bank because the cash allocation will be maintained in the Account as a cash balance. Until invested, cash balances will be swept to bank deposit accounts at the Bank through the Cash Sweep Program. Depending on the client’s election, cash balances will be swept to the Bank or to a money market mutual fund available under the Cash Sweep Program. If cash balances are deposited in a deposit account with the Bank, the Bank will receive additional economic benefits from cash investments held in the client’s Account and the use of the deposits. Through the Cash Sweep Program, the Bank receives a stable, cost-effective source of funding. The Bank uses the cash funds deposited in the bank deposits to fund its current and future lending, investment and other business activities. Its participation in the Cash Sweep Program increases deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” earned on the deposits — the difference between the interest paid on the bank deposits and other amounts paid out to others related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in clients’ Accounts that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more the Bank benefits. Cash balances swept to a deposit account of the Bank will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts that is paid is variable and may change at any time after the Account is opened without notice or limit. The interest rate earned in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. The conflicts of interests associated with the Cash Sweep Program and the deposit accounts are addressed in a variety of ways, including through disclosure in this Brochure, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to a client’s participation in the Cash Sweep Program. Management personnel of the Bank, MAA, Merrill and their Affiliates receive incentive compensation based on a number of factors including the profitability of the Bank, Merrill and BofA Corp., which is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of this management compensation approach. There is a financial incentive for management to structure the scope and approach of the compensation award program to result in revenue for the Bank, Merrill and BofA Corp. We maintain policies and procedures, including governance approval requirements, that are designed to review and mitigate any financial incentive or conflict to favor any one security type or investment product or service. We also provide disclosures of these conflicts in the Brochure and other client documents. Relationships With Asset Managers, Sponsors and Style Managers MAA, Merrill and the Bank, as well as their other Affiliates, have business relationships with investment managers, including Style Managers, Fund managers, distributors and sponsors, and insurance companies and other product providers (“Third Party Firms”). Bank Affiliates make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to these Affiliates including effecting transactions in the ordinary course of business for Funds and product vehicles managed or sponsored by them. These Affiliates also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to such Affiliates by a Third-Party Firm is additional compensation for services provided. In order to make investment products or services available to clients, MAA, Merrill and/or their Affiliates incur certain technology and infrastructure costs. While they do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, MAA, Merrill and/or any Affiliate reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that any such support is received from Third-Party Firms, it creates a conflict with their ability to use strictly objective factors when selecting product sponsors to make available. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. The nature of MAA’s, Merrill’s and their Affiliates’ relationships in general with Third-Party Firms is disclosed. Representatives do not have an incentive to recommend certain investment products, including managed strategies, over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, Strategies and Funds that are available through the Program and through Merrill investment advisory programs are selected based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Merrill, MAA and the Bank have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice that its representatives provide. 20 MAA-MerrillSPS-03-2025 Certain Third-Party Firms periodically participate in internal training and education conferences (“Conferences”) for invited financial professionals, which may include Representatives and employees of MAA, the Bank, and Merrill. These financial professionals may include employees who cover product, Chief Investment Office and home office support functions (“Non-Field Employees”). Conferences are organized on either a national or local level. Client and prospect events (e.g., seminars, trade shows, booth events) can also be held where Third-Party Firms participate (“Client Events”). Third-Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending financial advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with a number of Conferences and Client Events in the amount of approximately $21 million. Certain Third-Party Firms periodically host or participate in educational meetings (“Manager Meetings”) that provide Representatives and Merrill and/or MAA financial professionals, including Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attendees (not including any Representative or CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of charitable events and causes that we requested or initiated with the Third-Party Manager in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives for Representatives and Merrill and/or MAA financial professionals to recommend products of participating Third-Party Firms. They give those participating in Conferences, Client Meetings and Manager Meetings with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for non-Field Employees to select products of the Third-Party Firm. These conflicts are addressed in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill or the Bank for, or pay the costs of, such events in order for their investment products to be made available. Neither Merrill nor MAA incentivize Non-Field Employees to approve particular products of a Third-Party Firm. Third-Party Firms are not permitted to condition their payment on any amount of sales of their products or services. Third-Party Firm reimbursements for costs of meetings and events must align to applicable internal policies and policy limits and are subject to supervision and oversight that is reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice provided. Representatives are subject to Bank supervision and oversight and do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Representatives can attend Conferences and Manager Meetings described above and must abide by Bank policies and guidelines. Additionally, the Bank does not incentivize Representatives to recommend the products or services of a Third-Party Firm that makes contributions to charitable events or causes over those that do not. Personnel from Third-Party Firms will, from time to time, meet and work with financial professionals, including Representatives and Non-Field Employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. There are internal policies and procedures in place that limit Third-Party Firms from providing or paying for gifts and entertainment other than as permitted by and subject to the limits established under internal policies. In general, our financial professionals may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. Gifts or entertainment conditioned on achieving a sales target is not permitted. Permitting Third-Party Firm personnel access to our financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. Consistent with applicable laws, management and employees of BofA Corp. and its Affiliates are provided a broader level of access and exposure to Merrill, Representatives and other personnel, marketing events and materials, and client-related and other information. Such access and exposure is not available to other asset managers and enhances the ability of BofA Corp. Affiliates to distribute their funds and other investment products through the Bank, Merrill and MAA. In addition to monetary limits, the Bank and Merrill each have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. The policies, procedures and supervisory controls in place have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. Offering of Investments or Programs Managed by Us or Our Affiliates MAA, Merrill and their Affiliates act in a variety of capacities to a wide range of clients. From time to time in the course of those duties, confidential information is acquired that cannot be divulged or acted upon for advisory or other clients. Similarly, MAA and Merrill may give advice or take action with regard to certain clients, including the Bank for the Program, which differs from that given or taken with 21 MAA-MerrillSPS-03-2025 regard to other clients. This includes the advice given or actions taken for certain securities, Funds or Strategies or Style Managers. In some instances, the actions taken by Affiliates for similar services and programs will conflict with the actions taken by MAA. This is due to, among other things, the differing nature of the Affiliate’s investment service and differing processes and criteria upon which actions are taken. MAA, Merrill and their Affiliates provide some or all of the same services offered in the Program through other financial firms, either with their Affiliates or with firms that are unaffiliated. Certain of these services have fee rates that differ from the Account Fees. Merrill or one of its Affiliates may have a position in or enter into “proprietary” transactions in securities purchased or sold for clients, including clients participating in the Program, and benefit from such securities positions or transactions. MAA and Merrill address these conflicts through disclosure in this Brochure. Moreover, the Representatives are required to recommend investment advisory programs, other investment programs, investment products and securities that are appropriate for each client based upon the client’s investment objectives, risk tolerance and financial situation and needs. In addition, MAA, Merrill and their Affiliates have established, as appropriate, a variety of restrictions, procedures and disclosures designed to address potential conflicts of interest – both those arising between and among Accounts as well as between Accounts and MAA’s and Merrill’s other business. For example, MAA and Merrill personnel are also subject to personal trading restrictions as detailed in their respective policies and procedures and Code of Ethics. These policies and procedures and the Code of Ethics require certain MAA personnel to pre-approve certain securities transactions, disclose their investment accounts, provide an annual holdings report, and provide a quarterly transaction report. Merrill and its Affiliates and related business divisions, offer their own managed products or wrap programs that are similar to this or other Bank programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including as to recommendations and review determinations. This is due to, among other things, the differing nature of Merrill’s and MAA’s investment advisory services and differing processes and criteria upon which determinations are made. In addition, other BofA Corp. Affiliates or divisions, including Merrill, offer their own managed products or wrap programs that are similar to the Program. In particular, the CIO also may provide advice and/or recommendations to these different Affiliates or divisions, including advice related to the recommendation of certain investment managers. Importantly, the advice and recommendations provided for the Program will be different from, or even conflict with, the advice and guidance provided to other Affiliates or programs. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. For example, CIO may recommend a specific investment manager for inclusion in a Merrill program, but not the Program. In addition to providing advisory services to Program participants, Representatives also service other advisory and banking accounts for clients who do not participate in the Program, and offer and provide other services to clients who, in addition to participating in the Program, have other relationships or dealings with Merrill, MAA or their Affiliates. The Bank, MAA and their Affiliates also, from time to time, enter into specialized agreements to provide particular or unique services to certain clients, subject to negotiated fees. ITEM 12. BROKERAGE PRACTICES Transactions in Program Accounts All transactions in a Program Account, except as provided below, will be effected by or through Merrill or its Affiliates, acting as agent. In effecting transactions for a client’s Program Account, Merrill and its Affiliates will be acting exclusively as broker-dealer. If Merrill or its Affiliates effect the transaction through an Unaffiliated Trade Counterparty, we will take into account various factors, such as the nature and quantity of the securities involved, the markets involved, the reputation and perceived soundness of the firm, the firm’s clearance and settlement capabilities and other factors relevant to the selection of a broker-dealer for the execution of client securities transactions. The client should understand that the direction by the client and/or the Bank to use Merrill and its Affiliates to effect transactions in a Program Account may result in less advantageous execution, including greater spreads (the difference between the bid and the offer price) or less favorable net prices, than if an Unaffiliated Trade Counterparty were to execute the transaction. However, because clients generally are not paying for brokerage costs, any added expense typically will be absorbed by the Bank. The Bank pays an asset-based fee for these and other services provided by Merrill through the Program. In effecting transactions, Merrill or its Affiliates will be acting exclusively as a broker-dealer and trades will be handled by Merrill consistent with its best execution and other regulatory obligations. Even in meeting these obligations, it is possible that the client may be able to obtain better prices for transactions if such trades were executed with other broker-dealers or third parties, including having smaller spreads (the difference between the bid and the offer price) or at more favorable net prices. Merrill seeks to effect transactions correctly, promptly and in the best interests of clients. In the event an error occurs in its handling of client transactions, Merrill seeks to identify and correct any errors as promptly as possible without disadvantaging the client. In general, in instances where Merrill is responsible for effecting the transaction, Merrill may: (i) reimburse clients for any losses directly resulting from trade errors; (ii) credit to the client any profits directly resulting from such trade errors that are corrected after the settlement of the transaction; or (iii) retain any profits directly resulting from such trade errors that are corrected prior to the settlement of the transaction. 22 MAA-MerrillSPS-03-2025 As discussed in the section “Agency-Cross and Other Transactions”, there may be instances in which Merrill or its Affiliate (or a Discretionary Manager or its Affiliate, if applicable) will have the opportunity to engage in cross or agency-cross transactions, subject to applicable law. Merrill or its Affiliate or a Discretionary Manager or its affiliate, if applicable, would engage in such transactions only when the transaction is in the best interest of each party. MAA may, but is not required to, aggregate orders for the sale or purchase of securities for a client’s Account with orders for the same security for its other clients, proprietary accounts or the accounts of its employees and/or related persons, without a client’s prior authorization. In such cases, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro rata share of any fees. If a discretionary Strategy is selected, the Discretionary Manager has the authority to place orders for transactions with broker-dealers that it selects, including Unaffiliated Trade Counterparties, when consistent with their obligation to seek best price and execution. For certain Discretionary Managers, MAA provides administrative services to assist with the placement of orders at its direction. A Discretionary Manager may, but is not required to, aggregate orders for the sale or purchase of securities for the Strategy with orders of the same security for other clients in the same Strategy (either at Merrill or at other firms), for its own accounts or for the accounts of its employees and/or related persons. Certain Discretionary Managers that place orders for particular (but not all) transactions for their Strategies with Merrill and its Affiliates or with an Unaffiliated Trade Counterparty if the Discretionary Manager determines, after consultation with MAA, that: (1) they are able to aggregate a particular trade for Program clients in a block trade and (2) they expect such aggregation will be for the overall benefit of Program clients. A transaction that the Discretionary Manager has placed through an Unaffiliated Trade Counterparty for a particular Strategy is commonly referred to as a “step out” or “step out trade.” For certain Style Managers that are Discretionary Managers, we may provide administrative support to the Discretionary Managers to assist with the placement of orders at their direction. In selecting a firm to execute transactions and the markets in which the transactions will be executed, the Discretionary Manager is not obligated to solicit competitive bids for each transaction or seek the lowest available commission cost so long as it reasonably believes that the firm it selects can be expected to obtain a “best execution” market price on the particular step out trade. Each Discretionary Manager is responsible for ensuring that it complies with its own best execution obligations. Certain Discretionary Managers have historically executed all or a portion of their trades as “step outs.” Frequently, these trades have been for fixed income or other securities for which a markup or markdown is charged by the executing broker-dealer (generally referred to as “dealer spread”). The client will bear the cost of this dealer spread amount and the Account Fee does not cover this expense or cost. The Discretionary Manager may also execute step out transactions for certain equities and other securities for which the executing broker-dealer charges a brokerage commission. These trades have historically been for foreign securities for which a brokerage commission had been charged by the executing Unaffiliated Trade Counterparty. Under the Program, other than as noted below as to Foreign Ordinary Shares and American Depositary Receipts (“ADRs”), the client will not have to pay this Unaffiliated Trade Counterparty brokerage commission. The Style Manager Expense rates vary among Style Managers and it is possible that the Style Manager Expense rate for a Discretionary Manager is higher than that for other Style Managers with the same or similar Strategies. The client could be deemed to be indirectly bearing the cost of the step out trades by virtue of any such higher Style Manager Expense rate. Because the client will pay the same Style Manager Expense rate regardless of whether or not a Discretionary Manager has a step out trade, this creates a material conflict of interest, or the appearance of a material conflict of interest, between the Discretionary Manager and the client. The Discretionary Managers identified as trading through Unaffiliated Trade Counterparties, either on a regular or a limited basis, are listed in the document entitled “Style Manager Step Out Information Document” available at ml.com/SMA. Clients may also request a copy from their Representative. Information in this document is based solely on the historical information that has been provided by the Discretionary Managers and MAA makes no representation regarding the future trading practices of any Discretionary Manager for any Strategy. When Merrill through its Affiliate executes transactions in foreign ordinary securities outside the United States, it may use the services of foreign Unaffiliated Trade Counterparties. These foreign Unaffiliated Trade Counterparties may handle the client’s order as agent and assess a commission charge, or they may transact as principal and receive a dealer spread or mark-up/down. Additionally, to the extent a foreign currency conversion transaction is required to facilitate trade settlement, the foreign Unaffiliated Trade Counterparty (or its affiliate) effecting the currency conversion will be remunerated in the form of a dealer spread or mark-up/down. Although the remuneration is not disclosed in net price transactions, Merrill will undertake, at a client’s written request, to determine or ascertain from the counterparty this remuneration in a given transaction for the client’s Account. Foreign Unaffiliated Trade Counterparties also may charge commissions and/or dealer spreads when foreign issuers terminate an ADR facility, thereby necessitating conversion of ADRs to foreign ordinary share form. In such circumstances, the prices obtained for the post-ADR security may be lower than if the ADR remained intact. These commission charges and/or dealer spreads are in addition to the Account Fee. Additional information about execution expenses can be found in the Bank’s SPS Disclosure Statement. 23 MAA-MerrillSPS-03-2025 ITEM 13. REVIEW OF ACCOUNTS Program Account Reviews An important part of the Program relationship involves providing clients with the opportunity to engage in Account reviews periodically in which the client’s Representative reviews the client’s Account’s progress toward goals. Because these reviews provide the client with important and necessary information relating to the client’s Account, the client is strongly encouraged to take advantage of these opportunities to participate in these Account reviews with the client’s Representative. At least annually, the Bank will contact clients to request updated information and determine whether there have been any changes in a client’s financial situation and investment objectives, and whether the client wishes to impose any reasonable restrictions, or reasonably modify existing restrictions, on the management of the Account or reasonably modify existing restrictions. Additionally, on a quarterly basis, the Bank will notify clients in writing to contact the Bank if there have been any material changes in a client’s financial circumstances that might affect the manner in which the client’s assets should be invested. Clients should promptly inform the Bank in writing of any change in their financial circumstances that might affect the manner in which their assets should be invested. Any such information received that is deemed material or appropriate will be promptly forwarded by the Bank to MAA and, if applicable, any Discretionary Manager that may manage a portion of the client’s Account. If the changes provided are material in nature, a review of the client’s Account may be in order. Representatives will be reasonably available to clients for consultation. In addition, MAA and each Discretionary Manager have agreed to make one or more of their advisory or investment personnel reasonably available for consultation with clients or a joint consultation with their Representative regarding a Strategy, if requested by the client. Clients should contact their Representatives to arrange for a consultation with a Discretionary Manager or MAA. Client Reports Under the Program, clients will receive statements from the Bank of Account activity and current holdings on a quarterly or monthly basis, depending on client preference. Clients also may request periodic performance reviews with their Representatives, depending on a client’s relationship with the Bank. This review generally includes a presentation of the client’s Account performance, based on information reflected on the Bank’s and/or MAA’s records, supplemented by information that may be provided by the client, the Bank, Merrill, and/or Style Managers, and ongoing comparisons of Account performance with selected industry indices and/ or benchmarks. Account statements will be the definitive record of all activity in an Account. In the event of any discrepancy between the account statements and any performance reports received, the client account statements will control and prevail. MAA and its Affiliates may receive (and provide to clients) information about the performance of Style Managers and/or Strategies available through the Program that is not specific to the performance of any client Account. Performance results of the Style Managers are generally reported to MAA by third party vendors or the Style Managers, on a standardized basis. While information collected by MAA and its Affiliates regarding Style Managers and/or Strategies is believed to be reliable and accurate, MAA, the Bank and their Affiliates will not necessarily independently review or verify any such information, or be obligated to do so, nor will MAA, the Bank and their Affiliates audit or verify that these results are calculated on a uniform or consistent basis. Clients should understand that: • Past performance does not guarantee future results. • Performance may reflect (primarily or solely) management of accounts outside of the Program and the performance of Accounts may vary from “composite” performance due to factors such as Account size, timing of investments, client investment objectives and reasonable restrictions, the Program’s brokerage practices, as described above, and MAA’s management of a client’s Accounts. • Client risk parameters or benchmark indices are provided for comparison purposes only and there is no guarantee that they will be met or exceeded. Trade Confirmations Clients may elect to receive periodic statements (at least quarterly) detailing their Account activity instead of trade-by-trade confirmations. Periodic statements will contain the same information that would be included in the trade-by-trade confirmations. The client’s initial direction regarding receipt of trade-by-trade confirmations will apply to all of the client’s Accounts, including any changes to and additional Style Managers selected by the client, until such direction is changed. The client’s election to receive periodic statements in lieu of trade-by-trade confirmations will not affect the calculation of or amount of the client’s Account Fee; is not a condition to entering into or continuing participation in the Program; and may be rescinded by the client at any time by written notice to the Bank for any of the client’s Accounts. The client may request that its Representative provide to the client, at no additional cost, an interim update and further details concerning any transaction effected between periodic statements. Clients also will have access to this information via online access at privatebank.bankofamerica.com/login. If the client elects to receive periodic statements in lieu of trade-by-trade confirmations, the client may later choose to receive, and the Bank or its Affiliates will provide to the client at no additional cost, any confirmations for transactions effected for up to a one-year period preceding the client’s last periodic statement and trade-by-trade confirmations for all 24 MAA-MerrillSPS-03-2025 subsequent transactions. Confirmations or periodic statements will be sent or made available to the client, MAA, or any Discretionary Manager, as applicable and in accordance with applicable law. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION MAA, Merrill and their Affiliates have business relationships with many investment managers, including those participating in the Program, separate and apart from the Program. For example, Style Managers may direct clients’ transactions to Merrill and receive research, execution, custodial, pricing and other services offered by Merrill in the normal course of business. Merrill, the Bank and its Representatives may receive compensation in connection with such transactions and other services. Clients are encouraged to speak with their Representatives to discuss any questions that they may have about existing or potential conflicts of interest relating to their selected Portfolios or Strategies, including any business relationships that the relevant Funds or Style Managers have with MAA, BofA Corp., Merrill or their Affiliates or Representatives. As discussed previously in the section “Other Compensation and Conflict of Interest Considerations—Conflicts of Interest Related to the Selection of Style Managers,” Style Managers pay, or reimburse MAA or its Affiliates for, various costs relating to the Program and asset management generally. These conflicts are addressed through disclosure to clients in this Brochure and the Bank’s SPS Disclosure Statement. ITEM 15. CUSTODY Neither MAA nor Merrill maintains physical custody of client assets. Generally, the Bank or another Affiliate will maintain physical custody of securities for Program Accounts. Clients should receive periodic statements from the Bank or its Affiliates or, to the extent client assets are not custodied with the Bank or an Affiliate, other broker-dealer, bank or financial services firm that serves as qualified custodian. Clients should carefully review these statements. Clients who do not receive such account statements are encouraged to follow-up directly with their custodian and request such statements. To the extent a client receives additional reports from MAA or Merrill, they are urged to compare these reports to the account statements they receive from the qualified custodian. MAA’s and Merrill’s reports are generally preliminary and may vary from custodial statements based on accounting procedures, reporting dates, valuation methodologies and other factors. They are not intended to be a substitute for account statements provided by a qualified custodian and should not be used for official purposes. ITEM 16. INVESTMENT DISCRETION MAA generally has discretionary investment authority to implement one or more Strategies in a client’s Program Account based on the recommendations of the Strategies’ Style Managers. Generally, clients or their authorized representatives who choose to grant MAA discretion sign a Client Agreement with the Bank to that effect. MAA has entered into investment manager advisory agreements with a variety of Style Managers, which may or may not be Related Entities. A list of the Style Managers available through the Program appears in the Style Manager Expense Rate Supplement to the Bank’s SPS Disclosure Statement. In general, Style Managers provide advisory services through the Program by furnishing investment recommendations to MAA for one or more Strategies based on model portfolios in accordance with the applicable Strategy Profiles. MAA is responsible for implementing each Strategy based on the advice provided by a Style Manager, except when the Style Manager acts as a Discretionary Manager. MAA generally will implement a Style Manager’s recommendations for a Strategy without change, subject to any reasonable client-imposed restrictions, cash flow and other considerations. Certain of the Style Managers are Discretionary Managers that provide discretionary investment advisory services to clients that have selected the relevant Portfolio. A Discretionary Manager makes and implements investment decisions for a client’s Program Account in accordance with the Discretionary Manager’s Strategy Profile. MAA does not implement investment decisions for any portion of a client’s assets that is managed by a Discretionary Manager. However, MAA is responsible for enforcing any client- imposed reasonable restrictions for a client’s Program Account. MAA’s discretionary authority may be limited by the terms of the Client Agreement, Reasonable Investment Restrictions imposed by a client, Bank instructions, and MAA’s obligation to comply with regulatory requirements. As discussed above, MAA’s authority also may be limited where a client’s Program Account is invested with a Discretionary Manager. MAA will respond to corporate actions, including reorganizations, with respect to securities held in the client’s Program Account. MAA will not advise clients or act on clients’ behalf regarding any legal matters, including bankruptcies and class action lawsuits. The Bank will advise or act for clients in the event of a class action involving securities held in the client’s Program Account. ITEM 17. VOTING CLIENT SECURITIES The Bank or clients may not delegate to MAA or Merrill, and neither MAA nor Merrill accept or assume from the Bank or clients, proxy voting authority for any securities in a Program Account. Pursuant to separate arrangements between the client and the Bank, unless the client has notified the Bank otherwise, the client authorizes the delegation, on its behalf, of proxy voting authority for securities in an Account to the Bank and a proxy voting service selected by and subject to oversight by the Bank. Additional information regarding the Bank’s proxy voting arrangement for the Program, the proxy voting service and/or the Bank’s proxy voting policies can be obtained by contacting the client’s Representative. 25 MAA-MerrillSPS-03-2025 ITEM 18. FINANCIAL INFORMATION Not applicable because (1) MAA and Merrill do not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (2) there is no financial condition of which MAA is aware that is reasonably likely to impair its ability to meet contractual commitments to clients; and (3) MAA and Merrill have not been the subject of a bankruptcy petition at any time during the past 10 years. ADDITIONAL INFORMATION Covered Entities under the Volcker Rule Certain entity clients that qualify as “family wealth management vehicles”, or FWMV clients, may receive investment advisory services under this Program or other investment advisory programs where MAA and/or Merrill act as an investment adviser as well as lending services and engage, where permitted, in principal transactions. In doing so, they rely on the exception under the Volcker Rule implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Client Agreement. For certain entity clients that are deemed “covered fund” clients under the Volcker Rule, it is not permitted to offer both investment advisory services and the availability of margin, lending or other extensions of credit from the Bank, MAA, Merrill and any of their Affiliates or engage in certain principal transactions. Certain other transactions between the Bank or its Affiliates and the entity client will also be prohibited. 26 MAA-MerrillSPS-03-2025 GLOSSARY “Account Fee” means the IM&T Fee and the Style Manager Expense. “ADR” means American Depositary Receipt, which is a receipt for shares of a foreign company held by a U.S. financial institution that entitles the holder to rights and obligations of the underlying shares, including dividends and capital gains and losses. “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Affiliate” means a company that is controlled by, in control of or under common control with another company. “BofA Corp.” means Bank of America Corporation, the parent company of the Bank, MLPF&S, MAA and other Affiliates. “Bank of America Workplace Benefits” means the group providing specialized retirement account services, which operates through the Bank and other subsidiaries of BofA Corp. “Bank of America Private Bank” means the fiduciary business of Bank of America, N.A, which operates through the Bank and other subsidiaries of BofA Corp. “BofA Corp.” means Bank of America Corporation, the parent company of the Bank, MLPF&S, MAA and other Affiliates. “BofA Global Research” means the business unit of BofAS and/or one or more of its Affiliates that produces research material for clients. “BofAS” means BofA Securities, Inc., an Affiliate of MAA. “Brochure” means the Form ADV, Part 2A (including any amendments or supplements) of MAA relating to the advisory services it provides in connection with the Program, as updated from time to time. “CIO” means the Chief Investment Office, a business division consisting of Bank and Merrill employed personnel, which acts as a Related Entity for certain Related Strategies and which engages in the CIO Review Process for the review of Funds and investment strategies. “Code of Ethics” means MAA’s Investment Adviser Code of Ethics. “Dealer spread costs” means mark-ups, mark-downs and/or dealer spread charges imposed by an Unaffiliated Trade Counterparty or a trade counterparty that is an Affiliate. “Discretionary Manager” means a Style Manager that has full discretion to effect transactions for an Account with Merrill and its Affiliates or an Unaffiliated Trade Counterparty and to determine which securities to buy, sell or hold in its Strategy. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. “ERISA Plan” means a plan subject to the fiduciary responsibility provisions of ERISA or any other entity deemed to hold assets of such a plan. “ETF” means a Registered Fund that is an exchange-traded fund. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “Funds” means a registered and unregistered investment company, including a mutual fund, a money market fund, a closed-end fund, an ETF, an NTF, and any other pooled investment vehicle. “MAA” means Managed Account Advisors LLC. “Manager-Related Fund” means a Fund sponsored or advised by a Style Manager (including a Related Entity) or its Affiliates. “Merrill” or “MLPF&S” means Merrill Lynch, Pierce, Fenner & Smith Incorporated. “NTFs“ means mutual funds and ETFs registered with the SEC that are classified by us as Alternative Investments. “Program” means Select Portfolio Solutions, an investment service offered by the Bank. “Program Account” or “Account” means an account for investment of assets of the client through the Program. “Registered Fund” means any Fund that is registered under the Investment Company Act of 1940. “Related Entity” means an Affiliate of BofA Corp. or an entity in which BofA Corp. or an Affiliate has a material ownership interest. Related Entities include the Bank, MAA and Merrill. “Related Fund” means any Fund sponsored, managed, or advised by the Bank or a Related Entity. “Related Strategy” means any investment strategy sponsored, managed or constructed by the Bank, MAA, Merrill or a Related Entity. “Representative” means the client’s representative from Bank of America Private Bank or Bank of America Workplace Benefits. “Retirement Account” means an ERISA Plan, a U.S. tax-qualified plan of self-employed persons, a U.S. individual retirement account, or any other plan, arrangement or entity subject to Section 4975 of the U.S. Internal Revenue Code of 1986, as amended. “Rule 12b-1 fees” means fees paid for distribution of mutual funds pursuant to a plan made under Rule 12b-1 under the Investment Company Act of 1940. “SEC” means the Securities and Exchange Commission. “Securities Act” means the Securities Act of 1933, as amended. “SPS Disclosure Statement” means the disclosure statement of the Bank, including any supplements and as updated from time to time, for the Program. “SIPC” means Securities Investor Protection Corporation. “Strategy” means one or more investment styles or disciplines that may be selected for a client’s account, either individually or in combination with other Strategies, and that may include specific asset classes or asset types such mutual funds, ETFs or other Funds, in each case as determined by the Bank or MAA from time to time. “Strategy Profile” means a written document that contains a description of a Strategy offered in the Program and may contain other information relating to the Strategy or Style Manager. “Style Manager” means an investment manager that constructs and/or manages its respective managed strategy portfolios in a Strategy which can be a third party investment manager and the Bank, MAA, Merrill or another Related Entity. “Style Manager Expense” means the portion of the client’s Account Fee for the Style Manager’s services that is based on Program Assets allocated to the Style Manager’s Strategy. The Style Manager Expense rate varies depending on the Style Manager. “Unaffiliated Trade Counterparty” means a bank, broker or dealer other than Merrill or a Merrill Affiliate. “Unrelated Money Market Fund” means a registered money market fund that is not managed by Merrill or a Related Entity. Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. © 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated Printed in the U.S.A. 27 MAA-MerrillSPS-03-2025

Merrill Lynch Fiduciary Advisory Services Program BROCHURE Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 (800) 637-7455 www.ml.com This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or “Merrill”) relating to the Merrill Lynch Fiduciary Advisory Services Program. If you have any questions about the contents of this Brochure, please contact us at 800.MERRILL (800.637.7455). Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about MLPF&S also is available on the SEC’s website at http://www.adviserinfo.sec.gov/. The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency, are not a deposit or other obligation of or guaranteed by MLPF&S, Bank of America Corporation (“BofA Corp.”) or any of its affiliates and are subject to investment risks, including possible loss of principal. March 21, 2025 Workplace Benefits is the institutional retirement and benefits business of Bank of America Corporation (“BofA Corp.”) operating under the name “Bank of America.” Investment advisory and brokerage services are provided by wholly owned non-bank affiliates of BofA Corp., including Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as "MLPF&S" or "Merrill"), a dually registered broker-dealer and investment adviser and Member SIPC. Banking activities may be performed by wholly owned banking affiliates of BofA Corp., including Bank of America, N.A., Member FDIC. Merrill Lynch Life Agency Inc. (MLLA) is a licensed insurance agency and wholly owned subsidiary of BofA Corp. Investment products offered through MLPF&S and insurance and annuity products offered through MLLA: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value Are Not Deposits Are Not Insured by Any Federal Government Agency Are Not a Condition to Any Banking Service or Activity  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE MATERIAL CHANGES On March 22, 2024, Merrill filed its last annual update for its Merrill Lynch Fiduciary Advisory Services Program brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated the “Disciplinary Information” section to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our Advisors, field management employees and non-field employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Client Referrals and Other Compensation” at section “B. 1. Relationships With Third-Party Firms – Third-Party Firm Office Access, Gifts and Entertainment.” MATERIAL CHANGES AND ENHANCEMENTS MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes and Enhancements • We updated the “Disciplinary Information” section to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease- and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” • We have updated our disclosures throughout the Brochure to make other enhancements. I  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE September 30, 2024 Brochure Update Material Changes and Enhancements We updated the Brochure to introduce the Program Solutions Manager (PSM), a new role at Merrill that is a type of Designated Advisor qualified to deliver program services. A PSM can open defined contribution plan accounts and offer and provide Fiduciary Advisory Services (FAS) and Education and Plan Services (EPS) services but is not eligible to offer or provide other Merrill products and services that a typical Advisor can offer. See the following sections for details: Advisory Business; Fees and Compensation; Code of Ethics, Participation or Interest in Client Transactions and Personal Trading; Client Referrals and Other Compensation. II  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE TABLE OF CONTENTS MATERIAL CHANGES I ................................................................................................................. .............................................................................................................. TABLE OF CONTENTS II ADVISORY BUSINESS About Merrill Lynch, Pierce, Fenner & Smith Incorporated Fiduciary Advisory Services ................................................................................................................ ........................................................................... ................................................................................................................................ ……………………………………………………………………………………………. ……………………………………………………………………………………………… ……………………………………………………………………………………………… ………………………………………………………………………………………………………........ Summary Description of Services Investment Advisory Agreement Detailed Description of Services Limitation Of Services Termination Qualification Of Designated Advisors Other Investment Advisory Programs and Services ………………………………………………………………………………………………………………..………… …………………………………………………………………………………..… ............................................................................ .............................................................................................................................. Assets Under Management 1 1 1 2 3 4 9 10 10 11 11 FEES AND COMPENSATION Program Fees Calculation Of Program Fees 11 11 12 12 ........................................................................................................................ ..................................................................................................................................................... ........................................................................................................................... Calculation Of Program Fees For Clients With Record Keeping Services Through Merrill Or Our ...................... ……………………………………………….….. Advisor Alliance Non-Group Annuity Providers Calculation Of Program Fees For Clients With Record Keeping Services Through External Providers Calculation of Program Fees For Clients With Group Annuity Providers Excluded Assets Initial Billing Of Program Fees Billing Upon Termination Of Service Invoices And Methods of Payment Invoices Methods Of Payment …………………… .............................................................................. …………………………………..... ………………………………….. ……………………………………………………………………………………………………………………. ………………………………………………………………………………………………. ………………………………………………………………………………….…... ................................................................................................................. ………………………………………………………………………………………………………………………………… ………………………………………………………………………………………………………….... ................................................................................................................................. ……………………………………………………………………………...... ........................................................................................................ ........................................................................................................................................... ............................................................................................................. Other Fees And Expenses Treatment of Cash Balances in Your Account Compensation For The Sale of Products Sources of Revenue Conducting Business Through Merrill 12 13 13 13 13 13 13 13 14 14 15 16 16 16 ........................................................... PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT TYPES OF CLIENTS 16 ...................................................................................................................................... ............................................. .................................................................................................................................. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS FAS Eligible Investments 16 16 .................................................................................................................................................... Actively Managed Mutual Funds, Actively Managed Collective Investment Funds Actively Managed Special Pool Investments Insurance Funds, and Actively Managed Group Annuity Separate Accounts 17 Stable Value, Money Market Funds, Certain Insurance Company General Account and Separate ................................................................. Account Options, and Third Party Bank Deposit Products 17 Passively Managed Mutual Funds, Passively Managed Collective Investment Funds, Passively Managed Exchange Traded Funds, Passively Managed Special Pool Investments Insurance Funds and Passively Managed Group Annuity Separate Accounts Information Available To Designated Advisors Regarding Investments Status Change Of FAS Eligible Investments Discretionary Investment Menus Risks Associated With Certain Investments .............................................................. ................................................... .................................................................................................. ..................................................................................................................... .................................................................................................. ……………………………………………………………………………………………………………………….. …………………………………………………………………………………………………. ………………………………………………………………………………………………………………. Mutual Funds Collective Investment Funds Stable Value Funds 18 18 18 19 19 19 20 20 III  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE ……………………………………………………………………………………………………………. ………………………………………………………………………………………………………………… ….………………………………… ………………………………………………………………………………………… ……………………………………………………………………………………….... …………………………………………………..……………………………………………………. ……………………………………………………………………..…….. Money Market Funds Target Date Funds Insurance Company General Account and Separate Account Options Third Party Bank Deposit Products Group Annuity Separate Accounts Exchange Traded Funds Special Pool Investments Insurance Funds 20 21 21 21 22 22 22 ………………………………………………………………………………….… ………………………………………………………………………………………………………………. Information and Cyber Security Risks ESG-Themed Funds 22 23 .................................................................................................... IMPORTANT CLIENT RESPONSIBILITIES 24 .................................................................................................................... 25 DISCIPLINARY INFORMATION 26 ................................................................ OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Conflicts Of Interest And Information Walls Code Of Ethics Compensation, Conflicts of Interest and Material Relationships Sales Compensation - Benefits to Merrill and Designated Advisors from Enrolling in FAS Compensation and Benefits to Merrill and Designated Advisors Field Management and Merrill Management Compensation Account and Program Choice ...................................................................................................................................................... .................................................................................................. ………………………………………………………………………………………………………………………………. ……………………………………………………. …..… …………………………………….......... …………………………………………..… …. ……………………………………………………………………………………………….. …………….……………………….…………………….. ............................................................................................ ................................................................................................................................................. .......................................................................................... Mutual Fund-Related Compensation; Other Compensation Participation Or Interest In Client Transactions Related Persons Securities Trading By Merrill And Our Personnel 28 28 28 29 29 30 31 31 32 34 34 34 ............................................................................................................................ BROKERAGE PRACTICES 35 ............................................................................................................................... REVIEW OF ACCOUNTS 36 CLIENT REFERRALS AND OTHER COMPENSATION Compensation For Client Referrals Other Compensation Relationships with Third-Party Firms .................................................................................. ................................................................................................................. ......................................................................................................................................... …………………………………………….……………………..……………….... ………………………………………………………… 36 36 36 36 36 Third-Party Firm Business Relationships and Support Participation and Sponsorship by Third-Party Firms for Merrill Conferences, Manager Meetings and Charitable Events Third-Party Firm Office Access and Gifts and Entertainment ……………………………………………………………………………………….…. .…………………………………….…………. …………………………………………. Provision of Diversified Financial Services by Us and Our Affiliates 37 38 38 ...................................................................................................................................................... CUSTODY 39 39 INVESTMENT DISCRETION .......................................................................................................................... 39 VOTING CLIENT SECURITIES ....................................................................................................................... FINANCIAL INFORMATION 39 ......................................................................................................................... . GLOSSARY 40 ............................................................................................................................................... …. All capitalized terms used in the Brochure are defined in the body of this Brochure and/or in the Glossary. IV  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE This Brochure relates to the Merrill Lynch Fiduciary Advisory Services Program (the “Program” or “FAS”) offered by Merrill Lynch, Pierce, Fenner & Smith Incorporated (referred to in this Brochure as “Merrill”, “MLPF&S”, “we”, “us” or “our”). For purposes of this Brochure, “client”, “you”, or “your” refers to the Plan Sponsor (or other named fiduciaries) and “Plan” refers to the participant-directed defined contribution plan maintained by the Plan Sponsor and enumerated in the Client Agreement. FAS is an investment advisory program offered for participant-directed, defined contribution plans subject to ERISA (each a “Plan”). Through the Program, we can help Plan Sponsors construct and maintain an investment menu for their respective Plans. All capitalized terms are defined in the body of this Brochure and/or in the Glossary, which can be found at the end of this Brochure. ADVISORY BUSINESS A. ABOUT MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a global financial services firm that offers a broad range of brokerage, investment advisory, retail and other services. Merrill is registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer and has been registered as an investment adviser since 1978. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in the “Summary of Programs and Services” available upon request from your Designated Advisor. B. FIDUCIARY ADVISORY SERVICES (Non-Discretionary and Discretionary) The Program offers non-discretionary or discretionary services to clients. Discretionary services are only provided to certain clients as described in further detail below. When providing services in this Program, we acknowledge our status as a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”). When Merrill is providing non-discretionary services in the Program, we acknowledge we are acting as a fiduciary under section 3(21)(A)(ii) of ERISA with respect to the initial and ongoing recommendations we provide you for investment options made available under the Plan and other services, as described in the Client Agreement. When providing discretionary services in this Program, Merrill will acknowledge that it is acting as an ERISA Section 3(38) fiduciary to the extent it initially selects, and on a periodic basis makes changes to, investment options for your Plan’s investment menu. We will also acknowledge that we are an ERISA fiduciary to the extent we render investment advice (within the meaning of section 3(21)(A)(ii) of ERISA). 1  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE 1. Summary Description of Services The services in this Program are provided through a select group of individuals who are designated to provide FAS services (“Designated Advisor”). A Designated Advisor can either be an Advisor or Program Solutions Manager (“PSM”). An “Advisor” is one that is eligible to provide and offer additional Merrill products and services in addition to Fiduciary Advisory Services (FAS) and Education and Plan Services (“EPS”). A Program Solutions Manager (PSM) is a role that is distinct from an individual that has the title “Advisor”. A PSM can open defined contribution plan accounts and offer and provide FAS and EPS but is not eligible to offer or provide other Merrill products and services. We provide a disclosure document called the "Form ADV Part 2B - Brochure Supplement" which describes information about the Designated Advisor(s) you are working with, their designation, role and the services they can provide, among other things. We can change our designations, roles and services for our Designated Advisors at our discretion and at any time. FAS includes: Investment Menu Design • Investment Policy Statement (only in the Non-Discretionary service) • Investment Due Diligence and Recommendations • • Periodic Performance Reporting Non-discretionary and discretionary services are available to plans with record keeping services through Merrill or our Advisor Alliance providers, except for plans with group annuity or group funding agreements (“Group Annuity Plans”) as described below. Only non-discretionary services are available to Group Annuity Plans with record keeping services through our Advisor Alliance providers, or external record keeping services that are not record kept through Merrill or our Advisor Alliance providers (“External Providers”). When Merrill is providing non-discretionary services in the Program, our Designated Advisors will provide you with initial and ongoing advice with respect to the creation and maintenance of an investment menu for your Plan. Assistance in creating an Investment Policy Statement is also part of the non-discretionary service. When providing discretionary services in the Program, Merrill will act as an ERISA Section 3(38) fiduciary to the extent it initially selects, and on a periodic basis makes changes to, investment options for your Plan’s investment menu. Our Designated Advisors will provide advice and guidance on the Menu Type that may be most appropriate for your Plan. Once you have selected a Menu Type we will exercise discretion to select, and on a periodic basis make changes to, investment options for your Plan’s investment menu (“Discretionary Investment Menu”), subject to the limitations described below and in the Client Agreement. A more detailed description of the Program is provided elsewhere in this Brochure, along with other material information about Merrill. Before selecting this Program, please review this Brochure carefully and speak with your Designated Advisor if you have any questions. The Program fee is based on the totality of the services and is negotiable depending on a number of factors (see “Program Fees” section for additional details). 2  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Investment Advisory Agreement 2. The scope of any investment advisory relationship we have with you is defined in the Client Agreement that you sign with respect to the Program. Through FAS, we act as your investment adviser only for the Plan specifically referenced in the Client Agreement, and not for any other assets or accounts (including any other employee benefit plans), unless otherwise separately agreed to by us in writing. Our advisory relationship begins when we enter into the Client Agreement with you. The effective date of the Client Agreement is provided to you in a written confirmation. Preliminary discussions or recommendations before we enter into the Client Agreement with you are not intended as investment advice and should not be relied upon as such. There are separate Client Agreements for each of the FAS Non-Discretionary and FAS Discretionary services. FAS Non-Discretionary FAS non-discretionary services are available to plans for which either Merrill, our Advisor Alliance partners, or External Providers serve as recordkeeper. By participating in the Program, you acknowledge that the services we are providing are non-discretionary and that you have retained, and will exercise, final decision-making authority and responsibility for all matters concerning the Plan as well as for the implementation of any investment plan or strategy resulting from the services provided under the Client Agreement. Through the FAS non-discretionary Client Agreement, Merrill acknowledges that it is an ERISA fiduciary to the extent that we render investment advice (within the meaning of section 3(21)(A)(ii) of ERISA) to you regarding the Plan’s investment options, including the recommendation of FAS Eligible Investments as defined below (except as specifically noted below with respect to any Excluded Assets), but not in any other aspects of our relationship. You may make investment-related decisions contrary to our recommendations, or make your own decisions without the benefit of our advice. However, if you repeatedly disregard our investment advice, we may, at our discretion, and with notice to you, terminate you as an FAS client. FAS Discretionary FAS discretionary services are only available to plans for which either Merrill or our Advisor Alliance providers serve as recordkeeper. The discretionary service is not available for Group Annuity Plans with record keeping services through our Advisor Alliance providers or plans for which an External Provider serves as recordkeeper. By participating in the Program, you are retaining and authorizing Merrill to exercise discretion to select investments for the Plan’s investment menu, subject to the limitations described in detail in Section 3 (Detailed Description of Services) of this Brochure and in the FAS discretionary Client Agreement. In the FAS discretionary Client Agreement, Merrill will acknowledge that it is acting as an ERISA Section 3(38) fiduciary to the extent it initially selects, and on a periodic basis makes changes to, investment options for your Plan’s investment menu. We will also acknowledge that we are an ERISA fiduciary to the extent we render investment advice (within the meaning of section 3(21)(A)(ii) of ERISA) for certain aspects of the Program, as described in the Client Agreement. 3  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE 3. Detailed Description of Services The following are detailed descriptions of the services available through the Program: Creation Of A Written Investment Policy Statement (“IPS”) FAS Non-Discretionary Merrill will assist you in creating an initial IPS for the purpose of providing guidelines, limitations and direction for the selection and monitoring of the investment choices in the Plan. To assist you in creating an IPS for your Plan, Merrill will use the information collected from you through discussions with your Designated Advisor to create the IPS. If applicable for your Plan, the IPS will also include the Qualified Default Investment Alternative (“QDIA”) option you selected. After the draft IPS is completed, your Designated Advisor will review the IPS with you and answer questions you may have. Please note that the assistance we provide in creating a single IPS is a recommendation we are providing to you and it is your responsibility to provide final approval of the IPS for your Plan. It is your sole responsibility to provide all necessary information for us to provide assistance with the creation of the IPS and investment menu design. You are also responsible for implementing the IPS on behalf of the Plan. In addition, you should provide prompt written notice to Merrill of any change in the Plan Sponsor information or the Plan’s investment objectives, guidelines, or similar information, which would materially change the information previously provided by you and used in the design or selection of an investment menu. Merrill shall not have discretion nor any authority over the Plan’s documents or in implementing any aspect of the Program, including, without limitation, the investment menu or IPS, and shall not otherwise have management or control of the Plan assets or its legal documents. We encourage you to consult with your Plan’s other professional advisers as appropriate. Please note it is also your responsibility to adhere to the IPS in managing and supporting your Plan and its investment menu and making timely updates and changes to the IPS. To the extent you want us to remain current with any changes, you must also supply us with any modifications or changes to the IPS or investment menu on a timely basis. It will be your responsibility to update and provide us with such updated materials on a timely basis to assist your Designated Advisor with providing ongoing investment recommendations for the Plan. Merrill will provide investment menu recommendations based on the Plan’s IPS that is on file with Merrill. You should review the Plan’s investment menu periodically to verify that it remains in compliance with the IPS. The Plan Sponsor will be solely responsible for approving and implementing any change in the Plan’s investment menu and/or IPS. You should provide prompt written notice to Merrill of any change in Plan Sponsor information and any change in your Plan’s investment objectives, guidelines, or similar information, which could materially change the information previously provided by you and which you expect should be used by us to provide any ongoing advice under FAS. You should also provide Merrill with such other information as Merrill may reasonably request from time to time. 4  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE FAS Discretionary Assistance with creation of an IPS is not available in FAS Discretionary. This service is only available in FAS non-discretionary. Any IPS adopted and used by the Plan is the sole responsibility of the Plan Sponsor. Accordingly, Merrill will not be responsible for verifying that investment menu selections adhere to your Plan’s IPS, if any. Investment Menu Design FAS Non-Discretionary Your Designated Advisor will provide initial and ongoing advice in the design of an investment menu for your Plan. Merrill’s views on menu design are outlined in a Menu Design and Fund Selection Guide which can be obtained from your Designated Advisor. To assist in designing the investment menu, your Designated Advisor will gather information from you about your Plan including but not limited to Plan Sponsor information and asset class selections for the menu in order to create your Investment Policy Statement (IPS). Please note that the guidance we provide in the design of an investment menu for your Plan is a recommendation we are providing to you and it is your responsibility to provide final approval of the investment menu for your Plan. Please note that it is your responsibility to provide all requested information, which we rely upon to assist in menu design and creation of the initial IPS. In addition, you should provide prompt written notice to Merrill of any change in the Plan Sponsor information or the Plan’s investment objectives, guidelines, or similar information, which would materially change the information previously provided by you and used in the design of your Plan’s investment menu or IPS. Merrill will have no responsibility with respect to whether “employer securities” or “employer real property” within the meaning of Section 407 of ERISA will be available as an investment option under your Plan. You will have sole responsibility if “employer securities” or “employer real property” are made available and for the decision to maintain such investment option over time. You will be solely responsible for approving and implementing the Plan’s investment menu and any changes to that investment menu. FAS Discretionary Merrill will offer several types of investment menus, which will differ based on the number and categories of asset classes that will be used to construct the Plan’s investment menu (“Menu Types”). Each Menu Type will include specific and diversified asset classes. Your Designated Advisor will provide advice and guidance on the Menu Type that may be most appropriate for your Plan. Once you have selected a Menu Type we will exercise discretion to select, and on a periodic basis make changes to, investment options for your Plan’s investment menu, subject to the limitations described below and in the Client Agreement. The investment menus created by Merrill are referred to as Discretionary Investment Menus. Under FAS Discretionary, your Plan’s investment menu must include a qualified default investment alternative (“QDIA”). A QDIA is the investment into which Plan participants’ or plan sponsors’ contributions will be invested if the participant does not make an affirmative investment election. 5  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Merrill’s discretionary authority does not extend to selecting the type of QDIA your Plan will offer. You will be responsible for selecting whether to offer a balanced fund or a target date series QDIA. If you select a balanced fund QDIA, you will also be required to determine whether the balanced fund QDIA should have a conservative, moderate or aggressive asset allocation. Once you have made that QDIA type selection, Merrill will exercise discretion to select the particular investment option that is offered as part of your Plan’s investment menu for your chosen QDIA type. If you select a balanced fund QDIA, your Plan’s investment menu will also include additional asset allocation funds that are not used as a QDIA (i.e., if you select a balanced fund QDIA with a moderate asset allocation, your Plan’s investment menu will also include conservative and aggressive asset allocation funds). Merrill may also exercise discretion in replacing the particular QDIA investment option selected. You must provide your participants with advance notice and other information required under the Department of Labor’s QDIA regulations (or arrange for a third party to provide such notice). Merrill’s discretionary authority also will not extend to the selection of the type of cash investment alternative you make available under your Plan. You will be responsible for selecting whether the Plan’s investment menu will offer a money market or stable value fund. After you choose the type of cash investment alternative you want, Merrill will have discretion to choose, and replace the particular money market or stable value fund that is offered. If you select a stable value fund, you will have responsibility for reading and understanding applicable disclosures and signing a participation agreement or other contract with the stable value fund provider. If we exercise discretion and make a change to a stable value fund, you will need to execute a new participation agreement or other contract with the stable value fund provider. The Client Agreement will provide that if you fail to do so in a timely fashion, Merrill will be deemed directed by you to change your choice of a cash investment alternative to a money market fund. Merrill will have no responsibility with respect to whether “employer securities” or “employer real property” within the meaning of Section 407 of ERISA will be available as an investment option under your Plan. You will have sole responsibility in determining whether “employer securities” or “employer real property” are made available and for the decision to maintain such investment option over time. Under FAS Discretionary, you grant us the authority to provide instructions to your Plan’s recordkeeper regarding the selections we make, including changes, to your Plan’s investment menu. You must provide your Plan participants timely advance notice of the options we select and any changes to those options in accordance with applicable Department of Labor regulations (or arrange for a third party to provide such notice). If you arrange for a third party to provide such notice to your participants for a fee, any changes to Discretionary Investment Menus may lead to administrative costs to the Plan. Investment Due Diligence And Your Plan’s Investment Menu FAS Non-Discretionary Your Designated Advisor will provide you with initial and ongoing investment recommendations to assist in your selection of investment options (hereinafter referred to collectively as “Investments”) for your Plan’s investment menu, specifically FAS Eligible Investments as described below. These Investments may include actively managed and passively managed (index) mutual funds, target date mutual funds, balanced mutual funds, and money market funds, all of which are registered under the Investment Company Act of 1940 (“1940 Act”), as well as other types of funds such as Collective Investment Funds (“CIFs”), target date CIFs, group annuity separate accounts, and stable value funds, 6  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE which are not registered under the 1940 Act and certain insurance company general account options and third party bank deposit products. You are solely responsible for the final selection of all investments to be included in your Plan menu. Actively and passively managed mutual funds, target date mutual funds, and money market funds recommended through FAS will be offered with the lowest cost share class (generally, shares denominated by a fund sponsor as zero revenue or institutional share classes, or equivalents) available to Plans through your record keeping provider. In addition, group annuity separate accounts recommended through FAS will be offered with the lowest cost fee tier available to Plans through Advisor Alliance recordkeeping services. CIFs offered through FAS are recommended without a specific share class or fee tier. You must choose the share class or fee tier for a CIF from the share classes or fee tiers offered by the trustee sponsoring the CIF subject to availability on your recordkeeping platform. If you select a different, more costly share class or fee tier, which would adversely affect the performance of the mutual fund, CIF or separate account, that decision will be solely your responsibility and that decision will not fall within the advisory services that Merrill provides through FAS. Merrill shall bear no responsibility for your decision to select a different (or for CIFs a higher cost) share class or fee tier. Designated Advisors’ compensation is not affected by the share class or fee tier selected. Please see Code of Ethics, Participation or Interest in Client Transactions and Personal Trading—Conflicts of Interest and Information Walls—Mutual Fund-Related Compensation; Other Compensation. Merrill will communicate if an investment in your Plan menu is no longer a FAS Eligible Investment and will provide one or more recommendations for a replacement (see Advisory Business – Detailed Description of Services – Fiduciary Advisory Services Reporting and Ongoing Advice and see Methods of Analysis, Investment Strategies and Risk of Loss - Status Change of FAS Eligible Investments). FAS Discretionary Merrill will create a Discretionary Investment Menu to be used for your Plan, based on your selection of Menu Type, QDIA and cash alternative, that will consist of FAS Eligible Investments. For more information on the creation and monitoring of Discretionary Investment Menus, please see Methods of Analysis, Investment Strategies and Risk of Loss – Discretionary Investment Menus. The Discretionary Investment Menus may include actively managed and passively managed (index) mutual funds, target date mutual funds, balanced mutual funds, and money market funds, all of which are registered under the 1940 Act, and will be the lowest cost share class available to Plans through FAS Discretionary on the Merrill or Advisor Alliance recordkeeping platform chosen by the Plan (generally, shares denominated by a fund sponsor as zero revenue or institutional share classes, or equivalents) at the time the Plan’s recordkeeper implements the Discretionary Investment Menu. In addition, other types of funds may be included, such as group annuity separate accounts and stable value funds, which are not registered under the 1940 Act, and will be the lowest cost fee tier available to Plans through FAS Discretionary on the Merrill or Advisor Alliance recordkeeping platform chosen by the plan. The funds will be the lowest cost share class or fee tier available to Plans participating in FAS Discretionary and using Merrill or Advisor Alliance recordkeeping services, but you should not assume your Plan will be invested in the lowest cost share class or fee tier that the fund provider makes available. Access to lower cost share classes or fee tiers is also affected by whether a particular Plan participates in FAS non-discretionary or FAS discretionary services. The cost of the share classes or fee tiers offered through FAS non-discretionary may be higher or lower than those offered through FAS discretionary due to several factors, including how quickly the Plan’s chosen recordkeeper adds the lower cost share class or fee tier to its platform. Designated Advisors’ compensation is not affected by the share class or fee tier selected. Please see Code 7  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE of Ethics, Participation or Interest in Client Transactions and Personal Trading—Conflicts of Interest and Information Walls—Mutual Fund-Related Compensation; Other Compensation. Merrill will communicate to your recordkeeping service provider any additions, removals or replacements of investments to Discretionary Investment Menus. Your recordkeeper is required to inform you of the change promptly and in advance of the date it will be implemented. You must provide Plan participants with timely notices of changes in Discretionary Investment Menus in accordance with applicable Department of Labor requirements (or arrange for a third party to provide such notice). Plans participating in FAS discretionary can only include investment options included in the Discretionary Investment Menu, other than “employer stock” or “employer real property” within the meaning of Section 407 of ERISA when available through your record keeper. Merrill does not have fiduciary responsibility for any investments outside of those in the Discretionary Investment Menu. FAS Eligible Investments FAS Eligible Investments will include those investments that meet Merrill’s due diligence standards. As a general matter, we select FAS Eligible Investments based on a variety of factors, including but not limited to investment styles available in the marketplace, platform capacity, client needs, and the outcome of due diligence reviews. Due diligence on investments is performed by Merrill and by third parties that Merrill contracts with to provide such services (see Methods of Analysis, Investment Strategies and Risk of Loss). Fiduciary Advisory Services Reporting and Ongoing Advice Merrill will provide a periodic Plan-level report called the Fiduciary Advisory Services Report (“FASR”) that includes an analysis of the performance of the investments in your Plan menu. In FAS non-discretionary, the report will also highlight any investments that were not recommended by Merrill or investments that are no longer FAS Eligible Investments and for which Merrill will cease to be responsible for providing ongoing advice under the Program. Replacement recommendations of FAS Eligible Investments will be provided by your Designated Advisor in the FASR for any investments on a Plan’s menu that were not recommended by Merrill or that no longer meet Merrill’s due diligence standards. Your Designated Advisor may also make additional recommendations for changes in your Plan’s menu design, including without limitation the addition of new asset classes or substitution of other FAS Eligible Investments. You may determine to retain or select an investment that has not been reviewed or recommended by us. If you repeatedly disregard our advice, we may, at our discretion and with notice to you, terminate you as a FAS client. You have the responsibility to review such information, reports or statements provided on a periodic basis in the normal course of the delivery of services by Merrill through web access or by requesting a physical copy of materials from your Designated Advisor. You are responsible for accessing the provided information through web delivery means, including the establishment of user IDs and passwords. You should use the FASR to evaluate your Plan’s investment menu and progress towards your Plan’s investment goals. Your Designated Advisor will be available to assist you in understanding the format and content of the report, which includes graphic and tabular presentations of performance, and will assist you in reviewing and evaluating the reports. The principal source of information for the FASR is data from your recordkeeper. We also use outside information sources including investment research and data analysis firms. This information is obtained from sources we believe to be reliable, but reliability cannot be guaranteed. 8  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE For plans record kept with External Providers, you should provide Merrill with the information necessary to provide the reporting services outlined in this Brochure, and you should direct third party custodians/recordkeepers of the Plan’s assets to provide Merrill with such information necessary to carry out our performance reporting responsibilities under the Client Agreement. Merrill is not responsible for including information in any report which it does not receive on a timely basis. Merrill and its Affiliates are entitled to rely on the financial and other information that you or your selected third party custodian/recordkeeper provides to Merrill. Merrill does not independently verify this information, nor does Merrill guarantee the accuracy or validity of such information. Additional Information Included in the Fiduciary Advisory Services Report The FASR for plans with record keeping services through Merrill or our Advisor Alliance providers includes Plan data from your recordkeeper that is separate from FAS and is being provided for informational purposes only. In addition, your recordkeeper may make available certain portfolio model services (which are separate from FAS), including GoalManager Portfolio Rebalancing Service (Goal Manager), which allows for scheduled automatic rebalancing of your Goal Manager portfolio models in your Plan. For clients who select GoalManager as part of the recordkeeping arrangement, the FASR will include information about the portfolio allocation and performance of the portfolios. Portfolio model services, including GoalManager, are subject to a separate agreement and are not a part of the Program (see Advisory Business - Limitation of Services – Portfolio Model Services). 4. Limitation of Services Universe of Investment Recommendations – Investments recommended for your Plan’s investment menu or selected for your Discretionary Investment Menu are limited to the FAS Eligible Investments in the lowest cost share class (generally, shares denominated by a fund sponsor as zero revenue or institutional share classes, or equivalents) available to Plans through your recordkeeping provider. Merrill does not consider a Plan’s recordkeeping fees such as investment access fees when determining the FAS Eligible Investment options. The FAS Eligible Investment options will be further dependent on the investments available on your recordkeeping platform. There may be other investments that are appropriate for your Plan menu that are not included as FAS Eligible Investments. You may determine to retain or select an investment that has not been reviewed or recommended by us. If you repeatedly disregard our advice, we may, at our discretion and with notice to you, terminate you as a FAS client. If you enroll in FAS Non-Discretionary and include or maintain an investment that is not recommended by Merrill in your Plan’s investment menu, it would be solely upon your own initiative without any fiduciary or other responsibility by Merrill or any Affiliate. BofA Corp. Affiliated Products - BofA Corp. or Merrill affiliated mutual funds or other affiliated products (including, without limitation, deposit products including Retirement Bank Account) will not be presented as FAS Eligible Investments. In the event you were ever to include BofA Corp. or Merrill affiliated fund or product in your Plan investment menu, it would be solely upon your own initiative without any responsibility by Merrill or any Affiliate and you understand and agree that, with respect to any such investments: (i) Merrill does not and will not act in a fiduciary capacity under ERISA (or otherwise) with respect to the decision to select or maintain the Plan’s holdings of such affiliated investments, and has not and will not recommend to you any purchase, sale or retention of such investments under the FAS Client Agreement or otherwise in connection with the Program, and (ii) with respect to any such Plan assets that are now or hereafter invested in any BofA Corp. or Merrill affiliated mutual funds or products, that the terms of Merrill's engagement will not cover such investments. Without limiting the generality of the immediately foregoing, Merrill will provide periodic reporting for any such affiliated investments, which you agree is not a fiduciary act by Merrill. 9  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE In Plan Retirement Income Options - These are annuity-based options that can provide participants with income for retirement. These options are a separate service from FAS, subject to a separate agreement, and not subject to any ongoing review under the Program. Excluded Assets (“Excluded Assets”) - These assets include, but are not limited to, “employer securities" or "employer real property" within the meaning of section 407 of ERISA, participant loan balances, self-direct brokerage accounts/balances, in plan retirement income options, custom funds, or BofA Corp. or Merrill affiliated mutual funds or other affiliated products (including, without limitation, Retirement Bank Account). Excluded Assets may be included in your FASR, but they are not subject to the Client Agreement and therefore will not be a part of any ongoing advice and guidance under the Program. Portfolio Model Services– As described above in the section called Advisory Business –Detailed Description of Services – Fiduciary Advisory Services Reporting and Ongoing Advice - Additional Information Included in the Fiduciary Advisory Services Report, for clients utilizing GoalManager, information included in the FASR is included for informational purposes only. Portfolio model services, including Goal Manager, are a separate service from FAS and subject to a separate agreement. For plans record kept with External Providers, your recordkeeper may make available certain portfolio model services which allow Plan Sponsors to create diversified portfolios. For clients utilizing such portfolio model services, the FASR will not include information about those models, and those services are subject to a separate agreement with your recordkeeper. Education & Plan Services; Recordkeeping & Plan Administration – These services are separate from FAS and are subject to a separate agreement. Merrill is not acting as a fiduciary in providing these services. 5. Termination The Client Agreement may be terminated at any time by you or Merrill by giving notice as described in the Client Agreement. FAS services will continue until the termination date. For plans record kept by Merrill or our Advisor Alliance providers, requests for termination may be made directly by you or directed by you through your recordkeeper. Plan Sponsors are required to provide notification to their Designated Advisor and recordkeeper of the decision to terminate recordkeeping services, in accordance with their applicable recordkeeping arrangements. For plans record kept with External Providers, the Client Agreement may be terminated at any time by you by giving notice as described in the Client Agreement. The termination of your Designated Advisor’s employment with Merrill or a change in the role of your Designated Advisor will not automatically terminate the Agreement. In such an event, we will transfer the servicing of your plan to a different Designated Advisor, and we will inform you of this fact. Merrill reserves the right to take action under its Program guidelines to terminate the Plan from the Program or to authorize or preclude Designated Advisors from taking action in respect of your Plan if we are unable to obtain instructions from you as to your Plan in a timely manner to deliver the Program services. 6. Qualifications of Designated Advisors Designated Advisors are registered as broker-dealer and investment adviser representatives. To become designated to provide FAS, Advisors or PSMs are generally required to demonstrate specialized experience and meet certain qualification requirements. These requirements may include the Certified Plan Fiduciary Advisor (CPFA)® credential from National Association of Plan Advisors. In addition, Advisors and PSMs must complete training administered by Merrill. Those who meet Merrill’s initial and ongoing requirements may be designated to provide FAS services. PSMs can open defined contribution plan accounts and offer and 10  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE provide FAS and Education & Plan Services but are not eligible to offer or provide other Merrill products and services. 7. Other Investment Advisory Programs and Services In addition to FAS, Merrill offers a wide variety of advisory services. These include, but are not limited to, the following: Merrill Lynch Institutional Investment Consulting, Merrill Lynch Advice Access, Merrill Lynch Investment Advisory Program, Merrill Guided Investing, Merrill Guided Investing with Advisor, Merrill Edge Advisory Account, Merrill Personal Retirement Strategy, and Merrill Lynch Strategic Portfolio Advisor® Service. We also offer general information not directed to and not tailored to the specific needs of any individual or individual clients in the form of publications or research. More information about these programs and services is contained in the applicable Merrill Brochure (or Form ADV, Part 2A) and is available upon request or through the SEC’s website http://www.adviserinfo.sec.gov/. C. ASSETS UNDER MANAGEMENT As of December 31, 2024, Merrill had assets under management of $1,511.09 billion, of which $388.43 billion was managed on a discretionary basis and $1,122.66 billion was managed on a non-discretionary basis. Assets related to this Program are not included in this data. FEES AND COMPENSATION A. PROGRAM FEES For services provided in the Program, FAS clients will pay a Program fee. The effective date of the Program fee will be described in the Client Agreement. The Program fee will equal an annual fixed dollar amount or an annual asset-based fee rate applied to certain Plan assets. The Program fee is subject to a Program minimum and maximum annual fee amount. The Program minimum annual fee amount is $1,000. The Program maximum annual fee amount is an amount calculated as an annual asset-based fee rate of 0.45% of Plan assets less any Excluded Assets (defined below). The fee for FAS may be negotiated with your Designated Advisor depending on a number of factors, and under limited circumstances the minimum fee may be waived, at our sole discretion. The extent to which we may negotiate the fee for FAS is solely within our discretion. In general, all fees are payable quarterly, in arrears (except as described below). See Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Conflicts of Interest and Information Walls - Mutual Fund-Related Compensation; Other Compensation. As noted above, the Program fee is negotiable subject to the maximum rate that can be charged. Working with an Advisor as your Designated Advisor. Merrill compensates your Advisor on an ongoing basis from, and based on, the Program fee that is agreed to for your Plan. When proposing a Program fee to you, your Advisor typically will consider a number of factors, including the type and size of your Plan, the breadth of your relationship with Merrill, the range of services your Advisor anticipates providing, and competitive considerations and the Advisor's own compensation considerations. Your Advisor has a financial interest in the level of the Program fee. Merrill has business and compensation policies that result in Advisors receiving lower compensation if the agreed-upon Program fee is lower than certain established levels. Therefore, Advisors also have a financial incentive not to reduce fees below those levels. You may accept or decline any proposed rate by your Advisor as part of the negotiation process. For more information on 11  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Advisor compensation and conflicts of interest, see section “Compensation, Conflicts of Interests and Material Relationships – Compensation and Benefits to Merrill and Designated Advisors”. Working with a PSM as your Designated Advisor. Although PSMs can open defined contribution plan accounts and offer and provide FAS and EPS, they are not eligible to offer or provide other Merrill products and services. Thus, Merrill compensates PSMs differently than Advisors. PSMs receive a salary and may receive incentive compensation based on factors related to performance in their role, which may include productivity, client experience and retention, among other responsibilities. The incentive compensation for PSMs is not directly based on the Program fee. For purposes of determining the Program fee, the PSM will consider a number of factors, including the type and size of your Plan, the breadth of your relationship with Merrill, the range of services your PSM anticipates providing, and competitive considerations. You may accept or decline any proposed rate by your PSM as part of the negotiation process. For more information on PSM compensation and conflicts of interest, see section “Compensation, Conflicts of Interests and Material Relationships - Compensation and Benefits to Merrill and Designated Advisors”. B. CALCULATION OF PROGRAM FEES If Merrill cannot commence delivery of services, your account may be terminated in which case a refund for fees paid will be processed upon termination. The program fee will not be adjusted for your use of or failure to use services. Unless otherwise agreed to by us, the following describes the calculation of Program Fees for FAS. 1. Calculation of Program Fees for clients with record keeping services through Merrill or our Advisor Alliance Non-Group Annuity Providers The following describes the calculation of Program fees for Plans with recordkeeping services provided by Merrill or our Advisor Alliance providers with non-group annuity or group funding agreement based platforms. For plans record kept with Merrill or our non-group annuity Advisor Alliance providers, asset-based fees are calculated and payable quarterly, in arrears, based on the average market value of the Plan assets less Excluded Assets as described below. The market value of Plan assets as of the last business day of each calendar month less Excluded Assets is used to calculate the average market value for the billing quarter. The fee rate applied will be one quarter of the annual asset-based fee rate. Fixed fee payments are equal to one quarter of the agreed upon annual fee and are payable quarterly, in arrears. 2. Calculation of Program Fees for clients with record keeping services through External Providers The following describes the calculation of Program fees for Plans with recordkeeping services through External Providers. For plans record kept with External Providers, asset-based fees are calculated and payable quarterly, in arrears, based on the market value of the Plan assets as of the last business day of each calendar quarter less Excluded Assets as described below. The fee rate applied will be one quarter of the annual asset-based fee rate. Any assets reflected on the performance report other than Excluded Assets (described below) will be subject to the asset based fee. Fixed fee payments are equal to one quarter of the agreed upon annual fee and are payable quarterly, in arrears. 12  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE 3. Calculation of Program Fees for clients with Group Annuity Providers The following describes the calculation of Program fees for Plans with recordkeeping services provided by Advisor Alliance providers on group annuity or group funding agreement based platforms (“Group Annuity Providers”). The asset based fee or fixed dollar fee is agreed to between you and Merrill. For asset based fees, the market value of Plan assets (less Excluded Assets as described below) will be calculated by your record keeper as described in the Client Agreement. For fixed dollar fees, the fee will be calculated by Merrill or your recordkeeper as described in the Client Agreement. 4. Excluded Assets Excluded Assets include, but are not limited to, “employer securities" or "employer real property" within the meaning of section 407 of ERISA, participant loan balances, self-direct brokerage accounts/balances, in plan retirement income options, custom funds, or BofA Corp. or Merrill affiliated mutual funds or other affiliated products (including, without limitation, Retirement Bank Account). Merrill reserves the right to designate assets as Excluded Assets. Merrill will not be an investment adviser or take any fiduciary responsibility with respect to Excluded Assets. Initial Billing of Program Fees 5. Fees for the initial period will be charged and pro-rated in accordance with the applicable Client Agreement. 6. Billing Upon Termination of Service For all Plans, excluding plans with Group Annuity Providers, in the event of termination, the Program fees payable hereunder shall be pro-rated based upon the effective date of termination. Asset based fees will be calculated based upon the most recent quarter-end data received from your recordkeeper. For plans with Group Annuity Providers, the Program fee due through termination date will be calculated by your recordkeeper on a pro-rated basis. For additional information, see Advisory Business- Fiduciary Advisory Services – Termination. INVOICES AND METHODS OF PAYMENT C. Invoices 1. For plans with record keeping services through Merrill, our Non-Group Annuity Advisor Alliance providers, or External Providers, Merrill will provide you with an invoice for your FAS fee For plans with Group Annuity Providers, Merrill or your record keeper will provide an invoice for the initial billing period in accordance with the applicable Client Agreement. Subsequent to the initial billing period, FAS fees are collected by your record keeper and transmitted to Merrill. Plans with Group Annuity Providers must instruct the record keeper to remit payment to Merrill for FAS fees. 2. Methods of Payment Plan sponsors may pay Program fees from corporate assets or Plan assets, when this option is available through your record keeper, or for clients with recordkeeping services through Merrill or an Advisor Alliance Provider, from compensation Merrill receives (but does not retain) in connection with investments, as 13  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE described below. For plans record kept with Merrill or our Advisor Alliance providers, if your Plan holds mutual funds and other investments at Merrill, Merrill may, at the client’s direction, apply compensation that Merrill receives (but does not retain) from these investments toward payment of the Program fees. The amount of compensation applied toward payment of the Program fees will depend on whether such compensation will also be applied toward fees for other services selected by the client, such as Education and Plan Services fees and recordkeeping services fees, as applicable. For plans with record keeping services through External Providers, it is solely your responsibility to ensure timely and accurate payment is made in accordance with the invoice you receive from Merrill, regardless of the method of payment. Fund-Related Compensation Available for Program Fee For plans with record keeping services provided by External Providers, Merrill does not receive nor retain compensation in connection with investments. For plans record kept on the Merrill and Advisor Alliance platforms, Merrill has entered into agreements with various fund families and/or their service providers and various stable value and collective trust fund providers to be paid fees with respect to sales and/or servicing these funds and our customers who invest in these funds, including retirement plan customers. The type, amount and source of payment of these fees varies depending upon the fund, the services being provided by Merrill, and the share class or fee tier in which Plan participants are invested, as applicable. With limited exceptions, these fees will not be paid with respect to funds used in FAS discretionary. These limited exceptions include money market and stable value funds. Any revenue collected will not be retained by Merrill. (See Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Conflicts of Interest and Information Walls - Mutual Fund-Related Compensation; Other Compensation. In addition, for more information, please refer to the document entitled “Mutual Fund Investing at Merrill Lynch” or refer to the ERISA 408(b)(2) Fee Disclosure available from your Designated Advisor upon request). For plans with Group Annuity Providers, Program Fees can be paid from Plan assets or corporate assets, depending on the recordkeeper. Merrill does not receive investment-related compensation from investments in plans with Group Annuity Providers or investments held in plans record kept with External Providers. D. OTHER FEES AND EXPENSES The Program fee does not cover the following services which are subject to separate agreements and disclosures and not part of the Program: • Education and Plan Services • Recordkeeping fees and plan administration charges • Other fees charged by the record keeper such as investment access fees For further information, see Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Conflicts of Interest and Information Walls. E. TREATMENT OF CASH BALANCES IN YOUR ACCOUNT If you hold Plan assets in a brokerage account at Merrill, you must agree to terms and conditions of the applicable brokerage account agreement. The brokerage account agreement will include terms and conditions for an automatic cash sweep program. An automatic cash sweep program is a program provided as part of your brokerage account agreement whereby cash balances (i.e., cash not invested in your Plan’s investment menu) in your brokerage account are automatically swept into a cash sweep option 14  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE available for your account type that you select (“Cash Sweep Program”). Under this Program, Merrill will not recommend a cash sweep option under the Cash Sweep Program for your brokerage account. Certain Merrill account types for qualified retirement plans eligible for enrollment in the Program where Merrill provides record keeping services may have an option to select one of the following as the cash sweep option: (1) a bank deposit program with our Bank Affiliates; or (2) certain money market mutual funds. Certain other Merrill account types for qualified retirement plans eligible for enrollment in the Program may only have a money market mutual fund as the cash sweep option. Cash swept to bank deposit accounts of our U.S. Bank Affiliates earns interest and the bank deposits are insured by the Federal Deposit Insurance Corporation (“FDIC”), up to the FDIC standard limits. Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. You are responsible for monitoring the total amount of deposits held at the Bank Affiliates under the Cash Sweep Program or otherwise in order to determine the extent of FDIC insurance. There is more detailed information about FDIC insurance and limits in the Sweep Program Guide For Merrill Clients which can be found on mymerrill.com. Please refer to your account agreement and related disclosures for additional information regarding the automatic sweep options for your type of account. You can obtain a paper copy of these disclosures from your Designated Advisor. F. COMPENSATION FOR THE SALE OF PRODUCTS We (including our Affiliates and Related Companies) and our employees, including your Advisor, benefit from compensation paid by you for FAS and other services, and certain employees receive a portion of any fees and other compensation paid for FAS and other services. These compensation practices create a conflict of interest that gives us and certain of our Designated Advisors an incentive to recommend advisory services based on the compensation received. PSMs receive a salary and may receive incentive compensation based on factors related to performance in their role, which may include productivity, client experience and retention, among other responsibilities. While PSMs can open defined contribution plan accounts, offer and provide FAS and EPS, they are not eligible to offer or provide other Merrill products and services. Having plans enrolled in the Program help PSMs meet certain performance goals. However, the incentive compensation for PSMs is not directly based on the Program fee. Fees and commissions for certain products or services are higher than others, and the remuneration and profitability to us (including our Affiliates and Related Companies) and certain of our Designated Advisors resulting from management of certain accounts may be greater than that associated with other advisory accounts. To the extent that there is a difference in compensation, an Advisor has a financial incentive to recommend certain products or services to you over others. (See Code of Ethics, Participation or Interest in Client Transactions and Personal Trading for more information about the receipt of compensation for the sale of securities and other investment products.) We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure. Moreover, our Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest—both those arising between and among accounts as well as between accounts and our business. 15  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE G. SOURCES OF REVENUE As a broker-dealer, Merrill offers a wide variety of products and services. Our principal sources of income, which include commissions and other compensation for the sale of investment products, are derived from our business as a broker-dealer. Less than 1% of our gross revenues are expected to be generated from FAS on an annual basis. H. CONDUCTING BUSINESS THROUGH MERRILL You should discuss the investment advisory services we make available with your Designated Advisor to determine which may be most appropriate for you. Program fees may be higher or lower than the fees charged by other firms for comparable services, assuming such services are available. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Neither we nor our Designated Advisors receive performance-based fees for FAS. The investment recommendations provided in connection with FAS do not raise the conflicts associated with the side-by- side management of accounts. TYPES OF CLIENTS FAS clients include Plan Sponsors (or other named fiduciaries) of employee benefit plans subject to ERISA. FAS is available to participant-directed, defined contribution Plans. Non-discretionary and discretionary services are available to plans with record keeping services through Merrill or our Advisor Alliance providers, except for plans with group annuity or group funding agreements (“Group Annuity Plans”) as described below. Only non-discretionary services are available to plans with group annuity or group funding agreements (“Group Annuity Plans”) with record keeping services through our Advisor Alliance providers. Plans with external record keeping services that are not record kept through Merrill or our Advisor Alliance providers (“External Providers”) are eligible for the non-discretionary services provided through the Program. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. FAS ELIGIBLE INVESTMENTS As part of FAS, Merrill employs separate due diligence review processes for different types of investments as described below. FAS Eligible Investments are investments that meet Merrill’s and/or third party due diligence standards and are available for selection for your Plan’s investment menu. These investments include actively managed and passively managed (index) mutual funds, target date mutual funds, balanced mutual funds, and money market funds, all of which are registered under the Investment Company Act of 1940 (“1940 Act”), as well as other types of funds such as collective investment funds (“CIFs”), target date CIFs, group annuity separate accounts, and stable value funds which are not registered under the 1940 Act, certain insurance company general account and separate account options, and third party bank deposit products. The due diligence review processes described below are conducted by Merrill or third-party reviewers retained by Merrill. From time to time we may make additional investment options available in the Program. As a general matter, we select FAS Eligible Investments based on a variety of factors, including but not limited to investment styles available in the marketplace, platform capacity, and client needs. We also consider the outcome of due diligence and evaluation reviews conducted by our Chief Investment Office 16  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE (the “CIO”) or conducted by third parties subject to or under our oversight. FAS Eligible Investment options will be dependent on the investments available on the selected recordkeeping platform. 1. Actively Managed Mutual Funds, Actively Managed Collective Investment Funds, Actively Managed Special Pool Investments Insurance Funds, and Actively Managed Group Annuity Separate Accounts Actively managed mutual funds, actively managed special pool investment insurance funds, and actively managed collective investment funds are subject to initial and periodic reviews conducted by Merrill or one or more third-party reviewers whose services are retained by Merrill. The initial and periodic review of actively managed mutual funds and actively managed collective investment funds, whether conducted by Merrill or a third party, is subject to a multi-factor process (“Review Process”). Merrill retains the decision- making authority to add or remove an actively managed mutual fund and actively managed collective investment fund from the Program, regardless of which entity is responsible for the Review Process. The Review Process generally includes but is not limited to the following factors: Investment professional and strategy resources Investment philosophy and process • Organizational structure and stability of a fund manager or fund • Adherence to investment style • Evaluation of risk and volatility • • • Portfolio construction • Performance Based on these factors, Merrill or a third party reviewer uses a combination of both quantitative and qualitative analysis to review and select actively managed mutual funds, actively managed special pool investments insurance funds, and actively managed collective investment funds. Some of the analytical methods may be subjective. Generally no single factor will be determinative as to whether a particular actively managed mutual fund, actively managed collective investment fund, or actively managed special pool investment insurance fund is included as an FAS Eligible Investment. Further, over time, we may replace one or more factors with different factors that we reasonably believe are appropriate. Funds are monitored on an ongoing basis and are subject to a Review Process re-evaluation at least annually. Note that the third parties may use different factors in evaluating actively managed mutual funds or actively managed collective investment funds, or a subset of these factors, or may assign different weightings to the same factors. However, Merrill has reviewed such third parties’ due diligence processes and believes they are reasonable and appropriate in light of the objectives of the Program. In evaluating actively managed group annuity separate accounts, Merrill will review the underlying investment vehicle and expenses of the group annuity separate account. Merrill retains the decision- making authority to add or remove a group annuity separate account from the Program, regardless of which entity is responsible for the Review Process. 2. Stable Value, Money Market Funds, Certain Insurance Company General Account and Separate Account Options, and Third Party Bank Deposit Products The initial and periodic review of stable value, money market funds, certain insurance company general account and separate account options, and third party bank deposit products is conducted by a third-party reviewer, which we have engaged for this purpose. 17  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Stable value funds, money market funds, and certain insurance company general account and separate account options, are evaluated using quantitative and qualitative methods based on, among other factors, manager’s tenure or experience, yield, internal expenses, the credit quality of the underlying securities and, with respect to stable value funds and general accounts, the credit quality of the insurance providers. Third party bank deposit products are evaluated using quantitative and qualitative methods including, among other factors, evaluating the sponsoring bank’s credit quality. Merrill retains the decision-making authority to add or remove a stable value fund, money market fund, certain insurance company general account options, or third party bank deposit products from the Program. 3. Passively Managed Mutual Funds, Passively Managed Collective Investment Funds, Passively Managed Exchange Traded Funds, Passively Managed Special Pool Investments Insurance Funds, and Passively Managed Group Annuity Separate Accounts Passively managed investment vehicles are subject to a quantitative and qualitative assessment based on, among other things, the fund’s tracking error, liquidity, expenses and other risk metrics. In evaluating passively managed group annuity separate accounts, Merrill will review the underlying investment vehicle and expenses of the group annuity separate account. Note that we can add other factors or replace one or more factors as we deem appropriate. INFORMATION AVAILABLE TO DESIGNATED ADVISORS REGARDING INVESTMENTS B. Merrill makes available to Designated Advisors through regular or ad hoc internal publications or communications information reflecting our internal opinions and views with respect to Investments. In addition, we will communicate information to Designated Advisors regarding determinations to remove investments as FAS Eligible Investments. All such information is available to your Designated Advisor in considering whether a particular Investment is appropriate for the Plan’s investment menu. You should discuss with your Designated Advisor any questions you may have about our views with respect to a particular Investment. C. STATUS CHANGE OF FAS ELIGIBLE INVESTMENTS If you enroll in FAS Non-Discretionary and your Plan’s investment menu contains investments that were not recommended by Merrill or no longer meet Merrill’s due diligence standards or other Program considerations for inclusion as an FAS Eligible Investment, Merrill will provide you with an investment performance report that highlights those ineligible Investments. Your Designated Advisor will provide recommendations of FAS Eligible Investments to replace any investments that were not recommended by Merrill or that are no longer considered FAS Eligible Investments. If a FAS client repeatedly disregards our investment advice, we may, at our discretion, terminate a client from FAS. If you enroll in FAS Discretionary and your Plan’s Discretionary Investment Menu contains an investment that no longer meets Merrill’s due diligence standards or other Program considerations for inclusion as an FAS Eligible Investment, Merrill shall select a different FAS Eligible Investment for inclusion in your Plan. From time to time, Merrill may, in the exercise of its discretion, also select a different FAS Eligible Investment for inclusion in your Plan, even if the current investment remains an FAS Eligible Investment. FAS Eligible Investments may change at any time. Merrill will generally not provide specific information regarding the basis for a change. 18  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Note that not all investments recommended for other Merrill clients outside of this Program will be included as FAS Eligible Investments, and vice versa. Our review of investments is not a substitute for your continued review of your Plan’s investment menu and the performance of your Plan’s investment options. D. DISCRETIONARY INVESTMENT MENUS The process of selecting, replacing and monitoring of asset classes, asset categories and investment funds for inclusion in Discretionary Investment Menus is subject to an internal review process which includes investment and other professionals from different lines of business at Merrill. In constructing Discretionary Investment Menus, the universe of potential investments is FAS Eligible Investments. The universe of FAS Eligible Investments is further filtered by screening particular characteristics, which may include performance consistency, risk adjusted returns, volatility, downside capture, and style purity. Investment selection will also consider any potential capacity or liquidity concerns. Additional qualitative, quantitative or both qualitative and quantitative analysis may be utilized to determine the final selection of investments for each asset class included in a Discretionary Investment Menu. Discretionary Investment Menus will be monitored on an on-going basis, and changes may be made at any time at Merrill’s discretion. Menu changes may be attributable to an existing investment no longer qualifying as an FAS Eligible Investment, or because a more suitable investment was identified. E. RISKS ASSOCIATED WITH CERTAIN INVESTMENTS You should understand that all investments involve risk (the degree of risk may vary significantly), that investment performance can never be predicted or guaranteed and that the values of the Plan’s assets will fluctuate due to market conditions, and other factors. Investments made and the actions taken respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID- 19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. We make no representations or warranties with respect to the present or future level of risk or volatility of any Investments’ future performance or activities. There is no assurance that the performance results of any benchmark or index used in connection with FAS, including those shown on the performance report or other Merrill reports, can be attained. Nor is there any guarantee that our due diligence review processes will identify the best performing funds in their respective competitive universe. You are assuming the risks involved in selecting Investments for the Plan’s menu and participants could lose all or a portion of the amount held in those Investments. In FAS non-discretionary, you retain risks and responsibility associated with selecting and monitoring the Plan’s investments, and in FAS discretionary, you retain the risks and responsibility associated with monitoring the Plan’s investments and our selection of investments under the Program. Typically, Merrill recommends that a client seek a diversified menu in an effort to meet the Plan’s investment objectives and include Investments diversified across multiple asset classes in order to reduce Investment risk associated with concentrated Investments. 1. Mutual Funds Mutual funds are sold by prospectus. Please read the prospectus carefully before investing and if you enroll in FAS non-discretionary, before you select a fund for the Plan’s menu. To determine whether a particular investment is appropriate, carefully consider the important information on the investment objectives, risks, 19  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE charges and expenses. Your Designated Advisor can provide a copy of the prospectus. Mutual funds charge various fees and expenses, which will reduce the actual returns of your investment. 2. Collective Investment Funds Collective Investment Funds, including certain target date CIFs, are not available for direct investment by individual shareholders. Unlike a mutual fund, an investor gains access to a collective investment fund through a retirement plan, such as a 401(k) plan. Additionally, regulation of mutual funds and Collective Investment Funds varies. For instance, the mutual fund industry is regulated by the Securities and Exchange Commission (SEC), and mutual funds are subject to the Investment Company Act and the rules adopted thereunder, which provide important protections to fund shareholders. For example, mutual funds are sold by prospectus, are subject to limitations on leverage and extensive regulatory reporting requirements, and are governed by independent boards of trustees. In contrast, Collective Investment Funds, including certain target date CIFs, are not regulated by the SEC or subject to the Investment Company Act; instead, their investment managers and the CIFs are subject to less stringent guidelines and are overseen by the U.S. Office of the Comptroller of the Currency or by a state banking authority. 3. Stable Value Funds The objective of most stable value funds is to provide safety of principal and an investment return that is generally higher than a money market return, while providing participants the ability to withdraw their assets for ordinary transactions at book rather than market value. However, the ability to withdraw stable value assets at book value has limitations based on the insurance contracts that wrap the underlying assets. In addition, most stable value funds require a hold period before assets can be withdrawn from the fund by the Plan Sponsor at book value and may refuse to honor book value withdrawals after communications from a Plan Sponsor or Plan fiduciaries that it determines caused participants' withdrawals. Additionally, the Plan is often restricted from offering investment alternatives that are viewed as competitive with the stable value offering. Finally, stable value funds are subject to counterparty risk of the insurers that provide the fund's book value liquidity. 4. Money Market Funds The FAS Eligible Investments include money market funds that invest in government and treasury securities (“Government Money Market Funds”), as well as money market funds that invest in corporate commercial paper (“Prime Money Market Funds”). A Government Money Market Fund seeks to preserve the value of your investment at $1.00 per share. However, there is no guarantee it will do so. The sponsors of these funds have no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to these funds at any time. A Prime Money Market Fund does not seek to maintain a stable per share net asset value, and the securities held by the fund are subject to the risk that issuers and/or counterparties will fail to make payments when due or default completely. A plan participant could lose money by investing in a Prime Money Market Fund. Because the share price of these funds will fluctuate, when shares are sold, they may be worth more or less than the amount initially paid for them. All money market funds may impose a fee upon the sale of shares or may temporarily suspend the ability to sell shares if a fund’s liquidity falls below required minimums because of market conditions or other factors. Neither Government Money Market Funds nor Prime Money Market Funds are insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. 20  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Money market funds are sold by prospectus. Please read the prospectus carefully before investing and if you enroll in FAS Non-Discretionary, before you select a money market fund for your Plan’s investment menu. Your Designated Advisor can provide a copy of the prospectus. 5. Target Date Funds The target date (or retirement date, as applicable) for these funds is the approximate date when an investor plans to start withdrawing the assets from their retirement account. The principal value of these funds is not guaranteed at any time, including at the target date. Nor do these funds guarantee a certain amount of retirement income. These funds are designed to become more conservative over time as the target date approaches. Target date mutual funds are sold by prospectus. Please read the prospectus carefully before investing and before you select a target date mutual fund for your Plan’s investment menu if you enroll in FAS non- discretionary. Your Designated Advisor can provide a copy of the prospectus. Target date mutual funds are subject to the investment risks associated with each of the underlying funds in which a target date fund invests. Insurance Company General Account and Separate Account Options 6. All contract and rider guarantees, including optional benefits and any fixed crediting rates, are backed by the claims-paying ability of the issuing insurance company. They are not backed by Merrill or its Affiliates, nor does Merrill or its Affiliates make any representations or guarantees regarding the claims-paying ability of the issuing insurance company. Third Party Bank Deposit Products 7. Each Third Party Bank Deposit Product is a direct obligation of the depository institution at which the account is established. FDIC insurance covers all deposit accounts at an FDIC-insured bank up to the Standard Maximum Deposit Insurance Amount (“SMDIA”) of $250,000 per depositor, per ownership category, per depository institution. Deposits maintained in different categories of legal ownership — such as individual accounts, joint accounts or certain retirement accounts— are separately insured by the FDIC up to applicable insurance limits. FDIC insurance covers both principal and accrued interest. The current SMDIA limit of $250,000 per depositor, per ownership category, per depository institution could change in the future and the FDIC will not insure funds in excess of the limit. Plan sponsors and/or plan participants are responsible for monitoring the total amount of deposits held at the depository institution, in any ownership category, in order to determine the extent of FDIC insurance coverage available to such deposits. Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Merrill is not responsible for any insured or uninsured portion of deposits. In the event that federal deposit insurance payments become necessary, the FDIC is required to pay principal plus unpaid and accrued interest to the date of the closing of the relevant depository institution, as prescribed by law and applicable regulations, up to applicable limits. Since there is no specific time period during which the FDIC must make available such insurance payments, Plan sponsors should be prepared for the possibility of an indeterminate delay in obtaining insurance payments. In addition, plan sponsors may be required to provide certain documentation to the FDIC and the depository institution before any insurance payouts are released to the plan. Merrill will not be obligated to the plan sponsor for amounts not covered by deposit insurance and will not be obligated to the plan sponsor in advance of payment from the FDIC. You are responsible for monitoring the total amount of bank deposits that you hold with any one bank for FDIC insurance limits. 21  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE 8. Group Annuity Separate Accounts Investment options may be available to your Plan through a group annuity contract issued by your recordkeeping provider. Group Annuity contracts offer a choice of investment options that are funded by investments through insurance company separate accounts, also referred to as subaccounts. Separate accounts are creations under state insurance law and typically invest in shares of registered mutual funds or similar pooled investments. The value of a separate account investment will fluctuate up or down, depending on the performance of the underlying investments in the account. Most group annuity contracts are exempt from registration under the federal securities laws. However, certain of the separate account investment choices invest in mutual funds which are subject to SEC registration. Prospectuses for these mutual funds can be obtained by calling your Designated Advisor. 9. Exchange Traded Funds Exchange Traded Funds (ETFs) are pooled investment vehicles that track a particular index, sector, commodity or other asset and trade on a stock exchange. ETFs are sold by prospectus. Please read the prospectus carefully before investing and if you enroll in FAS non-discretionary, before you select a fund for the Plan’s menu. To determine whether a particular investment is appropriate, carefully consider the important information on the investment objectives, risks, charges and expenses. Your Designated Advisor can provide a copy of the prospectus. ETFs charge various fees and expenses, which will reduce the actual returns of your investment. 10. Special Pool Investments Insurance Funds Special pool investments insurance funds are pooled investment vehicles created under state insurance law. The value of these funds will fluctuate up or down, depending on the performance of the underlying investments in the fund. Most special pool investments insurance funds are exempt from registration under the federal securities laws. INFORMATION AND CYBER SECURITY RISKS F. With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly, BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, the funds and fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchanges and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents suffered by BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third- party providers have experienced cybersecurity incidents, as well as adverse impacts from such incidents, and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we or our service 22  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE providers will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory, operational and ESG reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. G. ESG-THEMED FUNDS There are an increasing number of products and services that purport to offer environmental, social, and governance (ESG) investment related strategies (“ESG Strategies”. The variability and imprecision of industry ESG definitions and terms can create confusion. Investment managers and product sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. Merrill generally does not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the manager) other than as part of the CIO Review Process. You should review the fund prospectus to gain an understanding of how these managers and product sponsors describe their investment approach. ESG Strategies, including ESG-related Funds, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries or 23  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by a Style Manager or fund manager, will align with your ESG-related beliefs or values. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the Style Manager or Fund manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities and, as a result, investment performance could suffer. On the other hand, category restrictions that aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category may not exclude all companies with any tie or revenue derived from such restricted category and require assumptions, opinions and the subjective judgment of the data provider that might not reflect your ESG-related views or values. If you hold an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event. Category restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that client restrictions would not have any practical effect on an account comprised primarily of Fund investments. When evaluating investments for an ESG Strategy, a Style Manager or fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment of an investment’s ESG or sustainable attributes. Merrill does not guarantee or validate any third-party data, ratings, screenings or processes. Moreover, the screenings and processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in a Portfolio holding investments in companies that derive revenue from the restricted category. IMPORTANT CLIENT RESPONSIBILITIES For the various services described herein, you are asked to complete a questionnaire or other form that elicits various types of information. You are responsible for providing accurate and complete information, and a failure to do so could significantly affect the services that we provide. In addition, external dependencies, including custodial obligations, are critical to the services provided in this agreement and may also impact the level of service provided. You are encouraged to work closely with your Designated Advisor to understand onboarding requirements and the dependencies that may impact the timing of service delivery, which may differ across the services provided under the Program (see Detailed description of services for further information). Further, you are obligated to notify your Designated Advisor promptly of any material change in financial circumstances or investment objectives that may affect the Program and if any of the representations, warranties or covenants included in the Client Agreement are no longer complete or accurate. You will use best efforts to notify Merrill if any of the below representations become inaccurate or if the identity of any of the Plan's named fiduciaries with respect to this relationship changes. In no event shall Excluded Assets be included as assets subject to the FAS Client Agreement. If you enroll in FAS Discretionary, you are contractually obligated to provide Plan participants with timely notices of changes in Discretionary Investment Menus and all notices and other information applicable to 24  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE QDIAs, in accordance with applicable Department of Labor requirements (or arrange for a third party to provide such notice). You will also be responsible for completing and executing any additional documentation, such as a participation agreement, that may be required to add, remove or otherwise change an investment option for your Plan. If you enroll in FAS non-discretionary, you represent and confirm that you have sole and final responsibility for selecting all investments for inclusion in your Plan’s menu. You have also concluded that participation in FAS is prudent and shall determine, in your own discretion, that each investment included in the Plan’s menu is a suitable investment for the Plan participants. Additionally, if you enroll in FAS non-discretionary with an External Provider, you must provide your Merrill and your external record keeping provider authorization for Merrill or a Merrill Affiliate to receive data from your record keeper in order for us to provide the Fiduciary Advisory Services Report. Failure to provide complete, accurate, and timely information could significantly affect the services provided. You should understand that our services described above should not substitute for or diminish the careful deliberation and determination made by those Plan fiduciaries having responsibility for management and administration of the Plan, following appropriate consultation with your other professional advisers and the review of relevant Plan documentation. DISCIPLINARY INFORMATION The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill Lynch’s Form ADV at: http://www.adviserinfo.sec.gov/. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a 25  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’s remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional private clients. Through its own arrangements and through its Affiliate BofA Securities, Inc. (“BofAS”), it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. Merrill also acts as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As a registered investment adviser, Merrill completes a Form ADV which is publicly filed with the SEC (available at http://www.adviserinfo.sec.gov/). For purposes of Form ADV Part 2, certain Merrill management persons are registered as registered representatives or associated persons of Merrill. In the future, certain Merrill personnel may be considered 26  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of Merrill to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, including us, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include: (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning; asset management and investment advisory and related record- keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research including: global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act and additional information about BofA Corp. can be found in publicly available filings with the SEC. From time to time, a shareholder of BofA Corp. may acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your account, such as buying or selling securities issued by the shareholder or its Affiliates, may be limited. We, through our Advisors, may suggest or recommend that clients, including Program clients, use Merrill’s securities account, execution, and custody or other services, or such services of an Affiliate. Similarly, Advisors, who also handle clients’ securities accounts, may suggest or recommend that clients purchase Merrill’s products or products of an Affiliate. Where you use or purchase Merrill’s or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Advisors may, as permitted by applicable law, receive compensation (the amount of which may vary) in connection with these products and services. PSMs can open defined contribution plan accounts and offer and provide FAS and EPS but are not eligible to offer or provide other Merrill products and services. Merrill and its Affiliates may have business relationships with the officers, directors, or employees of a variety of clients, including corporations, pension and retirement plans, and other entities receiving FAS. These business arrangements may create a conflict of interest to the extent that these individuals have any role or influence in the hiring or retention of Merrill and its Advisors or PSMs or with respect to their compensation. We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure. Moreover, our Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. While PSMs can open defined contribution plan accounts and offer and provide FAS and EPS they are not eligible to offer other Merrill products and services, they are required to make recommendations that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. 27  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest—both those arising between and among client accounts as well as between client accounts and our business. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. CONFLICTS OF INTEREST AND INFORMATION WALLS Merrill and its parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within the BofA Corp. organization possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., BofAS and Merrill evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. B. CODE OF ETHICS We have adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services. The Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that we follow in conducting our business with integrity and professionalism. Each Code of Ethics covers requirements relating to: • Employees complying with all applicable securities and related laws and regulations • Reporting and/or clearance of employee personal trading. • Prevention of misuse of material nonpublic information; and • Obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. All covered personnel must certify to the receipt of the Code of Ethics. We will provide a copy of each of the Code of Ethics to you upon request. We have imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions, as well as those of all employees. Our requirements impose certain responsibilities on Designated Advisors and their trading. Designated Advisors are permitted to participate in block trades along with their clients and/or other Program clients. 28  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE C. COMPENSATION, CONFLICTS OF INTEREST AND MATERIAL RELATIONSHIPS 1. Sales Compensation – Benefits to Merrill and Designated Advisors from Enrolling in FAS Merrill Benefits. Merrill earns revenue from the fee you pay as part of the Program Fee. We (including our Affiliates) and your Designated Advisor and other of our employees benefit from the fees and charges paid by you and other clients for the Services described in this Brochure. The compensation structure for Designated Advisors results in conflicts of interest between clients and Designated Advisors as described in this Brochure. Advisors earn compensation and benefits based on the revenue that Merrill earns from the fees paid in the Program, as well as revenue derived from certain, but not all, of the other fees and costs you incur that are not covered by the Program Fee. In addition, we earn revenue, and the Advisor earns compensation, from the referrals to Affiliates (including referrals to an Affiliate for banking products or services). PSMs receive a salary and may receive incentive compensation. PSMs do not receive commissions, bonuses or other compensation based directly on the sale of specific securities or the achievement of sales targets. PSMs may receive a discretionary incentive based on factors related to their performance in their role, which may include productivity, client experience and retention, among other responsibilities. Merrill may also receive revenue from third parties depending on the investment products in which you invest, which is not part of the Designated Advisor’s compensation. As Merrill revenue increases, the Designated Advisor’s compensation will increase or will be positively impacted. The amount of revenue we receive and compensation your Designated Advisor earns varies depending on the type of Designated Advisor (i.e., an Advisor or a PSM) and the program, service or product you select. These differences create a conflict of interest in that there is a financial incentive for your Advisor to recommend or select a certain type of relationship or certain investment programs based on the nature of the compensation they will receive. The amount of revenue we receive from your enrollment in the Program may also be more or less than the revenue that would be received if you had instead participated in other of our investment advisory programs or if you had engaged in the investment activities in a brokerage account. If there is higher compensation to us, your Advisor has a financial incentive to recommend certain investment strategies to you or recommend this Program over other programs or other services offered by us or our Affiliates. Designated Advisor Benefits. Advisors that provide services to you under the Program receive a portion of the Program Fee as compensation. If you have an asset-based fee rate, the more assets there are in your account, the more you will pay in fees, creating a financial incentive to recommend that you increase the assets in your account. In the Program, we make more revenue based on the level of assets in the account if you have an asset-based fee rate as well as the level of the Program Fee rate that you agree to or are charged. PSMs can open defined contribution plans and offer and provide FAS and Education & Plan Services but are not eligible to offer or provide other Merrill products and services. PSMs do not receive commissions, bonuses or other compensation based directly on the sale of specific securities or the achievement of sales targets. PSMs may receive a discretionary incentive based on factors related to their performance in their role, which may include productivity, client experience and retention, among other responsibilities. There is a conflict of interest when an Advisor recommends an account or program type, a security transaction or investment strategy where it is expected that Merrill will earn greater revenue over another account or program type, security transaction or investment strategy, and therefore an Advisor will earn more compensation. We address conflicts described in this and throughout the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure, by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, our Advisors are required to recommend investment advisory 29  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. While PSMs can open defined contribution plan accounts and offer and provide FAS and EPS they are not eligible to offer other Merrill products and services, and they are required to make recommendations that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. 2. Compensation And Benefits to Merrill and Designated Advisors Designated Advisors are paid a salary and incentive compensation by us based on the revenues Merrill receives for the Program Services that we and your Designated Advisor provide to your account. In general, an Advisor is credited with a portion of the Program Fee paid in the form of “production credits”. We compensate PSMs differently than we do Advisors. PSMs do not receive commissions, bonuses or other compensation based directly on the sale of specific securities or the achievement of sales targets. PSMs receive a salary that does not vary based on program fees or account assets. PSMs may receive a discretionary incentive based on factors related to their performance in their role, which may include productivity, client experience and retention, among other responsibilities. Advisors are eligible to receive a compensation award, payable over a defined period of time, from an incentive program that is currently based on meeting growth targets from the prior year in new households and in assets and liabilities. The growth in assets and liabilities component of the award is based on: the movement of client assets into accounts enrolled in this Program and our other investment advisory programs; investment activity in specified investment products (e.g., money market funds, alternative investments, 529 Plan accounts, annuities and/or life insurance); the opening of new BANA trust accounts; the establishment of 401(k) Plan accounts; and clients’ participation in banking and lending services (i.e., brokerage sweep deposit accounts and brokerage sweep money market funds, checking and savings accounts, the Preferred Deposit product available in brokerage accounts, loans, mortgages and margin lending) offered by Merrill, BANA and our other Bank Affiliates. Advisors do not receive additional compensation as a result of advisory client assets held in the bank deposit Cash Sweep Program. An Advisor is subject to a reduction in their incentive compensation grid if they fail to achieve growth for two consecutive years in the assets and liabilities component of the award. Merrill considers and approves its compensation program from year to year and its compensation criteria can change which will impact compensation paid to Designated Advisors. Having a compensation award based on meeting criteria based on client investment activity and engaging with Merrill or Affiliate financial and banking-related services presents a conflict of interest between the Advisor and you because it could lead to such activity being promoted by your Advisor to qualify for the compensation award or to avoid the reduction in their incentive compensation. Merrill addresses this conflict in a variety of ways, including by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures, documentation provided to clients prior to or at time of sale and disclosures in this Brochure. Advisors are also eligible to receive referral fees under defined referral programs and guidelines in the form of production credits based on referrals of clients to our bank Affiliates and other Merrill Affiliates for banking and lending services, like mortgages, as well as for referrals related to other financial services to other of our Affiliates. Advisor Recruitment Payments. Advisors who join Merrill from other firms generally receive payments in connection with that move. These payments may take various forms, including salary guarantees, upfront bonuses or loans, and various forms of compensation contingent on continued employment. The amount paid to an Advisor under these arrangements generally is based to a large extent on the size of the business serviced by the Advisor at their prior firm. In addition, as part of the recruiting arrangements, 30  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Advisors are eligible for future bonus payments based on assets that transfer to Merrill, including from the Advisor's prior firm, which creates a conflict of interest since the Advisor has an incentive to recommend that you transfer your assets to us. The future bonus payments are conditioned on the total assets in accounts serviced by the Advisor at Merrill. These bonuses are in addition to the incentive compensation to which they are otherwise entitled as Advisors. 3. Field Management and Merrill Management Compensation Elements of our field management compensation are based on revenues to Merrill as well as either 1) the Advisors whom they manage meeting strategic goals set for the year, including growth in assets and liabilities as well as participation in banking and lending services described above offered by Merrill, BANA and our bank Affiliates., or 2) on the PSMs whom they manage meeting performance and service goals and such other criteria as Merrill may establish from time to time. Management personnel and other employees of Merrill and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Merrill’s and BofA Corp.’s profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is an incentive for our field management team to encourage Advisors to recommend products and services that result in more revenue to Merrill and to meet their strategic growth compensation targets under the Advisor compensation plan. This includes enrollments into the Program, transactions in certain types of investment products and clients’ participation in banking and Affiliate lending programs, and other compensation targets. There is a financial incentive for management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. There is also incentive for field management to encourage PSMs to meet their performance and service goals that can result in more revenue to Merrill. We maintain policies and procedures and supervisory and review processes that are reasonably designed to ensure that Advisors meet the standard of conduct applicable to each client and that compensation plans and referral compensation and criteria have been designed and implemented to mitigate any incentive or conflict to favor any one security type or investment product or service. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. 4. Account and Program Choice Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Clients may have the ability to enroll accounts in the Program holding some or all of their investment assets and to have brokerage accounts for some of their assets. The various programs we offer and ways to interact with Merrill are outlined in the Services to Help You Create a Strong Retirement Plan fact sheet and the Statement of Services. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance for your Plan. The Program Fee you pay covers the services under the Program, including investment advice and guidance as described in this Brochure. You may be able to obtain the same or similar services or types of investments through other investment advisory programs and services offered by Merrill. These may be available at lower or higher fees than the 31  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Program Fee you pay. You may also be able to obtain some or all services from other firms and at fees that may be lower or higher than the Program fee we charge. We address potential conflicts in the following ways. We provide clients this Brochure and the Client Agreement, and by upfront information about our available programs. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Moreover, our Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. 5. Mutual Fund-Related Compensation; Other Compensation Your Plan may invest in mutual funds. We only make available mutual funds, money market funds, (each, a “fund”) and share classes of funds that retain and pay us to provide the required sub-accounting and other services for shareholders of such mutual funds who maintain their shares in a Merrill securities account. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges, dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping, services (together, “sub-accounting services”). Under agreements with each of these funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services to the holders of these funds maintaining shares in an account as well as in other Merrill securities accounts and receives the agreed-upon sub-accounting services fee. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by fund types, fund and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. For U.S. mutual funds, depending on the specific arrangement, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.26% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market mutual funds, the sub- accounting services asset-based fee is generally 0.005% per annum, while certain funds may also include an asset-based administration fee up to 0.50% per annum. We do not retain compensation for sub-accounting services for funds held in accounts enrolled in the Program. We have a conflict of interest in selecting certain fund products (or share classes) for inclusion as part of our product offering available to you. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of our product menu but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting services fees that we charge will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the sub-accounting services fees varies among funds and, in certain instances, between share classes of individual funds. This results in a conflict of interest because it creates an incentive for us to recommend that you invest in funds and share classes that pay higher fees. We receive higher sub- accounting payments from fund families that have higher fund assets held in our clients’ accounts as the 32  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE service fee calculation is based off of the level of the asset holdings. Additionally, there is a benefit to us because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. We address these conflicts of interest in the following ways. We disclose the nature of our sub-accounting service arrangements. We also determine the compensation paid to our Designated Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Designated Advisors do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. We also receive distribution (12b-1) fees up to 1.00%, administrative and shareholder servicing fees up to 0.55% with respect to mutual funds offered to customers, including participants in Plans that access the Program through Merrill or our Advisor Alliance providers. We receive but do not retain compensation for sub-accounting, distribution (12b-1) fees, and administrative and shareholder servicing fees with respect to mutual fund assets held in Merrill accounts for Plans that access the Program. For more information, please refer to the document entitled “Mutual Fund Investing at Merrill Lynch” or refer to the ERISA 408(b)(2) Fee Disclosure available from your Designated Advisor upon request. We also receive compensation from some mutual fund sponsors for our distribution, marketing, and other support with regard to their mutual funds in amounts that may vary by fund; we do not collect (or if we receive, we do not retain) such fees with respect to mutual fund assets held in Merrill accounts for Plans that access the Program. You should be aware that, except for mutual funds where no fees apply (zero revenue), the amount of fees paid by the different mutual funds and/or mutual fund sponsors varies and that mutual funds that would otherwise meet our criteria for inclusion in the Program but whose principal underwriters, agents or sponsors do not agree to pay such fees will not be selected, thereby limiting the available universe of mutual funds. For plans record kept with External Providers, we do not receive sub-accounting, distribution (12b-1), administrative, shareholder servicing, or distribution, marketing, and other support fees with respect to a Plan’s mutual fund assets as these assets are not custodied at Merrill. Your Plan may also invest in CIFs. Merrill receives certain servicing fees from CIFs. These fees are set forth in the purchase, subscription or participation agreement governing each investing plan’s investment in the fund as well as in the annual collective trust fund financial statement. We receive but do not retain these servicing fees with respect to CIF assets held in Merrill accounts for Plans that access the Program. For more information, please refer to the ERISA 408(b)(2) Fee Disclosure available from your Designated Advisor upon request. Consistent with applicable laws, management and employees of BofA Corp. and its Affiliates may be provided a broader level of access and exposure to Merrill, our management, Advisors and other personnel, marketing events and materials, and client-related and other information. Such access and exposure may not be available to other asset managers and may enhance the ability of BofA Corp. Affiliates to distribute their investment products through us. You should be aware that the amount of compensation paid by the different mutual funds and CIFs varies, and the presence of these compensation arrangements also creates an incentive for us to recommend an investment in mutual funds or CIFs that pay higher fees to us or our Affiliates. It is possible that the presence of these compensation arrangements will also cause us and our Affiliates to forego opportunities to negotiate more favorable financial terms for client investments in mutual funds or CIFs. We attempt to address the conflicts of interests associated with the compensation arrangements by calculating the compensation paid to our Designated Advisors on the same basis for all Program assets without regard to the amount of compensation arrangements we or our Affiliates receive in connection with the Investments. 33  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation arrangements and other business arrangements from affecting the nature of the advice we and our Designated Advisors provide, although such policies and procedures do not eliminate such conflicts of interest. In addition, we and our Affiliates select funds that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Retirement Bank Account (“RBA”) is a Bank of America, N.A.(“BANA”) bank deposit product. Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Deposits in RBA at BANA are financially beneficial to Merrill and its Affiliates. BANA uses bank deposits to fund its lending, investment and other business activities. Like other depository institutions, the profitability of BANA is determined in large part by the difference between the interest paid by BANA on bank deposits, and the interest or other income earned by BANA on loans, investments and other assets which may be funded in part by bank deposits. In addition, BANA determines the interest rate paid to depositors in RBA. For RBA, Merrill receives but does not retain compensation it receives as agent. (See section entitled Fees and Compensation –Invoices and Methods of Payment.) As described above, RBA will not be included as an FAS Eligible Investment that will be recommended to clients, and will be considered an Excluded Asset (and therefore, not included in the amount of Plan assets used to calculate a FAS fee). D. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS We, our Affiliates and employees benefit from the fees and charges you pay for FAS. You may also use other products or services available from or through us and, in such case, pay additional compensation, including fees for services related to Education and Plan Services for Plans who may also be FAS clients. Designated Advisors offering these services and providing ongoing assistance to you will, in turn, receive compensation from us. As noted above, you are not obligated to implement any of the FAS recommendations or to trade through Merrill. Similarly, you may determine whether to use any new or additional products and services offered by us. In such cases, we and our Designated Advisors will benefit from the additional compensation paid or generated from the above. E. RELATED PERSONS Other BofA Corp. Affiliates or divisions offer their own managed products or wrap fee programs that are similar to this or other Merrill programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including advice related to the recommendation of certain funds or investment managers. This is due to, among other things, the differing nature of the Affiliate’s investment advisory services and differing processes and criteria upon which determinations are made. F. SECURITIES TRADING BY MERRILL AND OUR PERSONNEL As part of a global financial services firm, Merrill will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by Merrill or any of its Affiliates, it or its Affiliates’ roles in connection with other clients and in the capital markets, its internal policies, and/or potential reputational risk. As a result, client accounts managed by Merrill may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by BofA Corp. From time to time in the course of those duties, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. See “Code 34  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE of Ethics, Participation or Interest in Client Transactions and Personal Trading - Conflicts of Interest and Information Walls.” We may give advice or take action with regard to certain clients, including FAS clients, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken for certain securities or investment managers. In some instances, the actions taken by Affiliates for similar services and programs may conflict with the actions taken by us. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. In addition, potential conflicts of interest also exist when Merrill maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon Merrill or its Affiliates by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude the inclusion of particular securities or financial instruments in a client’s investment menu where Merrill or its Advisors provide discretionary management services, even if the securities or financial instruments would otherwise meet the investment objectives of such investment menus. We and our Affiliates limit the overall aggregate ownership in certain mutual funds and ETFs (“In-Scope Funds”) by us, our Affiliates and those Merrill clients that have granted discretion to us, our Affiliates and/or Advisors (“discretionary clients”) to avoid potential restrictions on, and our Affiliates' ability to engage in, principal trading and other transactions with In-Scope Funds. A portion of the aggregate ownership limit is attributed to our Affiliates. When we and our Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to Merrill or our Affiliates, there is a corresponding reduction of the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In- Scope Funds that otherwise may have been the best available investment alternatives. Because both our and our Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest for us in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. Many of the conflicts related to participation or interest in client transactions and personal trading are less pronounced in the context of FAS because Designated Advisors do not make specific securities recommendations or analyze particular securities, other than the reviewed funds and other investment types to be considered for the Plan’s menu. We address these conflicts in a variety of ways, including through disclosure in this Brochure, our policies that require our Advisors to recommend investment advisory programs, investment products and securities that are suitable for, and in the best interest of, each client based upon your investment objectives, risk tolerance and financial situation and needs and considering cost; as well as a variety of restrictions, procedures and disclosures designed to address actual or potential conflicts of interest – both those arising between and among Accounts as well as between Accounts and our business (e.g., personal trading preapprovals, self-reporting, restrictions on our personnel detailed in our policies and procedures and Code of Ethics). BROKERAGE PRACTICES The Program does not make specific securities recommendations or analyze particular securities, other than the funds and other investment vehicles to be considered or used in your Plan’s investment menu. 35  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE REVIEW OF ACCOUNTS An important part of the Program relationship involves providing you with the opportunity to engage in periodic reviews with your Designated Advisor. These reviews provide updates on the progress of your Plan towards your goals and other important information about your Plan menu investments. On a periodic basis, your Designated Advisor will review with you the Plan’s Menu Design, and investments included on the Plan’s menu. Because these reviews provide you with important and necessary information relating to your Plan, you are strongly encouraged to take advantage of these opportunities to participate in these reviews. Your Designated Advisor shall be made reasonably available to assist you in reviewing and evaluating the reports on the Plan provided through FAS. Any review we perform does not substitute for your continued review of your reports or accounts. Our Program guidelines provide that, at a minimum, a periodic review of your Plan should occur on an annual basis, with Merrill having the ability to extend or defer the annual meeting within certain time limits based on meeting certain criteria. If you do not participate in a review within the timeframes we have established in our Program Guidelines, we have the right to, in our discretion, terminate your Plan from the Program. CLIENT REFERRALS AND OTHER COMPENSATION A. COMPENSATION FOR CLIENT REFERRALS Merrill has not entered into any client referral arrangements with third parties in connection with referrals of clients to FAS (Please see the section entitled Fees and Compensation - Compensation for the Sale of Products). B. OTHER COMPENSATION Please see the section entitled Code of Ethics, Participation or Interest in Client Transactions and Personal Trading – Compensation, Conflicts of Interest and Material Relationships. 1. Relationships With Third-Party Firms Third-Party Firm Business Relationships and Support We and our Affiliates have business relationships with investment managers, including Style Managers, PAS Managers, fund managers, distributors and sponsors, and insurance companies and other product providers (“Third-Party Firms”). We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for a Third-Party Firm and for any fund offered through the Program. We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates is additional compensation to us for services we and our Affiliates provide to them. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. 36  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our Advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, we select investment products that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our Designated Advisors, which can include PSMs, provide. Participation and Sponsorship by Third-Party Firms for Merrill Conferences, Manager Meetings and Charitable Events Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences for invited Merrill financial professionals. These financial professionals include Designated Advisors, and members of their team, employees who work for a Merrill branch, market or division to support Advisors (field management employees), which can include Designated Advisors and employees who cover product, Chief Investment Office and home office support functions (non-field employees). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third-Party Firms participate. Merrill organizes the conferences and client events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the conferences and client events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending Advisors and select employees facilitating the conferences and/or client events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses in connection with a number of conferences and client events in the amount of approximately $21 million. Certain Third-Party Firms periodically host or participate in manager meetings where they provide certain Advisors, Field management employees and non-field employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending Advisors, field management employees and certain permitted non-field employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to manager Meetings was $3.1 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of charitable events and causes that we requested or initiated with the Third-Party Manager in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for conferences, client events, Manager Meetings and charitable events present conflicts of interest. They create incentives for Designated Advisors to recommend products of participating Third-Party Firms. They give those Designated Advisors participating in conferences, client meetings, Manager Meetings and charitable events more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of 37  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE interest for field management employees to approve those recommendations and for non-field employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our Designated Advisors to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize field management employees to approve their Designated Advisor recommendations of products and services of those participating Third-Party Firms. Furthermore, we do not incentivize non-field employees to approve particular products of a Third-Party Firm for the Merrill platform. Third-Party Firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs for conference and client events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Third-Party Firm Office Access and Gifts and Entertainment Representatives of Third-Party Firms will, from time to time, meet and work with Designated Advisors, field management employees and non-field employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third-Party Firms from providing or paying for, and our Designated Advisors, field employees and non-field employees, from receiving, gifts and entertainment (including meals) other than as permitted by and subject to the limits established under Merrill internal policies. In general, our Designated Advisors, field management employees and non-field employees may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting Third-Party Firm representatives access to our financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. It can also create incentives for field management employees to approve recommendations of a Designated Advisor, where required. Furthermore, providing gifts and entertainment to non-field employees creates incentives to approve the investment products of the Third- Party Firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency of office visits and other business interactions and the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third- Party Firms. 2. Provision of Diversified Financial Services by Us and Our Affiliates From time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships are publicly available in Regulation NMS Rule 606 reports we file with the SEC. 38  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE CUSTODY To the extent we or an Affiliate hold any of the assets of your investment portfolio under this Program, you receive account statements from us or an Affiliate. You also should receive account statements from other unaffiliated custodians for assets of your investment portfolio held with such other unaffiliated custodians. We urge you to review these account statements carefully. Clients who do not receive such account statements are encouraged to follow-up directly with their custodian and request such statements. To the extent you receive additional reports from us, you should compare these reports to account statements received from custodians. Such reports may vary from custodial account statements based on accounting procedures, reporting dates, valuation methodologies and other factors and are not intended to be a substitute for account statements provided by a custodian, and should not be used for official purposes. Your account statement from us or an Affiliate or the account statements provided by other custodians reflect your official record of holdings, balances, and security values INVESTMENT DISCRETION For FAS discretionary, Merrill will exercise discretion to select investment options for a Plan’s investment menu that will be available to participants in a defined contribution plan as described in the brochure. However, Merrill does not have discretionary authority to manage securities accounts on behalf of Plan participants in connection with FAS (for both the FAS Non-Discretionary or FAS Discretionary services). VOTING CLIENT SECURITIES FAS does not involve voting proxies on the client’s behalf. FINANCIAL INFORMATION None. 39  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE GLOSSARY “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Advisor” means a select group of registered representatives that have designation or title “Financial Advisor,” “Private Wealth Advisor,” or “Wealth Management Advisor” who offer or provide an array of Merrill products and services. “Advisor Alliance” means a network of nationally recognized recordkeeping service providers selected by Merrill in a thorough structured selection process to be record-kept on a Merrill specific platform. Information on Advisor Alliance can be obtained through www.benefitplans.baml.com, Retirement Plans and Solutions For Small Businesses. “Affiliate” means a company that is controlled by, in control of, or under common control with another company. “BANA” means Bank of America, N.A. “Bank Affiliate” means Bank of America, National Association (BANA) or other banks that are affiliated with us. “BofA Corp.” and “BAC” means Bank of America Corporation. “BofAS” means BofA Securities, Inc., an Affiliate of Merrill. “Brochure” means the Merrill program brochure relating to the Merrill Lynch Fiduciary Advisory Services Program, as amended or updated from time to time. “Client” or “you” or “your” means the Plan Sponsor (or other named fiduciaries). “Client Agreement” means the investment advisory agreement between the Client and Merrill that you sign for the Program, as amended from time to time. “Code of Ethics” means Merrill’s Investment Adviser Code of Ethics. “CIFs” means Collective Investment Funds. “CIO” means Merrill’s Chief Investment Office “Designated Advisor” means a Merrill Advisor (Advisor) or Program Solutions Manager (PSM)that has met certain Merrill requirements and qualifications to deliver FAS services. “Discretionary Investment Menu” means an investment menu where Merrill will act as an ERISA Section 3(38) fiduciary to the extent it initially selects, and on a periodic basis makes changes to, investment options for a Plan’s investment menu. “EPS” means Education and Plan Services, a non-fiduciary service designed to provide education, resources and guidance related to relationship management and employee education services. EPS is not offered under FAS but is a separate service to defined contribution plans. “Eligible Investments” means those investments which Merrill’s CIO has performed due diligence review, and determined the investments meet Merrill’s and/or third party due diligence standards. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “Excluded Assets” means the investment portfolio assets that Merrill will not assist the Client in the evaluation, review and selection of investment managers and strategies under the Program. These assets include participant loan balances, self-direct brokerage accounts/balances, in plan retirement income options, custom 40  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE funds, or BofA Corp. or Merrill affiliated mutual funds or other affiliated products (including, without limitation, deposit products including Retirement Bank Account). “External Providers” means record keeping providers that are not Merrill or our Advisor Alliance providers. “FAS” or the “Program” means the Merrill Lynch Fiduciary Advisory Services Program. “FASR” means the Fiduciary Advisory Services Report. “FINRA” means the Financial Services Regulatory Authority, Inc. “Gifts” mean non-monetary gifts and gratuities such as promotional items (e.g., coffee mugs, golf balls, or gift baskets) and meals. “Group Annuity Plans” means group funding agreement based platforms. “Group Annuity Providers” means recordkeeping services provided by Advisor Alliance providers on group annuity or group funding agreement based platforms. “Investment Company Act” or “1940 Act” means the Investment Company Act of 1940, as amended. “IPS” means an Investment Policy Statement. “Menu Type” means Merrill’s offering of several types of investment menus, consisting of specific and diversified asset classes for which Merrill will provide advice and guidance that may be most appropriate the Plan. “Merrill,” “MLPF&S,” “we,” “us,” or “our” means Merrill Lynch, Pierce, Fenner & Smith Incorporated. “PAS Manager” means a third-party investment manager who provides discretionary managed strategies selected by MLPF&S for the Program and related investment advisory and trading services. This type of manager may also be referred to as a DC Manager in certain of our Program materials. “Plan” means the participant-directed, defined contribution plan subject to ERISA that is maintained by the Plan Sponsor and enumerated in the FAS Client Agreement. “PSM – a role or employee designation at Merrill that is a Designated Advisor and is distinct from a representative that has the title “Advisor." Program Solutions Managers can open defined contribution accounts and offer and provide FAS and EPS but are not eligible to offer or provide other Merrill products and services. “Program Fee” means the FAS fee. “Qualified Default Investment Alternative” or “QDIA” has the meaning as described in Section 404(c)(5) of ERISA and Department of Labor regulation 2550.404c-5. “RBA” means Retirement Bank Account. “Review Process” means multi-factor review process of actively managed mutual funds or actively managed collective investment funds, whether conducted by Merrill or a third party. “SEC” means the U.S. Securities and Exchange Commission. “Securities Act” means the Securities Act of 1933, as amended. “Style Manager” means an investment adviser, which may be Merrill, its Affiliate, or a third-party that provides a client’s Account with advice regarding the securities or other property to be purchased or sold in an Account. “Third-Party Firms” means asset managers or fund managers. “Training Events” means conferences that Merrill or an Affiliate hosts for clients. 41  MERRILL LYNCH FIDUCIARY ADVISORY SERVICES BROCHURE “Trust Management Accounts” or “TMA” means accounts over which BANA performs trust services, in additional to custodial duties for the plan. Unless otherwise noted, registered service marks and service marks are the property of BofA Corp. Corporation © 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated Printed in the U.S.A. 42 

TM Merrill Lynch Managed Account Service WRAP FEE PROGRAM BROCHURE Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 800.637.7455 www.ml.com TM This wrap fee program brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“Merrill”) relating to the Merrill Lynch Managed Account Service . If you have any questions about the contents of this brochure, please contact us at 800–MERRILL (800-637-7455). The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about Merrill also is available on the SEC’s website at www.adviserinfo.sec.gov. The investment advisory services described in this brochure are not insured or otherwise protected by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency; are not a deposit or other obligation of any bank or any affiliate of Merrill; are not endorsed or guaranteed by Bank of America, N.A., Merrill, any bank or any affiliate of Merrill; and involve investment risk, including possible loss of principal. March 21, 2025 Investment products: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value MAS2A 0325  MATERIAL CHANGES On March 22, 2024, MLPF&S filed its last annual update for the Merrill Lynch Managed Account Service brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. It also sets forth changes as well as enhancements made in this annual update as well as those made since the 2024 annual update, which were previously communicated. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated “Additional Information” at the heading “Disciplinary Information” to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its Financial Advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We enhanced existing disclosure regarding the conflicts of interest that Advisors have when determining the MAS Fee Rate they will agree to with a client. See “The MAS Fee” and “Compensation, Conflicts of Interest and Material Relationships.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our Financial Advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Compensation, Conflicts of Interest and Material Relationships.” MATERIAL CHANGES AND ENHANCED DISCLOSURES MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes and Enhancements • We updated “Additional Information” at the heading “Disciplinary Information” to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and- desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” • We have updated our disclosures throughout the Brochure to make other enhancements. 1 MAS2A 0325Merrill Lynch Managed Account Service Brochure TABLE OF CONTENTS MATERIAL CHANGES ............................................................................................................................................................................. 1 TABLE OF CONTENTS ........................................................................................................................................................................... 2 SERVICES, FEES AND COMPENSATION ..................................................................................................................................... 3 DESCRIPTION OF MAS ........................................................................................................................................................................ 3 INVESTMENT MANAGERS ................................................................................................................................................................. 4 OPTIONS AND MARGIN STRATEGIES ........................................................................................................................................... 5 REASONABLE INVESTMENT RESTRICTIONS ............................................................................................................................ 6 FUNDING AND OPERATION OF MAS ACCOUNTS ................................................................................................................... 6 CUSTODIAL AGREEMENTS .............................................................................................................................................................11 TRADING IN MAS ACCOUNTS ........................................................................................................................................................12 PROXY VOTING AND OTHER LEGAL MATTERS ......................................................................................................................15 THE MAS FEE ........................................................................................................................................................................................15 ABILITY TO OBTAIN THE MAS SERVICES SEPARATELY .....................................................................................................19 TAX MATTERS .......................................................................................................................................................................................21 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS .....................................................................................................22 CLIENT ELIGIBILITY ............................................................................................................................................................................22 RETIREMENT ACCOUNTS ................................................................................................................................................................23 ACCOUNT MINIMUMS ......................................................................................................................................................................23 PORTFOLIO MANAGER SELECTION AND EVALUATION .................................................................................................23 SELECTION OF INVESTMENT MANAGERS ..............................................................................................................................23 INVESTMENT MANAGERS ...............................................................................................................................................................23 MERRILL AND CERTAIN AFFILIATES ACTING AS PORTFOLIO MANAGERS ...............................................................24 TAILORED INVESTMENT ADVICE .................................................................................................................................................24 PERFORMANCE BASED FEES ........................................................................................................................................................24 METHODS OF ANALYSIS ..................................................................................................................................................................25 VOTING CLIENT SECURITIES .........................................................................................................................................................25 INVESTMENT RISK .............................................................................................................................................................................25 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ..............................................................................29 CLIENT CONTACT WITH PORTFOLIO MANAGERS .............................................................................................................29 ADDITIONAL INFORMATION ...........................................................................................................................................................29 DISCIPLINARY INFORMATION .......................................................................................................................................................29 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................................................................................30 CONFLICTS OF INTEREST AND INFORMATION WALLS.....................................................................................................31 CODE OF ETHICS ................................................................................................................................................................................31 COMPENSATION, CONFLICTS OF INTEREST AND MATERIAL RELATIONSHIPS .....................................................32 PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ..............................................................................................40 COVERED ENTITIES UNDER THE VOLCKER RULE ................................................................................................................43 REVIEW OF ACCOUNTS ....................................................................................................................................................................44 CLIENT REFERRALS AND OTHER COMPENSATION .............................................................................................................45 FINANCIAL INFORMATION ...............................................................................................................................................................45 GLOSSARY ..................................................................................................................................................................................................46 2 MAS2A 0325Merrill Lynch Managed Account Service Brochure SERVICES, FEES AND COMPENSATION This Brochure relates to the Merrill Lynch Managed Account ServiceTM (“MAS” or “Program”), an investment advisory service offered by Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or Merrill”). This Brochure also contains important information relating to clients’ responsibilities for their accounts, certain conflicts of interest involved with the services offered, and other matters. You should read this Brochure carefully when deciding whether the services are appropriate for you and ask your Financial Advisor any questions you may have. MLPF&S is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser and as a broker dealer. Merrill is an indirect wholly-owned subsidiary of Bank of America (”BofA Corp.”). BofA Corp., through Bank of America, N.A. (“BANA”), BofA Securities, Inc. (“BofAS”) and other Affiliates, provides integrated investment services and is a leading banking institution for consumers, corporations, and institutions. Capitalized terms that are not defined in this Brochure have the meanings provided in the Glossary. As used in this Brochure, “you” and “your” refer to the client. “We,” “us,” “our” and “MLPF&S” refer to Merrill. DESCRIPTION OF MAS MAS is designed to accommodate, for a limited period, your selection of an investment manager (an “Investment Manager”) or strategy of an Investment Manager that is not currently available in a Merrill investment advisory program. In MAS, you select an Investment Manager and the investment style or discipline or combinations of investment styles and disciplines offered by the Investment Manager (“Strategy”). You then instruct us to accept orders from your Investment Manager for your MAS account (an “Account”). Importantly, we will not have discretionary authority over the assets in your Account. You have sole discretion in the selection of your Investment Manager and Strategy, and, except as described below, we have not and will not evaluate any Investment Manager or your Investment Manager’s investment style or Strategy for compatibility or suitability with your objectives. Further, we do not and will not conduct any due diligence on, or ongoing monitoring of, the Investment Manager or Strategy. In MAS, Merrill provides certain services to your Account as described in detail in this Brochure, such as (1) executing securities transactions upon the instructions of your Investment Manager; (2) providing clearance and settlement of transactions and custody of Account assets, and additional services provided to all our clients with assets held by us as a custodian; (3) an automatic sweep option of cash balances; (4) margin facilities; (5) periodic performance reports; and (6) the ability to receive periodic (as opposed to trade-by- trade) confirmation delivery. To open an Account, you must enter into an investment advisory agreement with us (the “Client Agreement”) and designate your Investment Manager and Strategy. You must also complete documentation for your underlying Merrill securities account that provides us with information regarding your overall circumstances, financial goals and risk profile, as well as your Account’s investment objective and other important information with respect to your Account (the “Underlying Account Documentation”). Because we may rely on the information furnished in the Underlying Account Documentation to provide services to you with respect to your Account, it is important that you understand and represent in the Client Agreement that the information furnished therein is accurate and complete in all material respects and that you will promptly notify your Financial Advisor of any material changes. If you select certain types of Investment Managers, you will be required to execute additional documentation, as described more fully in the section “Investment Managers” below. We want you to know a few things up front about MAS, including: • You enter into a Client Agreement with Merrill for the services you receive from us. • As described in greater detail below, you agree to pay Merrill an annual asset-based fee (“MAS Fee”) for the services you receive from us for your Account. 3 MAS2A 0325Merrill Lynch Managed Account Service Brochure • The MAS Fee is negotiable depending upon a number of factors. • You will need to enter into a separate agreement with your selected Investment Manager. • Your Investment Manager will charge you a separate advisory fee for its services. • Your Investment Manager is exclusively responsible for the management of your assets. The scope of any investment advisory relationship we have with you is defined in the Client Agreement you sign for MAS. When you are enrolled in MAS, we act as your investment adviser only for your Account and not any other assets or accounts, unless otherwise separately agreed to by us in writing. Our MAS advisory relationship begins when we enter into the Client Agreement with you, which occurs on the later of the date of acceptance of the signed Client Agreement by us or the date you have contributed assets in the Account. Preliminary discussions or recommendations, before we enter into the Client Agreement with you are not investment advice and should not be relied on as such. Merrill has certain fiduciary obligations in providing the services to your Account. As a fiduciary, we will act in your best interest and will endeavor to provide you material facts and information relating to the services. This Brochure is a key element in meeting this disclosure obligation. The fiduciary standards we aim to follow are established under the Advisers Act and, where applicable, state laws. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker- dealer, or as both. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in our Client Relationship Summary on Form CRS (Form CRS) and in the Summary of Programs and Services, both of which are available at ml.com/relationships or upon request. In addition, these documents provide a summary of the other available investment advisory programs we offer. Certain aspects of these investment advisory programs are similar to the Services available in the Program. Please refer to the section “Ability to Obtain the MAS Services Separately and for Different Fees.” INVESTMENT MANAGERS We designed MAS to accommodate, for a limited period, your selection of an Investment Manager or Strategy of an Investment Manager that is not currently available in a Merrill investment advisory program. You should understand that you assume important responsibilities regarding your Investment Manager. You are solely responsible for negotiating your agreements with your Investment Manager, and neither Merrill nor our Financial Advisors will participate or advise you regarding the terms of such agreements, the advisability of entering into such agreements, or of continuing the retention or termination of your Investment Manager. We strongly encourage you to contact your Investment Manager on a periodic basis to: • Discuss your Account and its investment performance. • Review your Investment Manager’s philosophy and style of management so that you may determine the ongoing compatibility of your Investment Manager to your investment objective, overall circumstances, financial goals, and risk profile. • Discuss any restrictions you wish to impose or modify on your Account. • Request information regarding conflicts of interest between you and your Investment Manager which we, our affiliates and your Financial Advisor may not be aware of and are under no obligation to investigate or disclose. • Receive a current copy of your Investment Manager’s Form ADV filing and/or brochure for review. • We also suggest that you periodically check the registration status and other information regarding your Investment Manager, including disciplinary events, at the SEC’s website: www.adviserinfo.sec.gov. • You assume responsibility for monitoring your Investment Manager and your Account’s performance. 4 MAS2A 0325Merrill Lynch Managed Account Service Brochure We will not: • Perform any ongoing due diligence review with respect to your Investment Manager. • Make any representation concerning your Investment Manager’s abilities or qualifications as an investment adviser. • Bear responsibility for the services rendered, for information provided, or for any recommendations made by your Investment Manager with respect to your Account. • Endorse, recommend or otherwise suggest that your Investment Manager will make suitable investment decisions for you. • Undertake to investigate or monitor the suitability of your Investment Manager’s investment decisions. Merrill does not assume responsibility for your choice of Investment Manager and Strategy, the Investment Manager’s and Strategy’s investment performance, the Investment Manager’s adherence to your objectives and restrictions, the Investment Manager’s compliance with applicable laws or regulations, and/or other matters within your Investment Manager’s control. Similarly, we do not monitor transactions directed by the Investment Managers for compliance with any applicable restrictions or requirements, even where we execute the transactions. You always retain the final authority, obligation and responsibility for making your own determinations regarding the selection and retention of an Investment Manager as well as the monitoring of your Accounts. You also should understand that your Investment Manager has certain conflicts of interest, which we and our affiliates or your Financial Advisor may not be aware of and are under no obligation to investigate or disclose. We encourage you to speak with your Investment Manager to discuss any questions that you have about existing or potential conflicts of interest relating to your Investment Manager. We note that certain Investment Managers could be Related Managers and your ability to use Related Managers as part of MAS presents conflicts of interest for the Related Manager and us. We discuss these conflicts in the section entitled “Portfolio Manager Selection and Evaluation - Related Managers.” OPTION AND MARGIN STRATEGIES In certain circumstances, your Investment Manager may employ margin, write uncovered options and/or sell securities short (collectively, “Options and Margin Strategies”). As disclosed in the documentation relating to the use of margin in your Account you executed when opening your underlying securities account (“Margin Agreement”), if your Investment Manager uses margin to purchase securities, the collateral for the margin debt will be the assets in your Account and other accounts at Merrill. If the securities in a margin account decline in value, so does the value of the collateral supporting the margin loan, and, as a result we can take actions, such as issuing a margin call or selling securities or other assets maintained at Merrill in order to maintain the required equity in the Account. Overall, margin increases the risk of losses you would sustain, as compared to an unleveraged Account, in declining markets that negatively affect the value of securities bought on margin. You assume full responsibility for your Investment Manager using margin to buy securities. If you determine that you no longer want your Investment Manager to use margin in your Account, you are responsible for notifying your Investment Manager of such determination. We are not responsible for any losses resulting from your Investment Manager’s failure or delay in implementing such instructions. You may also discontinue use of margin in your Account according to the terms of the Margin Agreement. If you terminate the Margin Agreement, you are responsible for notifying your Investment Manager of such termination. We are not responsible for notifying your Investment Manager of the termination of the Margin Agreement or for any losses resulting from your failure to so notify your Investment Manager. In certain circumstances, your Investment Manager may write uncovered options and sell stock short in your Account. If you permit your Investment Manager to write uncovered options, you will be exposed to potentially significant losses. For a call option, if the value of the underlying instrument increases above the exercise price, you can incur large and unlimited losses until the option expires or other contract remedies are pursued. For a put option, you bear the risk of loss if the value of the underlying instrument declines 5 MAS2A 0325Merrill Lynch Managed Account Service Brochure below the exercise price. If your Investment Manager writes combination or straddle options (where your Investment Manager writes both a put and a call option on the same underlying instrument), your potential risk of loss is unlimited. Further, if a secondary market in options were to become unavailable, your Investment Manager could not engage in a closing transaction and you would remain obligated until expiration or assignment. To engage in options transactions, you need to execute an option account agreement with Merrill and, under the terms of that agreement, if you do not meet applicable margin payment requirements, we may liquidate stock, options or other account positions in your Account, with little or no prior notice to you. Selling stock short raises similar risks as writing uncovered call options and you will assume similar risks of loss. The costs, risks and other features and conditions of margin and short sales are more fully described in the Margin Agreement. REASONABLE INVESTMENT RESTRICTIONS You may impose reasonable investment restrictions on your Accounts, but you must communicate such restrictions directly to your Investment Manager. It is your responsibility to monitor such investment restrictions, review such investment restrictions with your Investment Manager, and advise the Investment Manager of any discrepancies or modifications to such restrictions. You should understand that your Investment Manager, not Merrill, will be responsible for complying with your restrictions, if any, and we and your Financial Advisor shall not be responsible for communicating, implementing, or monitoring your restrictions. If you have selected to restrict investments in your Account, you accept any effect such restrictions may have on the investment performance and/or diversification of the Account. FUNDING AND OPERATION OF MAS ACCOUNTS Funding Accounts. We will initiate MAS services for new Accounts after your execution of any required Account documentation, approvals and funding of the Account and expect such enrollment to occur promptly. Enrollment may be delayed or rejected if the account is underfunded or funded with ineligible assets. A Client request to enroll in the Program is not considered a market order due to the requirements for enrollment which includes funding as well as the administrative processing time needed to implement enrollment instructions. There is typically a short delay between Account inception and initial investment transactions. Until we initiate Program services with respect a new Account, your assets will be held in a brokerage account for which you will be solely responsible for making any investment decisions with respect to the assets. During such time, we will not act as an investment adviser with respect to the assets. Not all account types are eligible to enroll in the Program. You may fund your Account by depositing cash and/or securities acceptable to us. We may determine in our sole discretion that certain assets are ineligible for the Program or otherwise unacceptable. Failure to comply with a request to transfer such assets out of an Account enrolled in the Program will result in that Account’s termination from the Program. Upon enrollment in the Program, you acknowledge and direct that any “good-til-cancelled”, “good-til-date” or “day limit” orders for equity securities that have not been executed be cancelled. You should consider all relevant factors before you fund (either initially or otherwise) your Account with mutual fund shares or other securities, including that: • Your Investment Manager generally cannot purchase additional shares of any mutual fund in your Account (as described below), though your Investment Manager may sell them from your Account. • If you fund your Account with mutual fund shares, we will (except in certain limited circumstances) request that such shares be liquidated or transferred from your Account. If they are not liquidated or transferred within a limited period of time after being requested to do so, your Account will be removed from the Program. During the period that such contributed mutual fund shares are in your 6 MAS2A 0325Merrill Lynch Managed Account Service Brochure Account, we will consider such assets to be ineligible for the Program and, accordingly, they will not ultimately be subject to the MAS Fee. See “The MAS Fee-Calculation of Account Fees; Ineligible Assets” for more information. • In all cases, we will not exchange any mutual fund holdings in your Account to other share classes. Accordingly, you should not assume that these contributed mutual fund shares are the mutual fund share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. • You may have paid a front-end sales charge or may be subject to contingent deferred sales charges (“CDSC”) or redemption fees. Such sales charges and fees, if applicable, will remain your responsibility and will be in addition to your MAS Fee. Clients should understand that upon their account enrollment in MAS the following services will not be available for that Account: checks, Visa® debit cards, web bill pay, online client orders, and systematic withdrawal services such as Move Money®/funds transfer disbursements. Similarly, the enrollment of an Account in the Merrill Automated Investment Program (“AIPS”) will be suspended during your participation in MAS, except to the extent that you have authorized the automatic transfer of cash into the Account. Additional assets contributed through AIPS will be invested at your Investment Manager’s discretion. Withdrawals and Addition of Assets in MAS Accounts. You are responsible for notifying your Investment Manager of any deposits made into your Account and instructing your Investment Manager to liquidate positions in the event you wish to withdraw assets from your Account. We have no responsibility to invest cash deposits (other than cash sweeps described below) or liquidate positions for withdrawal, tax purposes or for other situations, nor do we have responsibility for any losses that may result from your failure to notify your Investment Manager. Unless otherwise agreed, your Account will be credited with any dividends, interest and principal paid on assets held in your Account. Cash Balances and the Cash Sweep Program. At times, your Account will have an allocation to cash based on the Strategy selected, the asset allocation and investment determinations your Investment Manager has made. The cash allocation is held as a cash balance and/or invested in cash alternatives such as money market mutual funds (“money market funds”) as determined by the Investment Manager for the Strategy, which could be a Related Manager. The allocation can result from your Investment Manager’s decision to keep a cash balance for operational and/or investment purposes as part of the investment strategy and is based on a number of factors, including the nature of the investment approach for the Strategy, the asset allocation, the investment determinations, rebalancings, market conditions, the Investment Manager’s cash management approach and market view and concerns. In certain circumstances, including periods of volatile or uncertain market conditions, any such cash allocation will be higher based on, for example, concerns about the market or a decision to pursue a defensive investment strategy. Some types of Strategies include investments that take an extended period of time to purchase due to the type of security, market availability and selection criteria. Until invested, the cash for these investments is typically automatically swept under the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the Investment Manager as a temporary investment pending purchase of the individual security. Unless your Investment Manager directs that your Account’s cash allocation be invested in a cash alternative investment like a money market fund, your Account’s cash allocation will be treated as a cash balance in your Account. Any cash balances will automatically be “swept” with your consent in accordance with the terms of your underlying Merrill brokerage account agreement (the “Cash Sweep Program”). The available automatic cash sweep options under the Cash Sweep Program vary based on the Merrill account type and other criteria such as citizenship, residency status and jurisdictional restrictions. Not all Merrill account types have the same cash sweep option. Except as described below, the only automatic cash sweep options currently available for Merrill account types eligible for enrollment in the Program are the Merrill Lynch Bank Deposit Program (“MLBD Program”), the International Bank Variable Rate Deposit Facility (“IBVRD Facility”) for accounts of non-U.S. citizens who are not residents of the United States (U.S.), and the Retirement Asset Savings Program (“RASP”) for retirement accounts. The MLBD Program, IBVRD Facility 7 MAS2A 0325Merrill Lynch Managed Account Service Brochure and RASP provide for an automatic sweep of cash balances to bank deposits with BANA and other banks affiliated with us (“Bank Affiliates”). For certain qualified retirement plan account types, the accountholder selects either: (1) the MLBD Program; (2) the Insured Savings Account Program (“ISA”), a bank deposit program where cash is swept to our Bank Affiliates and unaffiliated participating banks (the “ISA Participating Banks”); and (3) certain money market funds. To view a list of the depository institutions currently participating in the ISA Program, visit www. ml.com/ISA. Certain other Merrill account types for qualified retirement plans have the automatic cash sweep option of a money market fund only. The trust management account type (“TMA”) over which BANA provides various investment and trust-related services has its own automatic sweep options which include bank deposits at Bank Affiliates, the ISA Program and certain money market funds. Please refer to your trust agreement and/or TMA Brochure for additional information regarding the automatic sweep options for a TMA Account. You can obtain a paper copy of these disclosures from your Financial Advisor. Please refer to your account agreement and related disclosures for additional information regarding the automatic sweep options for your type of account. The Sweep Program Guide for Merrill Clients, which can be found on mymerrill.com or is available from your Financial Advisor, provides an overview of the automatic cash sweep options and how they work and a chart of automatic cash sweep options by Merrill account type. The current rates and yields for the cash sweep options are available at mymerrill.com and from your Financial Advisor. “Bank Deposit” Sweep Option. Under the MLBD Program, RASP and the IBVRD Facility, an Account’s cash balance is swept to accounts held at our Bank Affiliates. Under the ISA Program, an Account’s cash balance is swept to accounts that are held at ISA Participating Banks. To view a list of the depository institutions currently participating in the ISA Program, visit www.ml.com/ISA. Under each of the MLBD Program, the IBVRD Facility, RASP and the ISA Program, Merrill as your agent establishes the bank deposit accounts on your behalf at the Bank Affiliate or the ISA Participating Bank as provided for in your underlying brokerage account agreements. Bank deposits in the MLBD Program, RASP and the ISA Program are insured by the Federal Deposit Insurance Corporation (“FDIC”). Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection programs. Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Certain conditions must be satisfied for deposit insurance coverage to apply when bank deposits are opened on your behalf in the name of Merrill as your agent. Merrill has in place business requirements and practices that are reasonably designed to satisfy those conditions, which include, but are not limited to, proper account titling and recordkeeping. The sweep deposit accounts at banks in the MLBD Program, RASP and the ISA Program are protected by FDIC insurance, up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership category, per bank. FDIC insurance covers both principal and credited interest, up to applicable limits. Any such deposits in the same account ownership category, whether directly, through other Merrill accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If your total cash balances in any type of deposit account (whether a direct bank deposit account or a sweep deposit account), and/or in any type of bank product (i.e., a brokered CD) of a Bank Affiliate in the MLBD Program or RASP or any ISA Participating Bank exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Neither Merrill nor the Bank Affiliates manage or monitor the deposits swept under the MLBD Program, the RASP or the ISA Program for FDIC insurance limit purposes. Deposits are not aggregated or limited under the MLBD Program, RASP and the ISA Program based on the FDIC limits for the same depositor in the same bank across Merrill accounts. Merrill does not undertake through MAS or the Client Agreement or under the underlying brokerage agreement to provide you notice that cash balances in your MAS Account or in any of your other brokerage accounts or investment advisory accounts exceeds the FDIC coverage limit for any of our Bank Affiliates or any other Participating Bank. Monitoring FDIC insurance coverage limits is expressly not a MAS program service. 8 MAS2A 0325Merrill Lynch Managed Account Service Brochure You are responsible for monitoring the total amount of deposits held at the Bank Affiliates and at any ISA Participating Bank in order to determine the extent of FDIC insurance. The agreements and disclosures that you received in connection with establishing your underlying Merrill brokerage account and the Sweep Program Guide for Merrill Clients include additional information about FDIC insurance. A paper copy can be obtained from your Financial Advisor. For additional information on FDIC insurance, visit fdic.gov. Cash balances swept under the MLBD Program and RASP to a bank deposit account of our Bank Affiliates will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts will be periodically set and reset by the Bank Affiliates in their discretion. The rate is variable and may change at any time after the account is opened without notice or limit. Under the MLBD Program and RASP, interest rates are tiered based upon a client’s relationship with Merrill. Accounts with the MLBD Program and RASP as their Cash Sweep Program that are enrolled in MAS Accounts and in other specified Merrill investment advisory programs receive the highest tier rate available under the MLBD Program or RASP. A brokerage account with one of these sweep options that enrolls in MAS will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. There is no interest rate tiering offered under the IBVRD Facility. Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection and receive a lower rate than the highest rate available under the MLBD Program or RASP. The interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. “Money Market Fund” Sweep Option for Certain Account Types. Under account agreements covering certain retirement accounts and TMAs where the account holder has selected the money market fund option for the cash sweep, please note these money market funds have certain internal expenses and costs and also include a 0.40% asset-based administration fee per annum that is paid to Merrill. Merrill rebates the amount of the asset-based administration fee it receives to the clients of these Retirement Accounts with this sweep option. The amount of such rebate may be less than this 0.40% fee in certain rate environments where the fund manager waives or reduces the amount of such fee in order to avoid a negative return on the money market fund. You will bear your proportionate share of such money market fund’s fees and expenses including, but not limited to, management fees paid to the fund’s investment manager or its Affiliates, fees payable to the fund’s professional and other service providers, transaction costs and other operating costs. The MAS Fee does not cover or offset any fees and expenses that the money market fund incurs for transactions occurring within the fund itself. Please consult the prospectuses and offering material for the sweep money market funds for more detailed information on the amounts charged. “No Sweep” Option. Certain account types have the option to select the “No Sweep” option under their underlying brokerage agreement which results in cash being held in the Account as a cash balance and not ‘swept’ to any available sweep option under the Cash Sweep Program. The cash balance will not earn interest or dividends. The cash held in the Account will be covered by the Securities Investor Protection Corporation (SIPC) up to $500,000 per client, inclusive of $250,000 for cash. As a registered broker-dealer, Merrill benefits from the possession or use of cash balances, also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. Conflicts of Interest related to the Sweep Program. We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See “Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates” and the section “Participation or Interest in Client Transactions—Cash Balances and the Cash Sweep Program.” 9 MAS2A 0325Merrill Lynch Managed Account Service Brochure Cash Held with Custodian other than MLPF&S. Cash held with a custodian other than MLPF&S is not covered by the Cash Sweep Program and will not be subject to its cash sweep arrangements. You are responsible for separately establishing appropriate sweep arrangements with any such custodian. We will include the cash positions in your Account are included in the value of your Program assets for the calculation of the MAS Fee. Assets held in Accounts with a custodian other than MLPF&S are not subject to Merrill’s SIPC coverage. Closing an Account and/or Terminating the Client Agreement. The Client Agreement may be terminated at the direction of you or us as described in the agreement. The termination of the Agreement will terminate the Account enrollment in the Program. Termination of the Client Agreement will not generally affect or preclude the consummation of any transaction previously initiated for the Account and the completion of other processes that may be required to terminate the Account. Termination of your Account will be effective following the completion of processes that may be required to terminate the Account, including any required liquidations. We will not be responsible for market fluctuations in your Account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient liquidation of an Account include, but are not limited to, size and types of securities, liquidity of the markets and market- makers’ abilities. Due to the administrative processing time needed to terminate an Account, termination requests cannot be considered market orders. It could take up to several business days under normal market conditions to process your request. Termination of the Client Agreement is separate from, and will have no automatic effect on, any agreement entered into between you and your selected Investment Manager(s). You have the responsibility to notify your Investment Manager of your decision to terminate the Client Agreement or terminate your agreement with your Investment Manager. You further understand that neither Merrill nor your Financial Advisor is responsible for notifying your Investment Manager of your decision to terminate the MAS Account or your agreement with your Investment Manager. Other than as may be set forth in the Client Agreement, neither Merrill nor your Financial Advisor shall be responsible for any losses incurred by you as a result of your failure to notify the Financial Advisor of the termination of your agreement with the Investment Manager. Upon termination, we will refund any prepaid MAS Fee on a pro rata basis as specified in the Client Agreement or as required by law. The termination of your Financial Advisor’s employment with Merrill will not automatically terminate the Client Agreement. In the event that your Financial Advisor is no longer able to service your Account, Merrill may reassign that Account to a different Financial Advisor, and you will be notified of any such change. Rules for Cash Accounts and Margin Transactions. As a broker-dealer, Merrill is responsible for compliance with federal margin rules. When an Account enrolls in the Program, the Account will be designated as a cash Account irrespective of whether or not the accountholder had selected that margin apply to the underlying securities account. This account notation means that margin is not permitted and purchase of securities must be fully paid for on the date of the trade. With a cash Account, if securities are sold before the payment for their purchase has settled, an event known as a “free-riding violation” has occurred. Free-riding is prohibited under margin rules and our Program guidelines. Having a “free-riding” violation may result in your Account being restricted for 90 days or “frozen.” The imposition of such a freeze could have a negative effect on your Account and performance. The risk of engaging in an inadvertent “free-riding” violation and therefore freezing of your Account is enhanced (1) when you change Investment Managers and reconstitute your investments; (2) when you engage in periodic rebalancing (which results in purchases and sales of securities over a short period of time); or (3) when you withdraw cash from your Account when there is a pending order to purchase a security. If an Options and Margin Strategy is selected for the Account, margin will be specifically permitted and the account designation will change to that of a margin account. Loans and Collateral. Certain of your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through loan programs (“Lending Programs”), including those of Affiliates of Merrill such as the securities based lending Loan Management Account® (“LMA”) and Mortgage 100®/ 10 MAS2A 0325Merrill Lynch Managed Account Service Brochure Parent Power® mortgage programs. The terms and conditions applicable to the Lending Program are governed by the applicable loan documents and other service agreements and are not included or described further in this Brochure. You should review carefully the terms, conditions and any related risk disclosures for such Lending Program. The risks of pledging the assets in an Account in a Lending Program will be heightened in the event you pledge your Account or if your pledged Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. The lender has the right to protect its own commercial interests and to take actions that adversely affect the management of your Account and related performance. Regardless of whether the lender is Merrill, an Affiliate or a third-party lender, the lender’s lien is senior to any rights we may have on the assets in the Account. As such, the lender has the right to sell securities in the Account that serve as collateral, if needed. A collateral call could disrupt your selected Investment Manager’s investment strategy for the Account and, furthermore, neither you, we or the Investment Manager will be provided with prior notice of a liquidation of securities or transfer of interests in your pledged Account. Furthermore, neither you nor we are entitled to choose the securities which are to be liquidated or transferred by the lender. The costs associated with such a lending arrangement under a Lending Program are not included in the MAS Fee and, if the Lending Program is with an Affiliate, result in additional compensation to us, our Affiliate(s) and our Financial Advisors. The interest charges on any such margin loan or loan combined with the fees charged for Program Services may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. You should consult with your own independent tax advisor in order to fully understand the tax implications associated with pledging your Account as loan collateral and the potential liquidation of pledged assets. CUSTODIAL ARRANGEMENTS Generally, Merrill will act as the custodian for the assets held in your Account. Assets will be maintained in one or more central asset accounts established at Merrill through the applicable securities account. Pursuant to the Client Agreement, you have agreed to execute the applicable documentation for such accounts. In limited circumstances, upon your request and direction and with our consent, you may enter into arrangements for your assets in the Program to be maintained with (1) an Affiliated Custodian or (2) an Unrelated Custodian. Unless otherwise agreed with such custodian, you will pay a separate fee for these arrangements on terms agreed upon by you with such custodian. Our rights and authority respecting your assets enrolled in the Program, including as to transfers of assets held with the Affiliated Custodian or the Unrelated Custodian, are limited to those set forth in the Client Agreement, regardless of any separate agreements or arrangements you may have or may enter into with any such Custodian. We disclaim any broader rights that may be contained in your separate agreement with the Affiliated Custodian or Unrelated Custodian. You will be responsible for all fees and expenses charged by an Affiliated Custodian or an Unrelated Custodian subject to applicable law and the custodial arrangements you agree to. These fees and expenses are not covered by the MAS Fee. Cash held with an Affiliated Custodian or an Unrelated Custodian will not be subject to the same sweep arrangements you have with Merrill acting as the custodian, but we will include such cash positions in the value of your Account for the calculation of the MAS Fee. You are responsible for separately establishing appropriate sweep arrangements with the Affiliated Custodian or Unrelated Custodian. Assets held in Accounts with an Affiliated Custodian and the Unrelated Custodian are not subject to Merrill’s SIPC coverage. It is the responsibility of the Affiliated Custodian or an Unrelated Custodian to implement your proxy delivery instructions. Accounts that are custodied with an Affiliated Custodian or an Unrelated Custodian are not eligible to elect periodic trade confirmation delivery. You will be responsible for ensuring that we (and all vendors used by us) are provided with daily access to the Affiliated Custodian or Unrelated Custodian’s systems, transaction and account data and other information 11 MAS2A 0325Merrill Lynch Managed Account Service Brochure necessary to provide adequate account supervision, transaction, billing and other client reports and other necessary services to your Account. You understand that as a result of your use of a custodian other than Merrill, you may receive more limited information and reporting when we cannot obtain certain required information from the Affiliated Custodian or Unrelated Custodian. Furthermore, any performance and other reports we provide for your Account will be based upon information provided by the Affiliated Custodian or Unrelated Custodian, which we will use for purposes of calculating the MAS Fee. We are not responsible for verifying the accuracy of such information or any losses or errors by an Affiliated Custodian or Unrelated Custodian with respect to your Account. You have agreed to promptly notify your Investment Manager with respect to any additions or withdrawals of assets to your Account maintained at the Affiliated Custodian or Unrelated Custodian and have agreed that we will not be responsible or liable for any losses due to your failure to provide such prompt notification. Any assets held in your Account must be free from any lien, charge or other encumbrance (other than a lien, charge or other encumbrance in favor of us or our Affiliates). Such assets must remain so, unless you notify us and we agree. You must notify us in writing prior to effecting loans secured by securities in your Account (including loans by our Affiliates) as described below (commonly referred to as “collateralizing”). You understand that we will not provide advice on or oversee any of your collateral arrangements. In the event of any conflict between the terms of the Client Agreement and your collateral arrangements, the terms of the Client Agreement will prevail. You must also disclose to any lender the terms of the Client Agreement. No specific securities in your Account must be held as collateral to secure your loan. You should be aware of the adverse effects of collateralizing Accounts, including, but not limited to, the fact that the lending institution may require additional collateral or liquidation of securities held in your Account to meet a call, as well as the related tax consequences. You must promptly notify us of any default or similar event under your collateral arrangements as defined in the respective collateral arrangements. TRADING IN MAS ACCOUNTS Your trades are generally placed by, and are the responsibility of, your chosen Investment Manager, including any Related Manager. By executing an agreement with the Investment Manager and by executing the Client Agreement, you have granted the discretionary authority to the Investment Manager to determine (subject to your investment objectives and constraints) the securities to be bought or sold on your behalf, the amount of such securities, and the brokers or dealers to be used in such transactions. The Investment Manager you select is obligated, absent your direction to the contrary, to effect transactions with or through those brokers or dealers that, in the Investment Manager’s view, are capable of providing best price and execution of orders for your benefit. The Investment Manager has the authority to place orders for transactions with broker-dealers that it selects, including with Merrill or any of our Affiliates that act as a trade counterparty (an “Affiliated Trade Counterparty”) and with broker dealers that are not Merrill or one of its Affiliates (“Unaffiliated Trade Counterparty”). The Investment Manager is able to transact with Merrill or an Affiliated Trade Counterparty on a principal basis when permitted by law. They may place trades for purchases of securities in underwritten offerings with Merrill or any of our Affiliates or with an Unaffiliated Trade Counterparty under which certain underwriting compensation is earned by Merrill, BofAS or any of our other Affiliates or by the Unaffiliated Trade Counterparty. When these transactions are effected on a principal basis, we will receive additional compensation. When an Investment Manager places a trade order with Merrill or an Affiliated Trade Counterparty for the purchase or sale of fixed income or other securities where dealer spread charges are imposed, the dealer spread charges (that are part of the net price of the security) will be in addition to your MAS Fee. These dealer spread charges will not be listed in your trade confirmation or account statement; however, upon written request, we will undertake to obtain the amount of these charges for a given transaction in your Account. If the Investment Manager determines to execute a purchase or sale of any security for your Account through an Unaffiliated Trade Counterparty, any resulting execution charges (i.e., commissions, markups, markdowns, dealer spread charges) will be separately charged to that Account. A transaction that the Investment Manager 12 MAS2A 0325Merrill Lynch Managed Account Service Brochure has placed through an Unaffiliated Trade Counterparty for a particular Investment Manager Strategy is commonly referred to as a “step out” or “step out trade.” In selecting a firm to execute transactions and the markets in which the transactions will be executed, the Investment Manager is not obligated to solicit competitive bids for each transaction or seek the lowest available commission cost to you, so long as it reasonably believes that the firm it selects can be expected to obtain a “best execution” market price on the particular “step out trade.” Each Investment Manager is responsible for ensuring that it complies with its own best execution obligations. Certain Investment Managers have historically executed all or a portion of their trades as “step outs.” Frequently, these trades have been for fixed income or other securities for which trading-related charges and costs (e.g., mark-up/downs, dealer spreads) are charged by the executing broker-dealer. These trading- related charges and costs are included in the net price of the security and are charges and costs that are in addition to your MAS Fee. You, rather than Merrill or the Investment Manager, will bear the cost of these trading-related charges and costs. See information in the section “Other Fees and Expenses.” In addition, these trading-related charges and costs will not be reflected as separate charges on your trade confirmations or account statements. We will undertake, at your written request, to obtain the amount of this remuneration for a given transaction in your Account. Investment Manager Strategies that we have identified as trading through an Unaffiliated Trade Counterparty, either on a regular or limited basis, are designated in the “MAS Investment Manager Strategy Step Out Information Document.” This document is available at ml.com/SMA and is available upon request from your Financial Advisor. Information in this document is based solely on historical information that has been provided by the Investment Managers at their discretion and we have not independently verified such information. We do not make any representation regarding the future trading practices of any Investment Manager for any Investment Manager Strategy. We recommend that before selecting an Investment Manager Strategy, you review the Manager’s Form ADV, Part 2A brochure, which contains more detailed information about its brokerage practices. You should consider the costs of “step out trades.” You will pay a MAS Manager Fee for the investment management and related services that the Investment Manager for the Strategy provides. The rates charged by Investment Managers vary among each other and among other Strategies. For trades in fixed income securities, whether executed as a “step out trade” or a trade with an Affiliated Trade Counterparty, you will pay the dealer spread charges associated with such trade. It is possible that the MAS Manager Fee rates for Strategies may be higher than other available Strategies. You could be deemed to be indirectly bearing the cost of the “step out trades” by virtue of any such higher charges. In addition, you will pay the same fee rate for a particular Strategy regardless of whether or not the Investment Manager executes “step out trades.” You should consider the use by the Investment Manager in executing “step out trades” when selecting a Strategy. The potential cost advantage associated with using Merrill to execute trades for your Account is expected to alter the way in which each Investment Manager satisfies its duty to seek best execution. That said, Investment Managers may utilize execution services of broker-dealers other than Merrill. In particular, BANA, a Related Manager, will select broker-dealers other than Merrill and the resulting transaction costs will be in addition to the MAS Fee. We and our Affiliates will ordinarily act as agent in executing transactions on behalf of Accounts. Principal transactions may also be effected for MAS Accounts under the appropriate circumstances as permitted by law. Principal transactions may be subject to a dealer spread (i.e., the difference between the bid and the offer price), which would result in additional compensation or other benefit to us. Transactions in securities customarily traded in dealer markets (such as fixed-income or over-the-counter securities) that are purchased from or sold to broker-dealers other than us may include markups or markdowns by these firms. In accordance with the instructions of your Investment Manager and your authorization, our execution services (or those of an affiliated broker-dealer) will generally be used for the purchase and sale of securities for a MAS Account, unless you designate another broker-dealer or applicable law is to the contrary. However, in buying or selling certain securities (particularly those that customarily trade in “dealer markets”), we may, 13 MAS2A 0325Merrill Lynch Managed Account Service Brochure for legal or other reasons, cause such transactions to be effected through an Unaffiliated Trade Counterparty. When we select an Unaffiliated Trade Counterparty to execute transactions, we will consider various factors, such as the nature and quantity of the securities involved; the markets involved; the importance of speed, efficiency and confidentiality; the firm’s apparent knowledge of such markets and sources from or to whom particular securities might be purchased or sold; the reputation and perceived soundness of the broker- dealer; the ability and willingness of the broker-dealer to facilitate both purchases and sales of securities for client accounts by participating in such transactions for its own account; the firm’s clearance and settlement capabilities; and other factors relevant to the selection of a broker-dealer for the execution of your securities transactions. The MAS Fee does not cover transaction charges or other charges, including markups and markdowns, resulting from trades effected through us or with an Unaffiliated Trade Counterparty. In addition, the MAS Fee does not cover transaction and other charges incurred by registered and unregistered investment companies, including mutual funds, money market mutual funds, closed-end funds, ETFs and hedge funds, real estate investment trusts and other pooled investment vehicles (“Funds”) that might be held by you in MAS Accounts or that the Investment Manager may invest in. Purchases of securities from an underwriter or dealer in a distribution will be effected at the public offering price. Your transactions are effected by us on the instruction of your selected Investment Manager. Accordingly, it should be understood that, for any and all transactions effected by or through us in an MAS Account at the direction of your Investment Manager, we are acting exclusively as a broker-dealer in relation to such transactions. We and the Investment Managers may, but are not required to, aggregate orders for the sale or purchase of securities for your Account with orders for the same security for our other clients, proprietary accounts, or the accounts of our employees and/or related persons, without your prior authorization. In such cases, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro rata share of any fees. For foreign ordinary security transactions executed outside the U.S., we may use the services of a foreign Unaffiliated Trade Counterparty (or its affiliate). The foreign Unaffiliated Trade Counterparty (or its affiliate) will handle the order and will assess trading-related charges and costs (i.e., commissions, mark- ups/downs, dealer spreads and other fees and charges) and, to the extent a foreign currency conversion transaction is required, it will be remunerated in the form of a dealer spread or a mark-up/down. These trading-related and currency conversion-related charges and costs are included in the net price of the security and are charges and costs that are in addition to your MAS Fee. In addition, these charges and costs will not be reflected as separate charges on your trade confirmations or account statements. We will undertake, at your written request, to obtain the amount of this remuneration for a given transaction in your Account. We and our Affiliates may effect agency-cross transactions in which we or one of our Affiliates acts as agent for the parties on both sides of the transactions involving MAS or other clients in accordance with applicable law. When effecting such crossing transactions, we or our Affiliates generally receive compensation (the amount of which varies) from each party to such transactions, which is in addition to the fees described herein. While such compensation, in theory, creates a conflicting division of loyalties and responsibilities, transactions involving MAS are directed by your Investment Manager, (which could be a Related Manager) and we will be acting solely as a broker-dealer in connection with such trades. In the event an error occurs in the handling of client transactions that is a result of any transaction effected by us or our Affiliates, we seek to identify and correct any errors as promptly as possible without disadvantaging the client. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the client. In general, in instances where we are responsible for effecting the transaction incorrectly, we may: (i) reimburse clients for any losses directly resulting from trade errors; (ii) credit to the client any profits directly resulting from such trade errors that are corrected after the settlement of the transaction; or (iii) retain for ourselves any profits directly resulting from such trade errors that are corrected prior to the settlement of the transaction. 14 MAS2A 0325Merrill Lynch Managed Account Service Brochure PROXY VOTING AND OTHER LEGAL MATTERS Unless otherwise designated in the Client Agreement or other writing addressed to us (or another custodian you select), you direct your Investment Manager for your Account to vote the proxies and receive other issuer-related material relating to the securities held in your Account, and you represent in the Client Agreement that, under any applicable instruments or governing law, you are authorized to make such direction. To the extent that we are the custodian and voting instructions are not received, and as permitted by applicable law, we will comply with the rules and policies of the SEC and applicable self-regulatory organizations, consistent with our role as a non-discretionary custodian. As a broker-dealer, we use a third- party service provider for certain proxy-related functions, including processing and forwarding proxy and other issuer-related materials, and receive amounts collected by the vendor for the costs of these services as permitted by applicable securities regulation. In addition, we do not advise or act for you regarding any legal matters, including bankruptcies and class actions, pertaining to the securities held in your Account, nor will we be responsible for making any tax credit or similar claim or any legal filing (including, but not limited to proofs of claim) on your behalf. Unless otherwise agreed, we will send you any documents we receive for client distribution with regard to such matters. The Investment Manager is responsible for responding to corporate actions. THE MAS FEE We have set the maximum MAS Fee rate schedule for the Program as set forth below. The MAS Fee rate schedule is subject to change. The MAS Fee rate is negotiable meaning you and your Financial Advisor may agree to a MAS Fee rate for an Account that is lower than the maximum rates listed in the schedule below. The extent to which you and your Financial Advisor agree to a lower rate is solely within your and your Financial Advisor’s discretion and is subject to our policies regarding the Program. You may accept or decline any proposed rate by your Financial Advisor as part of the negotiation process. Dollar Value of Assets in Each MAS Account Annual Equity/ Balanced/ Convertible/ REIT Maximum Fee Schedule Annual Fixed Income Maximum Fee Schedule Up to $1 million 1.80% 0.65% $1,000,000– 1,999,999 1.35% 0.65% $2,000,000 – 4,999,999 1.35% 0.50% $5,000,000 – 9,999,999 1.00% 0.45% $10 million or greater Determined by Mutual Agreement Determined by Mutual Agreement For purposes of determining which maximum MAS Fee Rate applies to your Account, we will consider the aggregate value and composition of assets in your Account and in certain other of your Merrill accounts and those of your household. The MAS Fee rate that is applicable to your Account is the rate agreed upon between you and your Financial Advisor (the “MAS Fee Rate”). The MAS Fee is based on the dollar value of assets in the Account and the agreed upon MAS Fee Rate. The MAS Fee Rate applicable to an Account will not change during a calendar quarter, and any decrease in the MAS Fee Rate will take effect at the beginning of the next calendar quarter. Note that the MAS Fee does not cover the services of the Investment Manager for the Strategy in the Account. Merrill compensates your Financial Advisor on an ongoing basis derived from the MAS Fee Rate that applies to your Account. When considering whether to offer or agree to charge a lower MAS Fee Rate, a Financial Advisor typically will consider a number of factors, including the type and size of your Account, the breadth of our relationship with you, your engagement with the Financial Advisor, competitive considerations and how Merrill compensates the Financial Advisor. Because the amount of compensation paid to your Financial 15 MAS2A 0325Merrill Lynch Managed Account Service Brochure Advisor is based on the MAS Fee Rate for your Account, your Financial Advisor has a financial interest in that Rate. In general, Financial Advisors receive “production credits” toward their compensation formula based on the amount of the MAS Fee that you pay for your Account. Merrill’s policies result in Financial Advisors receiving fewer production credits if the weighted average of the MAS Fee Rates for your and your designated household members’ Accounts is lower than the rate levels for specific wealth asset tiers that Merrill establishes. Merrill and Financial Advisors have a conflict of interest based on this structure because the Financial Advisor is incentivized not to offer a MAS Fee Rate below such rate levels since that would reduce their compensation earned. For more information on Financial Advisor compensation and conflicts of interest, see “Compensation, Conflicts of Interest and Material Relationships—Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel—Financial Advisor Compensation and Awards.” Merrill typically pays a portion of the MAS Fee it receives from each client to the Financial Advisor for that client. The exact portion paid by Merrill to the Financial Advisor varies among the Financial Advisors and depends on factors such as each Financial Advisor’s overall annual revenue production. The amount received by a Financial Advisor as a result of a client’s participation in this Program may be more than the Financial Advisor would receive if the client participated in certain other of our investment advisory programs, or paid separately for investment advice, brokerage and other services covered by the MAS Fee. In those circumstances, the Financial Advisor has an incentive to recommend an investment advisory program that would pay higher compensation. We offer similar programs and/or investment strategies in different sales channels and at different fee levels. The MAS Fee paid by a client may be higher or lower than the fees other clients pay in the Program or another investment advisory program and/or the cost of similar services offered through other financial firms. See “Ability to Obtain Certain Services Separately and for Different Fees.” The full amount of the MAS Fee payable under the Client Agreement will be charged in accordance with the terms of the Client Agreement, regardless of the amount of transactions your Investment Manager chooses to effect in your Account. The MAS Fee will not be adjusted for your use of, or failure to use, the MAS services, including (1) the level of trade activity; (2) your choice of a Strategy where the Investment Manager engages in trading activity away from us for certain security types; (3) your decision to custody your assets at a financial institution other than Merrill. You should note that any security purchased prior to enrolling in MAS and subsequently transferred into a MAS Account will be subject to the MAS Fee. This means that you may pay both an up-front commission (when the security was purchased prior to enrolling in MAS) as well as the MAS Fee (once enrolled in MAS) in connection with the purchase of the same security on the transferred security. Upon request, and at no charge, we will provide additional detailed information regarding your MAS Fee. Please contact your Financial Advisor if you would like to receive this more detailed MAS Fee information. Investment Manager Fee. You will be charged the advisory fee that you have agreed to pay the Investment Manager (“Investment Manager Fee”) for the Strategy you select. The Investment Manager Fee will vary depending on the Strategy. Calculation of Account Fees. The MAS Fee is payable quarterly in advance, on all assets in your Account (including assets held by an Affiliated Custodian or Unrelated Custodian and assets purchased on margin or other extensions of credit by us or our Affiliates). The MAS Fee is based on the estimated value of your Account’s assets as of the last business day of the previous calendar quarter, as determined by us or another custodian holding such assets. Merrill will use a variety of pricing sources in calculating the value of such assets in your Account, including Affiliates. All assets (including cash balances swept under the Cash Sweep Program to a deposit account or a sweep money market fund, depending on your account type, and any cash alternatives including money market funds selected by your Investment Manager) are included in the value of your Account for the calculation of the MAS Fee, unless we have deemed that any assets are ineligible for the Program, in which case, such assets would not ultimately be subject to the MAS Fee. 16 MAS2A 0325Merrill Lynch Managed Account Service Brochure Depending on when such ineligible assets are contributed to, or liquidated or transferred from, the Account, such assets will be either: (i) excluded from the value of your Account for the calculation of the MAS Fee; or (ii) included in the Account’s value for that calculation but you will receive a subsequent adjustment for any MAS Fees charged for holding those ineligible assets. In addition, any money market funds that are not held through any relevant cash sweep vehicle applicable to your Account or invested in by the Investment Manager as part of its strategy are considered ineligible assets, and, therefore, are not ultimately subject to the MAS Fee are considered ineligible assets, and, therefore, are not ultimately subject to the MAS Fee and could subject your Account to termination if not timely liquidated or transferred out of your Account. For the avoidance of doubt, any money market funds that are held through any cash sweep vehicle applicable to your Account, are eligible assets and, therefore, are subject to the MAS Fee. In certain limited circumstances, where an Investment Manager purchases or holds contributed mutual fund shares (whether money market funds or otherwise) in your Account as part of its Strategy, such shares would be subject to the MAS Fee. The MAS Fee for your accounts does not cover the services of Investment Managers, and while Merrill may not consider all Account assets for purposes of your MAS Fee, your Investment Manager may do so for its fee. For the initial quarter, the MAS Fee is calculated proportionally based upon the number of days left in such quarter from the date our MAS advisory relationship begins, which occurs on the later of the date of acceptance of the signed Client Agreement by us or the date you have contributed assets in the Account. The initial MAS Fee is based on the estimated value of the Account as of the close of business on the day preceding notification to the Investment Manager to begin managing the MAS Account. You may elect to have the MAS Fee paid by debit from the MAS Account, debit from an alternate Merrill account, or through the payment of an invoice. No MAS Fee adjustment will be made for contributions or partial withdrawals, or for Account appreciation or depreciation, within a billing period. The account value used for the calculation of fees may differ from that shown on your monthly securities account statement and performance report due to a variety of factors, including trade date or settlement date accounting, the treatment of accrued income, round lot valuation and other considerations. Further, it should be noted that the valuation of client securities reported in the performance report may also be subject to occasional re-pricing in reasonable and appropriate circumstances, but such re-pricing will not affect, or result in the adjustment of, previously calculated MAS Fees. Deduction of Account Fees. As set forth in the Client Agreement, you may authorize us to deduct the MAS Fee from your Account. We also may, for your convenience and if so agreed between you and your Investment Manager, deduct from your Account the Investment Manager Fee. We will remit your Investment Manager Fee to your Investment Manager. The Investment Manager Fee will be deducted in addition to, but after, the MAS Fee payable to Merrill. You may also directly remit your Investment Manager Fee to your Investment Manager. To the extent permitted by law, all assets in your Account or other assets held by Merrill or any Affiliate for you will be subject to a lien for the discharge of your obligation to make timely payment to us, and we may sell assets in your Account to satisfy this lien. Other Fees and Expenses. We want you to know that the MAS Fee does not cover: • Investment Management fees you pay to your selected Investment Manager (and set by such manager). • Transaction charges (i.e., commissions, sales charges, markups, markdowns) on trades effected through or with an Unaffiliated Trade Counterparty (including on fixed-income or over-the-counter transactions in which we act as agent). • Dealer spread charges, markups or markdowns charged by an Unaffiliated Trade Counterparty (including on fixed-income or over-the-counter transactions in which we act as agent). • Dealer spread charges, markups and markdowns imposed by Affiliated Trade Counterparty for purchase and sale of fixed income securities and other securities where a dealer spread charge is imposed. 17 MAS2A 0325Merrill Lynch Managed Account Service Brochure • Underwriting discounts, selling concessions or other transaction charges with respect to any new issue securities offering that we or our Affiliate may receive in connection with the offering, a portion of which may be used to pay your financial advisor. • Margin interest and fees and charges, charged by us or third parties, imposed for any margin strategy or for any securities that are shorted as part of an options strategy and that are in limited supply (i.e., the shorted securities are “in demand”), a portion of which may be used to pay your Financial Advisor. • Transfer taxes. • Fees charged by us, our affiliates or unaffiliated third parties in connection with short-sale transactions. • Fees, expenses and charges charged by Funds or by the managers or sponsors of Funds. Exchange, alternative trading system fees, required SEC fees or similar fees charged by third parties, including issuers. • Electronic fund, wire and other account transfer fees, including any fees or markups charged for foreign currency exchange or conversions relating to transfers or wires to or from your Account, a portion of which may be used to compensate your Financial Advisor. • Custodial fees and expenses associated with your use of an Affiliated Custodian or an Unrelated Custodian. • Commissions and charges for transactions in foreign ordinary securities and dealer spread charges, mark-ups or mark-downs in connection with foreign currency conversions, including transactions in foreign ordinary shares or ADRs or foreign currency wire transfers either in or out of your Account. • Any other charges imposed by law or otherwise agreed to with regard to your Account including those charges payable to Merrill and/or third parties as described in this Brochure. The MAS Fee does not include certain fees and charges relating to transfer and termination fees, cash management services, money transfers, wire transfers and foreign exchange conversion fees and costs and certain corporate action fees. Certain of these costs are detailed on the Merrill Schedule of Miscellaneous Account and Service Fees and the Explanation of Fees document (as to foreign conversion costs), available at ml.com/relationships. Please see the securities account agreement and account enrollment documents relating to brokerage services and related transactions and account fees for your Merrill account. If you have any questions about any charges or fees applicable to your Account, please consult with your Financial Advisor. If your MAS Account holds a Fund security or the Strategy invests in a money market fund, as with any Fund investment, you will bear your proportionate share of such Fund’s fees and expenses including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. In addition, any Fund contingent deferred sales charge, redemption or other fees imposed by a Fund manager as a result of your redeeming the Fund (e.g., to invest in a particular Program Strategy) will be separate from, and in addition to, the MAS Fee. The MAS Fee does not cover or offset any fees and expenses that any Fund incurs for transactions occurring within the Fund itself, including commissions and other transaction-related charges incurred by the Fund, even if we or any Affiliate effect these transactions for the Fund or provide services to the Fund. All of these fees and costs may be material. If your Investment Manager determines to execute a purchase or sale of any security for your Account through a broker or dealer other than us, any resulting execution charges will be separately charged to your Account and are in addition to the MAS Fee. As noted above, on trades effected through or with us by the Investment Manager, we will not charge a commission on agency transactions. Principal transactions effected with us, as permitted by law, will be subject to a dealer spread (i.e., the difference between the bid and the offer price), which results in additional compensation or other benefit to us. The MAS Fee does not cover charges (generally the dealer spread) imposed by an Unaffiliated Trade Counterparty on step out trades as dealers, including where MLPF&S or its Affiliates act as agent in 18 MAS2A 0325Merrill Lynch Managed Account Service Brochure executing fixed income or over-the-counter transactions. Clients for which an Investment Manager places any fixed income, foreign or securities trades on an over-the-counter basis through an Unaffiliated Trade Counterparty will not receive a discount from, or credit against, the MAS Fee for any markup or mark-down imposed by the executing Unaffiliated Trade Counterparty. Neither the MAS Fee nor the Investment Manager Fee covers these transaction execution costs. See “Trading in MAS Accounts” for more information on step out trades. Please note that a security that has been purchased in a brokerage or other account at Merrill or its Affiliate or at another investment firm and is moved into MAS, including those purchased in an initial public offering or any primary or secondary new issue offering, will become subject to the MAS Fee immediately. For such purchases, you will have paid an up-front commission or transaction charge and upon transfer to MAS you will pay the MAS Fee once the security is held in an Account enrolled in MAS. This means we and your Financial Advisor receive compensation in the form of sales commissions as well as from the ongoing MAS Fee once the security is transferred to an Account. Options and Margin Strategies. MAS Accounts are generally not permitted to effect margin transactions. However, when so permitted, the margin interest you pay on debit balances is not included in the MAS Fee. Financial Advisors will receive additional compensation in such circumstances, unless waived, as well as, in limited cases, from rights or tender offers. If your Investment Manager utilizes Options and Margin Strategies, you will incur costs in addition to the MAS Fee. Although you will be paid interest on the short market value of any securities sold short in your Account, Merrill will also benefit from these short sale positions. The rate of interest paid to you will be determined by Merrill in our sole discretion and will reflect the retention of compensation by us. In addition, you will be charged fees, as reflected on your Account statements, for any securities we deem to be “in demand” either at the time your Investment Manager sells such securities short or at any time before the short position is “closed out” by your Investment Manager. Investment Managers that sell securities short will use cash generated from short sales to purchase additional securities, (i.e., leverage). If margin is used by your Investment Manager or if adverse market conditions trigger a margin call, you will pay interest pursuant to the Margin Agreement. Loans and Collateral. If your Account assets are “pledged” or used as collateral, with our consent, in connection with loans obtained through a Lending Program, the costs associated with such a lending arrangement under a Lending Program are not included in the MAS Fee and results in additional compensation to us, our Affiliate(s) and our Financial Advisors. Cash Assets. The MAS Fee will be applied to any cash and eligible cash alternatives held within your Account. You will experience negative performance on the cash asset holdings in your Account if the fee charged on your cash and any cash alternatives is higher than the return you receive on any cash asset holdings. The MAS Fee is in addition to other compensation that we and our Affiliates earn on cash that is held for investment purposes and on cash held as part of a cash asset allocation and swept to a cash sweep vehicle in accordance with the Cash Sweep Program. For more information about the Cash Sweep Program, including compensation and benefits we and our Affiliates receive, see “Funding and Operation of MAS Accounts—Cash Balances and the Cash Sweep Program” and “Participation or Interest in Client Transactions—Cash Balances and the Cash Sweep Program” for more information. ABILITY TO OBTAIN THE MAS SERVICES SEPARATELY You may be able to obtain investment advisory services and access to managed investment strategies from other investment advisory programs that we or our Affiliates offer. Depending upon the factors below, MAS may cost you more or less than purchasing the services separately. You may also be able to obtain some or all of the types of MAS services available through MAS from other firms, and account fees may be higher or lower than the fees charged by other firms for comparable services. It is your responsibility to review the other services or investments available through us and our Affiliates with your Financial Advisor to determine which may be most appropriate for you. In comparing the account types and programs and their relative costs, you should consider various factors, including, but not limited to: 19 MAS2A 0325Merrill Lynch Managed Account Service Brochure • Your preference for an advisory or brokerage relationship. • Your preference for a discretionary or a non-discretionary relationship. • Your preference for a fee-based or commission-based relationship. • Your preference for access to a dedicated Financial Advisor. • The types of investment vehicles and solutions that are available in each program or service and their costs. • How much trading activity you expect to take place in your Account. • How much of your assets you expect to be allocated to cash. • The frequency and type of client profiling reports, performance reporting and account reviews that are available in each program or service. • The scope of ancillary services that may be available to you in a brokerage account but that are not available in an advisory program. We have provided you with materials that help to explain the various platforms and programs we offer, including the Form CRS and the Summary of Programs and Services, both of which are available at ml.com/ relationships or from your Financial Advisor upon request. Merrill makes available two other investment advisory programs that provide a client with the ability to receive certain investment advisory services directly from an investment manager under a separate agreement as well as certain limited investment advisory services from Merrill as described in the applicable program brochures. By enrolling into the Merrill Lynch Investment Advisory Program (“MLIAP”) and selecting the Premium Access Strategy (“PAS”) option, clients will receive access to discretionary management services and investment strategies of a third-party or affiliated investment manager (a “PAS manager”) pursuant to a separate contract with the PAS manager. The client will pay Merrill an asset-based fee based on the value of the assets enrolled in the account and the Merrill fee rate, a rate negotiated by the client and the Financial Advisor, subject to a maximum rate of 1.75%. The client and the PAS manager also negotiate the PAS manager fee rate as part of the client’s separate contract with the PAS manager. BANA, our Affiliate, makes available certain of its managed strategies through MLIAP as PAS manager strategies. BANA makes available certain of its managed strategies through MLIAP as PAS strategies to Accounts and to TMA Accounts enrolled in MLIAP. These strategies may also be available directly through BANA outside of MLIAP, including though the Select Portfolio Solutions program offered by BANA to its clients for which a Merrill Affiliate acts as an investment adviser. The fee schedules applicable to MLIAP TMA clients and clients with accounts directly through BANA are different from that offered in MAS and can be lower than the MAS Fee Rate negotiated with your Financial Advisor. Certain Investment Managers that participate in the MAS program also provide managed investment strategies in MLIAP. By enrolling into the Merrill Lynch Strategic Portfolio Advisors program (“SPA”), clients will receive access to discretionary management services and investment strategies of an investment manager and related advisory and trading services pursuant to a separate contract with such manager. The client will pay Merrill an asset-based fee based on the value of the assets enrolled in the SPA account and the Merrill SPA fee rate, a rate negotiated by the client and the Financial Advisor. The maximum Merrill SPA rate that can be charged in SPA is 1.50% for equity and hybrid SPA managed strategies and 0.70% for SPA managed fixed income strategies and there are various fee levels depending on the assets invested in the program. The client and the SPA manager also negotiate the SPA manager fee rate as part of the client’s separate contract with the SPA manager. Certain third-party Investment Managers that participate in the SPA program also also provide PAS manager strategies in MLIAP. There are important differences among this Program, MLIAP and SPA and having a BANA account relationship in terms of the involvement of your Financial Advisor in providing ongoing advice, the services, 20 MAS2A 0325Merrill Lynch Managed Account Service Brochure structure and administration, the depth of research conducted on the investment managers available in the programs and the applicable fees. The investment strategies available to you in the Program are not offered in MLIAP or SPA. You may request a copy of the ADV program brochures for these programs by contacting your Financial Advisor. TAX MATTERS You acknowledge that your Investment Manager may sell all or a portion of the securities in your Account, either initially or during the course of your participation in MAS. You are responsible for all tax liabilities arising from these transactions. We and your Financial Advisor will not offer tax advice to you on these or any other issues. You also are responsible for all tax liabilities and tax-return filing obligations arising from all transactions in your Account enrolled in the Program. We are not responsible for attempting to obtain any tax credit or similar item or preparing and filing any legal document on your behalf. You should review all disclosures you receive associated with the investments held in and transactions occurring within your Account with a qualified tax professional. We do not, and will not, offer tax advice to you and you need to rely on such qualified tax professional in all instances for tax advice. If you are an investor with special circumstances such as a non-U.S. resident or an entity sensitive to unrelated business taxable income, you should also discuss with your qualified tax professional the tax consequences of each investment held in your Account as there may be additional tax withholding, reporting and payment obligations which may result from such investments. Special tax rules may apply to the investments themselves which may result in unique tax consequences to you. In some circumstances, certain tax elections may be able to be made that will affect the tax consequences arising from such an investment. Certain investments (such as master limited partnerships) may result in tax consequences to investors that are subject to tax on unrelated business taxable income and you will be responsible for the reporting and filing of tax returns and the payment of the associated income tax resulting from such investments. You should be aware that tax consequences may arise when portfolio changes occur in your Account, such as rebalancing, liquidations and redemptions and as a result of any action undertaken as part of a Direct Indexing Strategy (as defined below). We specifically disclaim any undertaking of tax management of your Account or investments and assume no responsibility for any resulting tax consequences. Special Risks and Limitations Associated with Direct Indexing Strategies. You may elect a Strategy for your Account where an objective of the portfolio management investment approach undertaken by the Investment Manager is to opportunistically sell securities that have a loss and invest proceeds in strategy-aligned replacement securities or other tax loss harvesting approaches (a “Direct Indexing Strategy”). The Investment Manager’s investment decisions and related transaction orders for the Direct Indexing Strategy may include selling depreciated positions and seeking to recognize tax losses to offset your capital gains (and, possibly, ordinary income to a limited extent), recognizing capital gains to seek to offset any recognized losses, selling the highest cost securities first, seeking to avoid the wash sale rules and/or other tax harvesting actions. There are risks and limitations associated with Direct Indexing Strategies and these limitations may result in tax-inefficient trades and wash sales. You should consult your tax and/or legal advisor prior to enrolling in any Direct Indexing Strategy, as well as on an ongoing basis to determine whether the wash sale rules, the straddle rules, or other special tax rules could apply to your trading activity. Generally, under the wash sale rules, if you sell a security for a loss and you repurchase the same (or a substantially identical) security either 30 days before or 30 days after the date of sale, the loss is disallowed. In addition, other tax treatment rules, such as the straddle rules, may disallow losses. There is little authority governing whether an ETF replacement security is “substantially identical” to another ETF security for purposes of the wash sale rules. As such, no assurances can be provided that if an Investment Manager chooses an ETF as a replacement security to the sold security, the replacement security will not be deemed “substantially identical” for purposes of the wash sale rules. 21 MAS2A 0325Merrill Lynch Managed Account Service Brochure It is important to note that Direct Indexing Strategies apply on a per-Account basis only and only to the Account that has selected the particular Direct Indexing Strategy. Please note, however, that the wash sale rules apply to securities transactions in not only that Account but also to securities transactions in all other accounts held by you, your spouse and certain entities controlled by you and your spouse. The accounts covered under the wash sale rules include all taxable accounts and retirement accounts held at Merrill or an Affiliate that are brokerage accounts and/or accounts enrolled in investment advisory programs, and all securities accounts of any type held with third parties in each case, held by you, your spouse and certain entities controlled by you and your spouse (collectively, “securities accounts”). The Direct Indexing Strategy will not take into account trading activity in any of these other securities accounts. The sale of a security for a loss in an Account enrolled in a Direct Indexing Strategy will not generate a loss for tax purposes if the security was part of a wash sale or straddle as a result of trading activity or securities in any other of your securities accounts. In addition, the purchase of a replacement security in an Account enrolled in a Direct Indexing Strategy may give rise to a wash sale with respect to a security or position in any of your securities accounts (including those of your spouse and certain of your spouse’s controlled entities). Similarly, other trades executed in any securities account may also result in a wash sale in the Account enrolled in a Direct Indexing Strategy. In applying a Direct Indexing Strategy to an Account that includes selling securities and investing in Strategy- aligned replacements, the performance of any replacement security selected will not be the same as that of the security sold and, in fact, the replacement security may perform worse than the security sold. Any tax-related benefits that result from a Direct Indexing Strategy may be negated or outweighed by investment losses and/or missed gains (realized and unrealized) that also may result. An Account that enrolls in a Direct Indexing Strategy will generally trade more frequently than an account which has not selected a Direct Indexing Strategy. There are implicit trading opportunity costs associated with the additional turnover which may affect the returns on your Account. Direct Indexing Strategies may not be appropriate for your financial situation. If you are taxed at lower aggregate marginal income tax rates, you may be less likely to benefit from the Direct Indexing Strategies than would an investor taxed at higher aggregate marginal income tax rates. Because you may use capital losses only to offset certain amounts of capital gains that you might have, and possibly, to a limited extent, ordinary income, if you have net capital losses in excess of the applicable threshold, you may not realize as many immediate tax benefits through the application of a Direct Indexing Strategy to your Account. It is your obligation to monitor transactions across all of your accounts to identify any wash sales or straddles and for all tax liabilities attributable to the disallowance of any losses pursuant to the wash sale rules or of any deferral under the straddle rules. Merrill cannot provide any assurances that losses will not be disallowed pursuant to the wash sale rules or deferred under the straddle rules. If you elect to enroll in a Direct Indexing Strategy, you should consider receiving trade-by-trade confirmations (rather than receiving trade confirmations on a periodic basis), monitoring those confirmations, and, to the extent any security is sold for a loss, refraining from acquiring the same (or a substantially identical) security in your Account or any of your securities accounts. Despite this, it is possible that you may still be subject to the wash sale or straddle rules in any given tax year. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS CLIENT ELIGIBILITY Merrill requires that all clients who wish to enroll in the Program enter into the Client Agreement. The Client Agreement sets forth the terms and conditions that govern the handling of the client’s Account and the investment advisory relationship between the client and Merrill. A separate account is required for each MAS Account. In addition, clients enter into separate agreements with the selected Investment Manager, which sets forth the terms and conditions that govern the management of the client’s Account by the Investment Manager. Merrill and/or the Investment Manager may each decline to accept a particular client or account in the Program at any time and for any reason at their sole discretion. 22 MAS2A 0325Merrill Lynch Managed Account Service Brochure Investors eligible to participate in MAS include, but are not limited to, individuals, trust and estates (to the extent allowed by state law), charitable organizations, banks, corporations, or such other participants as we determine in our discretion and in accordance with applicable law. RETIREMENT ACCOUNTS MAS is generally closed to new enrollments by Retirement Accounts. If you are an existing Retirement Account client, you should understand that our services described herein are offered in order to assist plan fiduciaries as they carry out their investment-related responsibilities and are not intended to be a basis for decisions related to your Account. Moreover, these services should not substitute for or diminish the careful deliberation and determination of your plan fiduciaries, after appropriate consultation with other professional advisers and the review of relevant plan documentation. ACCOUNT MINIMUMS The minimum account size for a MAS Account generally is $100,000, but we, in our discretion, may accept accounts less than $100,000. Certain Investment Manager Strategies require minimum investment amounts as determined by the Investment Manager. You may fund your Account with cash and/or securities acceptable to us. When funding an Account with securities (or otherwise transferring securities into an Account), however, you should bear in mind that your Investment Manager may decide to sell all or a substantial portion of such securities and that you will be responsible for any tax or other liabilities (such as CDSC on certain classes of mutual fund shares) resulting from such transactions. PORTFOLIO MANAGER SELECTION AND EVALUATION SELECTION OF INVESTMENT MANAGERS Selection of your Investment Managers is at your sole discretion, and, except as described below, we have not and will not evaluate any Investment Manager or your Investment Manager’s investment style or Strategy for compatibility or suitability with your objectives. Generally, we do not authorize Investment Managers to make any statements pertaining to us, or any Investment Manager’s participation in any Merrill service or program, including MAS. You represent and warrant that you have independently selected each Investment Manager and investment style and believe that each Investment Manager and investment style is appropriate for your Accounts. You further represent and warrant that you have not asked for, received or relied upon our advice in making each selection. We make no representations regarding the qualifications of your Investment Manager. We do not endorse, recommend or otherwise suggest that your Investment Manager will make suitable investment decisions for you. We do not undertake to investigate or monitor the suitability of your Investment Manager’s investment decisions. To the extent that you become aware of investment decisions by your Investment Manager that are unsuitable for your Account, you should contact your Financial Advisor or your Investment Manager. We do not specifically identify or select Investment Managers to participate in MAS, and we do not maintain a roster of approved MAS Investment Managers from which you may select. However, we may have, or may have in the past had, certain relationships or been affiliated with an Investment Manager, as described more fully below. We do not calculate the performance of Investment Managers, and neither Merrill nor any third party reviews Investment Manager performance information to verify its accuracy or its compliance with presentation standards. Performance information may not be calculated on a uniform or consistent basis. You are responsible for the continued review of your Accounts and the performance of your Investment Manager. We are not responsible for the investment decisions your Investment Manager makes. You are responsible for reviewing your Account performance in light of your Account’s asset allocation and investment performance, and contacting your Investment Manager if they have questions or concerns. We do not assume responsibility for replacing or recommending the replacement of Investment Managers. 23 MAS2A 0325Merrill Lynch Managed Account Service Brochure INVESTMENT MANAGERS Most of your Investment Managers from which we receive investment directions in MAS are not affiliated with us. However, certain Investment Managers may be, or have been in the past, Related Managers. The status as a Related Manager creates additional conflicts of interest (see “Related Managers below”). Unless otherwise noted in this Brochure, the services provided by us and your Financial Advisor to you will not be affected by the type of Investment Manager you have retained, and in MAS, we do not and will not conduct any due diligence on, or ongoing monitoring of, any Investment Managers. In certain instances, your Investment Manager may have referred clients to your Financial Advisor, or Merrill programs or services, including MAS. In these instances, a conflict of interest exists between you and your Financial Advisor, Merrill and/or your Investment Manager. Please ask your Financial Advisor and/or Investment Manager for more information regarding Investment Manager referrals. Referral-Arrangement Managers. In very limited instances, we have entered into contractual arrangements through which we are compensated for referring you to Referral-Arrangement Managers. If you have been introduced to such a Referral-Arrangement Manager, we will provide a written statement describing the terms of the arrangement and a copy of the Referral-Arrangement Manager’s brochure. You also will be required to sign an acknowledgement of your receipt of these materials. Because we are compensated for referring clients to Referral-Arrangement Managers, this presents a conflict of interest that you should be aware of and consider before choosing a Referral-Arrangement Manager for MAS. Legacy Managers. While we may have previously conducted due diligence or ongoing monitoring of Legacy Managers in the Previous Program, we are not responsible for conducting any due diligence or monitoring in MAS beyond that described in this Brochure and the Client Agreement. You should not consider any prior statements that we or your Financial Advisor may have made concerning a Legacy Manager, including any written materials or Legacy Manager information distributed by us, when deciding whether or not to retain the services of a Legacy Manager. Related Managers. The MAS program may allow you to use the services of Investment Managers that are Related Managers. The selection of a Related Manager results in increased compensation to us or an Affiliate. Again, Merrill will not recommend and does not provide any due diligence on any Investment Manager, including Related Managers, in MAS. MERRILL AND CERTAIN AFFILIATES ACTING AS PORTFOLIO MANAGERS Merrill acts as the wrap fee program sponsor for this Program and also acts as the portfolio manager in other wrap fee programs sponsored by us. We receive the MAS Fee as described in this Brochure. We also act as a portfolio manager in certain investment advisory programs which are not wrap fee programs but are otherwise similar to the program described in this Brochure. Investment Managers, which may include Related Managers, are exclusively responsible for the management of client assets as described in the section “Services, Fees and Compensation.” Your Investment Manager charges a separate management fee for services. TAILORED INVESTMENT ADVICE You will enter into a separate agreement with your selected Investment Manager for the management of your assets. You may impose reasonable investment restrictions on your Account but you must communicate such restrictions to your Investment Manager. PERFORMANCE BASED FEES The Program does not charge performance-based fees. 24 MAS2A 0325Merrill Lynch Managed Account Service Brochure METHODS OF ANALYSIS As noted in the section Portfolio Manager Selection and Evaluation, selection of your Investment Manager is at your sole discretion, and, except as described in such section, we have not and will not evaluate any Investment Manager or your Investment Manager’s investment style or strategy. You should understand that all investments involve risk (the amount of which may vary significantly), that investment performance can never be predicted or guaranteed and that the value of your Account will fluctuate due to market conditions and other factors. VOTING CLIENT SECURITIES As described in the section “Proxy Voting and Other Legal Matters,” unless otherwise designated in the Client Agreement or other writing addressed to us or another custodian you select, you direct your Investment Manager for each MAS Account to vote the proxies relating to the securities held in the MAS Account. INVESTMENT RISK Set forth below is a summary description of material risks related to the MAS services and investment strategies and products that have significant or unusual risks. The information provided below is meant to summarize certain risks and is not inclusive of each and every potential risk associated with each investment type or applicable to a particular Account. Therefore, you should not rely solely on the descriptions provided below and are urged to speak with your Financial Advisor and the Investment Manager and ask questions regarding risk factors applicable to a particular Strategy, read all Strategy-specific risk disclosures and determine whether a particular Strategy is suitable for your account in light of your specific circumstances, investment objectives and financial situation. General. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed, and the value of your assets will fluctuate due to market conditions and other factors. Investments made and the actions taken respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics, terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. You should review the offering materials and other disclosure available for each relevant investment security or transaction to get an appreciation of its associated risks and fees. Strategies that consist of equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain Strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. 25 MAS2A 0325Merrill Lynch Managed Account Service Brochure Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. You should review the offering materials and other disclosure available for each relevant investment security or transaction to get an appreciation of its associated risks and fees. You are assuming the risks involved with investing in securities and other investment products, and you could lose all or a portion of the amount you hold in the Program. You should understand: • Investment performance can never be predicted or guaranteed. • The values of your Accounts will fluctuate due to market conditions, manager performance and other factors. • There is no assurance that the performance results of any benchmark or index used in connection with MAS, including those shown on performance reports or our other reports, can be attained. • All or a portion of your securities may be sold either at the initiation of or during the management of your Accounts. You are responsible for all the tax liabilities arising from these transactions and are encouraged to seek the advice of qualified tax professionals. • The purchase and sale of U.S. securities may have additional adverse tax consequences and risks if you are not a resident of the U.S. Risks of the Strategy. By deciding to allow your Investment Manager to manage your assets in the Account in accordance with the selected MAS Strategy, you assume the risks associated with the Investment Manager’s investment decisions. Accordingly, if your Investment Manager assembles a concentrated position in the Account, you assume the risk of a substantial loss in value to the entire Account if there is a decline in the concentrated position or industry sector. Similarly, if your Investment Manager effects trades in securities that we do not follow or for which we have a contrary recommendation, you assume the risk associated with this activity. Market movements, the investment decisions of your Investment Manager, and other factors may result in significant differences between the performance of Account assets and any investment objectives made known to us. You acknowledge that the investments made and the actions taken for your Account will be subject to various market, liquidity, currency, economic and political risks, and may decline in value. You further acknowledge that we do not assume responsibility for or endorse the investment decisions made by your Investment Manager, which may involve additional and significant risks. If your Investment Manager chooses to make use of margin to effect transactions in an Account, you assume the risk associated with margin transactions, including that losses in the value of an asset purchased on margin are magnified as a result of the use of borrowed money. Generally, we believe that these investment styles add risk to a portfolio that you should not assume unless you are prepared to experience significant losses in the value of your Account. Ultimately, as between you and us, you bear the risk of all of these decisions including: • You can lose more funds than amounts deposited in margin accounts. • We can force the sale of securities or other assets in your Merrill account(s). • We can sell your securities and other assets without contacting you. • You are not entitled to choose which securities or other assets in the Account are to be liquidated or sold to meet margin calls. • We can increase our “house” maintenance margin requirements at any time without advance written notice. • You are not entitled to an extension of time on a margin call. • If a margin call cannot be fully satisfied from assets in your Account or other assets at Merrill, you will remain liable for the outstanding debt. 26 MAS2A 0325Merrill Lynch Managed Account Service Brochure If your Investment Manager writes uncovered options in your selected Strategy, you assume additional risk, including: • You will be exposed to potentially significant losses. • If your Investment Manager writes an uncovered call option, if the value of the underlying instrument increases above the exercise price, you can incur large and unlimited losses until the option expires or other option contract remedies. • If your Investment Manager writes an uncovered put option, you bear the risk of loss if the value of the underlying instrument declines below the exercise price. • If your Investment Manager writes combination or straddle options (where a put and a call option are written on the same underlying instrument), the potential risk of loss is unlimited. • If a secondary market in options were to become unavailable, your Investment Manager could not engage in a closing transaction and you would remain obligated until expiration or assignment. • In accordance with the option account agreement, if you do not meet applicable margin payment requirements, we may liquidate stock, options or other positions in the Account, with little or no prior notice to you. Please note that short selling stock has similar risks as those described above regarding writing uncovered call options and you will assume similar risks of loss. The Investment Manager for the strategy in our Account can sell all or a portion of the securities in your Account, either initially or during the course of your enrollment in the Strategy. You are responsible for all tax liabilities arising from these transactions. We and your Financial Advisor will not offer tax advice to you on these or other issues. Information and Cybersecurity Risks. With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly. BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities, Investment Managers, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents suffered by BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents and well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we or our service providers, will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (“AI”) 27 MAS2A 0325Merrill Lynch Managed Account Service Brochure and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory, operational and ESG reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. ESG-themed Strategies. There are an increasing number of products and services that purport to offer environmental, social, and governance (“ESG”) or sustainable strategies (“ESG Strategies”). The variability and imprecision of industry ESG definitions and terms can create confusion. Investment Managers and product sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. Merrill and its Affiliates generally do not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the Investment Manager). You should review the offering materials to gain an understanding of how these managers and product sponsors describe their investment approach. ESG Strategies can limit the types and number of investment opportunities and, as a result, could underperform other Strategies that do not have an ESG or sustainable focus. Certain Strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by an Investment Manager will align with your ESG-related beliefs or values. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the Investment Manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s 28 MAS2A 0325Merrill Lynch Managed Account Service Brochure ability to make investments or take advantage of opportunities that may be available to clients that do not choose similar restrictions and, as a result, investment performance could suffer. On the other hand, category restrictions that aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category may not exclude all companies with any tie or revenue derived from such restricted category and require assumptions, opinions and the subjective judgment of the data provider that might not reflect your ESG-related views or values. If you hold an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event. When evaluating investments for an ESG Strategy, an Investment Manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment an investment’s ESG or sustainable attributes. Merrill does not review, guarantee or validate any third-party data, ratings, screenings or processes. Moreover, the screenings and processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in a Account holding investments in companies that derive revenue from the restricted category. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS As part of the enrollment process into MAS, you may need to provide information about your financial circumstances, investment objectives, risk tolerance and other relevant information relating to your Account. With certain exceptions, this information will not be provided to your Investment Manager. You are obligated to notify your Financial Advisor promptly of any material change in financial circumstances, investment objectives or investment restrictions (if any) that may affect the services your Financial Advisor provides to the Account in MAS. You are notified periodically to emphasize the need for you to report such information. The management of your Account is the responsibility of your selected Investment Manager. Accordingly, you must also provide any such updated information directly to your Investment Manager, and neither Merrill nor our Financial Advisors have any obligation to communicate such information to your Investment Manager. CLIENT CONTACT WITH PORTFOLIO MANAGERS We do not place any restrictions on your ability to contact and consult with your Investment Manager. Under MAS, you enter into a separate agreement with your Investment Manager and that agreement will discuss your ability to contact your Investment Manager. ADDITIONAL INFORMATION DISCIPLINARY INFORMATION The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill’s Form ADV at adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the MLBD Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. 29 MAS2A 0325Merrill Lynch Managed Account Service Brochure On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’s remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through BofAS, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system and also provides financing to clients, including margin lending and other extensions of credit as well 30 MAS2A 0325Merrill Lynch Managed Account Service Brochure as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As a registered investment adviser, Merrill completes a Form ADV, which is publicly filed with the SEC and accessible at adviserinfo.sec.gov. For purposes of Form ADV Part 2, certain MLPF&S management persons are registered as registered representatives or associated persons of MLPF&S. In the future, certain MLPF& personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of MLPF&S to the extent necessary or appropriate to perform their job responsibilities. We, through our Financial Advisors, may suggest or recommend that clients, including MAS clients, use our securities account, execution and custody or other services for your investment activity or use the services of an Affiliate. Similarly, Financial Advisors may suggest or recommend that clients purchase our products or our Affiliates’ products. Where you use or purchase Merrill’s or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Financial Advisors, as permitted by applicable law, receive compensation (the amount of which varies) in connection with these products and services. CONFLICTS OF INTEREST AND INFORMATION WALLS Merrill and its parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within BofA Corp. possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp. and Merrill evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. CODE OF ETHICS Merrill has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services. The Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that we follow in conducting our business with integrity and professionalism. The Code of Ethics covers requirements relating to employees complying with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. Covered personnel must certify to the receipt of the Code of Ethics. The Merrill Investment Adviser Code of Ethics is available at mymerrill.com/ADV/materials or we will provide a copy of each Code of Ethics to you upon request. We also have imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions as well as those of all employees. Our requirements impose certain responsibilities on Financial Advisors and their trading. Financial Advisors are permitted to participate in 31 MAS2A 0325Merrill Lynch Managed Account Service Brochure block trades along with their clients and/or other Program clients. COMPENSATION, CONFLICTS OF INTEREST AND MATERIAL RELATIONSHIPS Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel Merrill Benefits. Merrill earns revenue from the MAS Fee paid to us under the Program, as well as from commissions, markups/markdowns, up-front sales charges and other sales charges or fees (collectively, “Sales Charges”) paid in connection with brokerage transactions. Merrill also earns revenue from other fees and payments you may make and from what it receives from Affiliates and third-party Investment Manager, fund managers, product distributors and sponsors and other product providers (“Third-Party Firms”) related to transactions in your Account. Merrill may also receive revenue from Third-Party Firms depending on the investment products in which you invest, which is not part of the Financial Advisor’s compensation. The amount of revenue we receive and compensation your Financial Advisor earns varies depending on the type of account relationship you have with us and whether your account is enrolled in the Program or is a brokerage account. These differences create a conflict of interest in that there is a financial incentive for your Financial Advisor to recommend or select a certain type of relationship or certain investment programs based on the nature of the compensation they will receive. The revenue we receive from your enrollment in the Program may also be more or less than the revenue that would be received if you had instead participated in other of our investment advisory programs or if you had engaged in the investment activities in a brokerage account. There is a conflict of interest when your Financial Advisor recommends an account or program type, a security transaction or investment strategy where it is expected that Merrill will earn greater revenue over another account or program type, security transaction or investment strategy and therefore will earn more compensation. The more assets there are in your Account, the more you will pay in fees, creating a financial incentive to recommend that you increase the assets in your Account. In the Program, we make more revenue based on the level of assets in the Account as well as the level of the MAS Fee rate that you agree to or are charged. Financial Advisor Compensation and Awards. The Financial Advisor compensation structure results in conflicts of interest between clients and Financial Advisors. Financial Advisors earn compensation based on the revenue that Merrill earns from the MAS Fee paid by you in the Program and other revenue derived from certain, but not all, of the other fees and costs you incur that are not covered by the MAS Fee. They also earn compensation and benefits based on the revenue that Merrill earns from Sales Charges related to securities transactions in any brokerage account you may have as well as from the revenue derived from the referrals to Affiliates (including referrals to an Affiliate for banking products or services). You could pay higher fees in a brokerage account than from an account that you enroll in the Program depending on the level of trade activity, products invested in and other factors, which incentivizes your Financial Advisor to recommend a brokerage account. By contrast, if the trading activity in your brokerage account is limited, your Financial Advisor has a financial incentive to recommend that you enroll your account in the Program because we and your Financial Advisor could earn greater compensation from the Program’s annual asset-based fee. For more information about these conflicts, please review the section “Account and Program Choice.” As Merrill revenue increases, the Financial Advisors’ compensation will increase or will be positively impacted. This means that a Financial Advisor will have a financial interest in recommending transactions that generate higher amounts of revenue for Merrill and compensation for them, rather than those transactions that generate lower amounts of revenue. They also have the incentive to charge the maximum MAS Rate rather than agreeing to a lesser fee rate or offering a discount or waiver of Sales Charges for brokerage transactions. We pay Financial Advisors a salary and incentive compensation that is based on the revenues Merrill receives for making available and/or providing the MAS services, as well as for the brokerage services provided to clients with brokerage accounts. In general, a Financial Advisor is credited in the form of “production credits” with a portion of the MAS Fee paid and, for brokerage accounts, the Sales Charges received from securities transactions. In addition, Financial Advisors also receive production credits based on a clients’ use of margin 32 MAS2A 0325Merrill Lynch Managed Account Service Brochure lending, in respect of brokerage cash swept to Bank Affiliates and for referrals of clients to BANA and other Merrill Affiliates for banking, lending and for other financial services, including trade execution. The calculation of production credits generated takes into account the MAS Fee you pay for the MAS services, Sales Charges received for the investment products purchased or sold in any brokerage account and other factors which may change from time to time. Because different investment products and services have varying Sales Charges, there are different associated production credits related to brokerage transactions in those products. Merrill compensates your Financial Advisor on an ongoing basis derived from the MAS Fee rate that applies to your Account. The MAS Fee rate is negotiable and when considering whether to offer or agree to a charge a lower MAS Fee rate to you, a Financial Advisor typically will consider a number of factors, including the type and size of your Account, the breadth of our relationship with you, your engagement with the Financial Advisor, competitive considerations and how Merrill compensates the Financial Advisor. You may accept or decline any proposed rate by your Financial Advisor as part of the negotiation process. Because the amount of compensation paid to your Financial Advisor is based on the MAS Fee rate for your Account, your Financial Advisor has a financial interest in that Rate. In general, Financial Advisors receive “production credits” toward their compensation formula based on the amount of the MAS Fee that you pay for your Account. Merrill’s policies result in Financial Advisors receiving fewer production credits if the weighted average of the MAS Fee Rates for your and your designated household members’ Accounts is lower than the rate levels for specific wealth asset tiers that Merrill establishes. Merrill and Financial Advisors have a conflict of interest based on this structure because the Financial Advisor is incentivized not to offer a MAS Fee Rate below such rate levels or is incentivized to maintain a certain level of assets in the Account since that would reduce their compensation earned. In the Program, the Financial Advisor has a financial incentive to obtain the highest MAS Fee rate in the fee discussions with you and this incentive can influence the recommendations related to the Strategy for an Account (which will have its own separate Investment Manager fee rate that would apply to your Account). The higher the MAS Fee rate you agree to, the more your Financial Advisor earns in production credits. The more overall production credits that a Financial Advisor generates, the higher the Financial Advisor’s incentive compensation. This creates a conflict of interest for the Financial Advisor to recommend a Strategy that could result in more earned production credits. The opportunity to negotiate a higher MAS Fee rate provides the Financial Advisor with an incentive to recommend Strategies with a lower Investment Manager Fee over Strategies that have a higher Investment Manager Fee. The ability to negotiate a higher MAS Fee rate benefits Merrill as well as the Financial Advisor since Merrill retains a certain percentage of the MAS Fee. Financial Advisors are eligible to receive a compensation award, payable over a defined period of time, from an incentive program that is currently based on meeting growth targets from the prior year in new households and in assets and liabilities. The growth in assets and liabilities component of the award is based on the movement of client assets into accounts enrolled in certain of our investment advisory programs; investment activity in specified investment products (e.g., money market funds, alternative investments, 529 Plan accounts, annuities and/or life insurance); the opening of new BANA trust accounts; the establishment of 401(k) Plan accounts; and clients’ participation in banking services and lending services (i.e., brokerage sweep deposit accounts and brokerage sweep money market funds, checking and savings accounts, preferred deposit products available in brokerage accounts, loans, mortgages and margin lending) offered by Merrill, BANA and our other Bank Affiliates. Financial Advisors do not receive additional compensation as a result of advisory client assets held in the bank deposit Cash Sweep Program. A Financial Advisor is subject to a reduction in their incentive compensation if they fail to achieve growth for two consecutive years in the assets and liabilities component of the award. Merrill considers and approves its compensation program from year to year and its compensation criteria can change that will impact compensation paid to Financial Advisors. Having a compensation award based on meeting criteria based on client investment activity and engaging with Merrill or Affiliate financial and banking-related services presents a conflict of interest between the Financial Advisor and you because it could lead to such activity being promoted by 33 MAS2A 0325Merrill Lynch Managed Account Service Brochure your Financial Advisor to qualify for the compensation award or to avoid the reduction in their incentive compensation. Financial Advisor Recruitment Payments. Financial Advisors who join Merrill from other firms generally receive payments in connection with that move. These payments may take various forms, including salary guarantees, upfront bonuses or loans and various forms of compensation contingent on continued employment. The amount paid to Financial Advisors under these arrangements generally is based to a large extent on the size of the business at their prior firm. In addition, as part of the recruiting arrangements, they are eligible for future bonus payments based on assets that transfer, including from their prior firm, which creates a conflict of interest since they have an incentive to recommend a transfer of the assets to us. The future bonus payments are conditioned on the total assets in accounts that they service at Merrill. These bonuses are in addition to the incentive compensation to which they are otherwise entitled as Financial Advisors. Rollover Recommendations and Compensation. Financial Advisors have a financial incentive to recommend rolling over assets (a “rollover”) from an employer-sponsored retirement plan (such as a 401(k) plan) or a retirement account at another firm into an Individual Retirement Account (IRA). We and our Financial Advisors also have a financial incentive to recommend a rollover to Merrill because transactions in the rollover IRA will generate either investment advisory fees if that account is enrolled in the Program or Sales Charges and other compensation that benefits Merrill and the Financial Advisor. Note, MAS is generally closed to new enrollments by Retirement Accounts. For more information, please review the section “Account Requirements and Types of Clients – Retirement Accounts.” Referral Program and Compensation. Our Financial Advisors may recommend that you utilize the banking products and lending services of BANA or purchase products or services of our Affiliates. In addition, they may refer clients to BANA, BofAS and other Affiliates for financial services that they provide, including transaction execution and investment banking services and products (including banking products). They may introduce fund and other investment product distributors, sponsors, service providers or their affiliates to other services that we, BofA Corp. and our Affiliates provide. Similarly, employees of BANA, BofAS and other Affiliates may refer clients to us for brokerage and investment advisory services. These referrals can involve the payment of referral fees between us and BANA or our Affiliates. If a Financial Advisor refers a client to BANA or other Bank Affiliates to establish a bank account directly with the bank, Merrill receives a payment directly from each Bank Affiliate based on the daily deposit balance held by the Bank Affiliate. The amount of the payment made to Merrill varies from time to time and varies based on the Bank Affiliate. We may waive all or part of this payment. Our referral payment program results in a conflict of interest because Merrill and our Financial Advisors are incentivized to introduce products or financial, banking and lending services that provide us or our Affiliates additional compensation or the Financial Advisor with associated production credits. Field Management and Merrill Management Compensation. Elements of our field management compensation are based on revenues to Merrill and based on the Financial Advisors whom they manage meeting strategic goals set for the year, including the growth in assets and liabilities component of the award as described in the subsection “Financial Advisor Compensation and Awards.” Management personnel of Merrill and other employees of Merrill and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is an incentive for our field management team to encourage Financial Advisors to recommend products and services that result in more revenue to Merrill, BANA and other Bank Affiliates and to meet their strategic growth compensation targets under the Financial Advisor compensation plan. There is a financial incentive for Merrill management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. 34 MAS2A 0325Merrill Lynch Managed Account Service Brochure We address the compensation conflicts described in this “Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel” section and in other sections of the Brochure, in a variety of ways, including the disclosure of the conflicts in this Brochure, by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. We engage in oversight and supervision of particular account type relationships and specific investment product choices and we provide account and product disclosures. We maintain policies and procedures and supervisory and review processes that are reasonably designed to ensure that Financial Advisors meet the standard of conduct applicable to each client and that compensation plans and referral compensation and criteria have been designed and implemented to mitigate any incentive or conflict to favor any one security type or investment product or service. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. Account and Program Choice Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. You have the ability to enroll accounts in the Program holding some or all of your investment assets and to have brokerage accounts for some or all of your assets. The various programs we offer and ways to interact with Merrill are outlined in the Form CRS, this Brochure and in the Summary of Programs and Services. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. There are differences among the programs and account relationships. You may be able to obtain the same or similar services or types of investments you obtain in the Program through a brokerage account or other investment advisory programs and services offered by Merrill. These may be available at lower or higher fees than the MAS Fee you pay. You may also be able to obtain some or all services from other firms and at fees that may be lower or higher than the MAS Fee we charge. A recommendation of the type of account relationship creates a conflict of interest for us and your Financial Advisor. The amount of compensation we and our Financial Advisors receive depends on the type of account and relationship you choose. In the Program, you will pay the MAS Fee at the rate you agree with your Financial Advisor for the MAS services. In the Program, the amount of compensation paid to us and to your Financial Advisor depends on the level of assets in your Account and the MAS Fee rate applicable to your Account, as well as certain indirect compensation outlined in this Brochure. In a brokerage account, you will pay per trade Sales Charges to purchase and sell securities and a portion of those charges and fees will be paid to your Financial Advisor. In a brokerage account, the amount of revenues we receive and the compensation that our Financial Advisors receive depends on the level of trading activity in the brokerage account, the applicable Sales Charges and the associated production credits as well as other indirect compensation. You could pay higher fees in a brokerage account than from an account enrolled in the Program depending on the Sales Charges, frequency of trading and the investment products for investment and other factors. By contrast, if the trading activity in your brokerage account is limited, your Financial Advisor has a financial incentive or conflict of interest to recommend that you enroll in the Program because we and your Financial Advisor could earn greater compensation from the annual asset-based fee. Certain investment strategies are available to you outside of the Program for more or less than you would pay in the Program. We offer other investment advisory programs that offer certain of the Strategies that are the same as or similar to those available in the Program. There are important differences between this Program and our other available investment advisory programs in terms of the services, structure and the applicable fees. You may obtain these Strategies for a lower cost than you pay in the Program but you will receive different services from the Services you receive through the Program. 35 MAS2A 0325Merrill Lynch Managed Account Service Brochure When you compare the account types and investment advisory programs and their relative costs with what is available in the Program, you should consider the various factors outlined in the section “Ability to Obtain the MAS Services Separately.” Certain of these factors relate to your preferences regarding the relationship, whether you are seeking the types of MAS services available in the Program, how you want to pay for investment services, the MAS Fee rate you agree to with your Financial Advisor and the types of Strategies you are interested in investing in. We address these conflicts through the disclosure in this Brochure and the Client Agreement, by providing clients with upfront information about our available programs and through Program enrollment confirmations in light of your investment objectives, preferences and financial circumstances. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. Use of Related Investment Managers Certain Investment Managers could be Investment Managers that are Related Managers and your ability to use Related Managers as part of MAS presents conflicts of interest for the Related Manager and us. The selection of a Related Manager would result in increased compensation to us or our Affiliate because we and/ or the Merrill Affiliate will retain both the MAS Fee and the Investment Manager Fee (other than with respect to Retirement Accounts). For this reason, a conflict of interest exists when your Financial Advisor assists you in the selection of a Strategy of a Related Manager. In addition, we have a conflict of interest when recommending, selecting, monitoring and considering the removal or status change of a Related Manager because we and our Affiliates have an incentive to favor Related Managers over those whose selection would be expected to result in less total compensation to us and our Affiliates. If the Strategy of a Related Manager is selected, we and/or the Merrill Affiliate retain both the MAS Fee and the Investment Manager Fee (other than with respect to Retirement Accounts). For this reason, a conflict of interest exists when your Financial Advisor assists you in the selection of a Strategy of a Related Manager. Our Affiliates such as BANA, offer their own managed products or wrap programs that are similar to this or other Merrill programs. Advice and/or recommendations provided to accounts in those programs, including advice related to the recommendation of certain Investment Managers, will be different from, or even conflict with, the advice and recommendations provided in connection with the Program or to other Affiliates. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. For example, we may recommend a specific Investment Manager for inclusion in a BANA program, but not a Merrill program. Conflicts of interest related to the inclusion of Related Managers in MAS are further discussed under the section “Trading in MAS Accounts.” We address these conflicts through disclosure in this Brochure. We also determine the compensation paid to our Financial Advisors on the same basis for all Strategies selected for use in the Program without regard to the amount of compensation we or our Affiliates receive. Our Financial Advisors do not have an incentive to recommend certain Strategies over others because they do not receive additional compensation from the MAS Manager Fee for a Strategy. Cash Sweep Program Compensation Received by Us and Our Affiliates Merrill benefits financially when there are cash balances in the bank deposit accounts affiliated with the Cash Sweep Program. Merrill receives payments from our Bank Affiliates on a per account basis for each account that sweeps to one of our Bank Affiliates relating to offering and supporting the Cash Sweep Program. The fees we receive from the Bank Affiliates is one of many factors that affect the interest rate paid by the Bank Affiliates on your swept cash balances under the Cash Sweep Program. For Accounts that are eligible 36 MAS2A 0325Merrill Lynch Managed Account Service Brochure for and that elect a money market fund as its cash sweep option, we receive compensation for providing infrastructure, marketing support, sub-accounting or other services. If you choose the “No Sweep” option, we also benefit from the custody or use of uninvested cash balances also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. For the ISA cash sweep option available to certain account types, we receive a fee directly from each Participating Bank based on the daily deposit balance held by the Participating Banks. For referrals made by a Financial Advisor resulting in a bank deposit account with a Bank Affiliate, we are entitled to receive a fee directly from each Bank Affiliate based on the daily deposit balance, which fee can be waived in whole or in part. For Program Accounts, Financial Advisors are compensated based on the MAS Fee charged on the Account which is based on the agreed-upon MAS Fee Rate and the value of the assets in the Account, including cash balances and cash alternatives swept under the Cash Sweep Program. This creates a conflict of interest and an incentive for the Financial Advisor to recommend that you hold your securities investments and cash assets in your Account so that it would be included in the fee calculation. In addition, Financial Advisors receive increased compensation based on achieving a number of strategic objectives, including, among other activities, the growth in their clients’ participation in banking services and Lending Programs offered by Merrill, BANA and our other Bank Affiliates, like the brokerage account bank sweep deposits and brokerage account sweep money market funds, checking and savings accounts, the Preferred Deposit product available in brokerage accounts, loans, mortgages and margin lending. Financial Advisors do not receive additional compensation as a result of advisory client assets held in the Cash Sweep Program. The Bank Affiliates benefit financially from the Cash Sweep Program. Through the Cash Sweep Program, they receive a stable, cost-effective source of funding. They use the cash funds that are deposited in the bank deposits to fund their current and future lending, investment and other business activities. The participation of the Bank Affiliates in the Cash Sweep Program increases their respective deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” they earn on the deposits—the difference between the interest paid on the bank deposits and other amounts paid to Merrill related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in your Account that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more our Bank Affiliates benefit. Cash balances swept to a bank deposit account of our Bank Affiliates will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts is periodically set and reset by the Bank Affiliates in their discretion. Under MLBD Program and RASP, interest rates are tiered based upon your relationship with Merrill. Accounts with the MLBD Program and RASP as their Cash Sweep Program that are enrolled in MAS and in other specified Merrill investment advisory programs receive the highest tier rate available under the Cash Sweep Program. A brokerage account with one of these sweep options that enrolls in the Program will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. There is no interest rate tiering offered under the IBVRD Facility. Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection and receive a lower rate than the highest rate available under the MLBD Program or RASP. In any event, the interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. Merrill receives compensation for administrative and other services from the money market funds available as an automatic sweep option for certain Retirement Accounts and TMAs which we do not retain under applicable regulation. We rebate the compensation received from the fund managers of the sweep money market funds to clients of these types of accounts. 37 MAS2A 0325Merrill Lynch Managed Account Service Brochure We address the conflicts of interests associated with the Cash Sweep Program and the deposit accounts in a variety of ways, including through disclosure in this Brochure, by requiring clients to affirm their interest for the Cash Sweep Program options in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to your participation in the Cash Sweep Program. Financial Advisors do not receive any additional compensation for assets held in the Cash Sweep Program as opposed to another cash alternative product. We have adopted various policies and procedures reasonably designed to prevent the cash sweep arrangement compensation and other business arrangements from affecting the nature of the advice we and our Financial Advisors provide. Third-Party Firm Business Relationships and Support While we do not recommend or select Investment Managers participating in MAS, we and our Affiliates have business relationships with Investment Managers, including Investment Managers participating in MAS, and other Third-Party Firms. We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for product vehicles managed or sponsored by them. We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates by a Third-Party Firm is additional compensation to us for services we and our Affiliates provide. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Financial Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our Financial Advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, we select Strategies that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our Financial Advisors provide. Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (“Conferences”) for invited Merrill financial professionals. These financial professionals include Financial Advisors, employees who work for a Merrill branch, market or division to support the Financial Advisors (“Field Employees”) and employees who cover product, Chief Investment Office and home office support functions (“Non-Field Employees”). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third-Party Firms participate (“Client Events”). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending Financial Advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with such Conferences and Client Events in the amount of approximately $21 million. 38 MAS2A 0325Merrill Lynch Managed Account Service Brochure Certain Third-Party Firms periodically host or participate in meetings (“Manager Meetings”) where they provide certain Financial Advisors, Field Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending Financial Advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third- Party Firms in support of charitable events and causes that we requested or initiated with Third-Party Firms in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives for Financial Advisors to recommend products of participating Third-Party Firms. They give those Financial Advisors participating in Conferences, Client Meetings and Manager Meetings with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for Field Employees to approve those recommendations and for non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our Financial Advisors to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Employees to approve their Financial Advisors’ recommendations of products and services of those participating Third-Party Firms. Furthermore, do not incentivize Non-Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. We limit the participation of Financial Advisors, Field Employees and Non-Field Employees in these events. Third-Party Firms are not permitted to condition their payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs of Conferences and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits and are subject to Merrill supervision and oversight that is reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Representatives of Third-Party Firms will, from time to time, meet and work with our Financial Advisors, Field Employees and Non-Field Employees, in one-on-one or small individual group meetings, to provide information and support regarding their respective investment products. We have adopted policies and procedures that limit Third-Party Firms from providing and paying for, and our Financial Advisors, Field Employees and Non-Field Employees from receiving, gifts and entertainment, other than as permitted and subject to the limits established under Merrill internal policies. In general, Financial Advisors, Field Employees and Non-Field Employees may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting Third-Party Firm representatives access to our financial professionals and paying for meals presents a conflict of interest. Providing Financial Advisors with gifts and entertainment creates incentives for them to recommend investment products of those Third-Party Firms. It can also create incentives for Field Employees to approve recommendations of a Financial Advisor, where required. Furthermore, providing gifts and entertainment to Non-Field Employees creates incentives to approve the investment products of the Third-Party Firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to 39 MAS2A 0325Merrill Lynch Managed Account Service Brochure condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS There are various ways that we can be viewed as participating or having an interest in client transactions. These situations and any conflicts of interest arising from such activities, execution approach or other capabilities we offer in the Program are discussed in this section and throughout the Brochure. Cash Balances and the Cash Sweep Program. As further described in “Funding and Operation of MAS Accounts—Cash Balances and the Cash Sweep Program” in cash balances may be held in your Account for a number of different reasons, including as part of a Strategy’s asset allocation to cash. To the extent the Investment Manager does not select a cash alternative vehicle for your Account’s cash allocation, the cash allocation will be maintained in your Account as a cash balance. Unless your Account is a certain type of Retirement Account or a TMA Account, the only sweep vehicle currently available to you for the cash balance is a bank deposit account affiliated with the Cash Sweep Program with our Bank Affiliates. Please see the section “Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates” for a discussion of the conflicts of interest related to the Cash Sweep Program. The Sweep Program Guide for Merrill Clients provides information on the fees that Merrill receives from the Bank Affiliates for each account, including Program Accounts that sweeps to the MLBD Program, the RASP and the ISA Program. These fees are up to $100 per year for each account received from the Bank Affiliates and a fee of up to 2% per annum of the daily balances from the ISA banks. This compensation is subject to change from time to time, and Merrill may waive all or part of it. For TMA and certain eligible retirement accounts that have selected the money market fund automatic sweep option, the available sweep money market funds include a 0.40% asset-based administration fee per annum that is paid to Merrill. Merrill rebates the amount of the asset-based administration fee it receives to these clients. The amount of such rebate may be less than this 0.40% fee in certain rate environments where the fund manager waives or reduces the amount of such fee in order to avoid a negative return on the money market fund. Merrill may benefit from the possession or use of cash balances, also known as free credit balances, in your accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. Other Compensation Received by Us and Our Affiliates. Separate and apart from the Program, Merrill, through its Financial Advisors, may suggest or recommend that you use the Merrill brokerage account and our execution and custody or other services for other of your investment activity or use the services of our Affiliates. Similarly, our Financial Advisors may suggest or recommend that you purchase our products or those of our Affiliates. Where you use or purchase our or our Affiliate’s products and services, we and our Affiliates will receive fees and compensation. We address the conflicts of interest presented by these Affiliated transactions described below by calculating the compensation paid to our Financial Advisors without regard to the amount of the compensation that we or our Affiliates receive from those transactions. In addition, we have adopted various policies and procedures reasonably designed to prevent the receipt of compensation by Merrill and its Affiliates and other business arrangements from affecting the nature of the advice we provide. Principal, Agency-Cross and Cross-Trades. There may be instances in which we or an Affiliate of ours act as principal in effecting an investment transaction for your Account, in accordance with applicable law. If we or an Affiliate of ours effect a principal transaction for your Account, we will not charge a markup or markdown. However, principal transactions may be subject to a mark-up, mark-down, dealer 40 MAS2A 0325Merrill Lynch Managed Account Service Brochure spread, underwriting discount, selling concession or other compensation and our Affiliates can profit from transacting as your counterparty or having proprietary positions in the subject securities. We or one of our Affiliates may, at times, act as agent for both buyer and seller in effecting investment transactions involving MAS clients or other advisory clients (“agency-cross transactions”), in accordance with applicable law. Since we generally will receive compensation from each party to an agency-cross transaction, there is a conflict between our responsibilities and loyalties to you and to the other party to the transaction. Any compensation we receive will be in addition to the MAS Fee. By signing the Client Agreement, you consent to us acting as your agent in effecting agency-cross transactions for the account when we consider them advisable and consistent with applicable law. You may revoke the consent at any time by notifying us in writing. From time to time, we may cause your account to engage in a transaction for the purchase or sale of a security with another client, subject to applicable law. We would do so only when we determine that the transaction is in the best interest of each party, and we would not receive any compensation in connection with the transaction. Investments in Fund Products. We generally restrict Investment Managers from purchasing mutual fund shares in your Account, including purchasing additional shares of any mutual fund that you used to fund your Account (either initially or otherwise). To the extent that you fund your Account with mutual fund shares, and you or your Investment Manager do not liquidate or transfer such shares from your Account within a limited period of time after being requested to do so, we will terminate your Account from MAS. Mutual funds and money market funds that are not held through a cash sweep vehicle applicable to your Account are not eligible assets and therefore are not subject to the MAS Fee. In the event your Investment Manager is permitted to use these mutual funds as a part of the Strategy used in your Account, you understand that these funds may be related to the Investment Manager. Any fees and compensation, including the sub-accounting services fees discussed below, that we or our Affiliates receive from or on behalf of a mutual fund or either of their product sponsors in connection with your investments enrolled in the Program are in addition to the MAS Fee and, except to the extent required by applicable law, the MAS Fee is not offset or reduced by any such fees and compensation we receive. These mutual funds may pay us to provide the required sub-accounting and other services. These sub- accounting and other services include aggregating and processing purchases, redemptions, exchanges dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under agreements with mutual funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services (either directly or through a subsidiary) to the holders of these types of mutual funds maintaining shares in an Account as well as in other Merrill securities accounts and receive the agreed upon sub-accounting services fee. This cost is either borne by the mutual fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by type of mutual funds, the mutual fund itself and by share class. For U.S. mutual funds, depending on the specific arrangements, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market funds, the sub-accounting services asset-based fee is generally 0.005% per annum. These fees and fee rates are subject to change from time to time and may be received individually, or as part of a “bundled” arrangement includes other types of fees, such as administration and distribution payments. Due to applicable regulation, we do not retain compensation for sub-accounting or administrative services for money market fund assets that are held through a cash sweep vehicle for Retirement Accounts or TMAs. The amount of the sub-accounting services fees varies among mutual funds and, in certain instances, between share classes of individual mutual funds. There is a benefit to us from the sub-accounting fee because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. We disclose the nature of our sub-accounting service arrangements. Mutual funds and money market funds, that 41 MAS2A 0325Merrill Lynch Managed Account Service Brochure are not held through a cash sweep vehicle applicable to your Account are not eligible assets and therefore are not subject to the MAS Fee. Provision of Financial Services. BofA Corp., through its subsidiaries and Affiliates, including us, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning, asset management and investment advisory and related recordkeeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, ETFs, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research including: global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. As a result, we, BofA Corp. and our Affiliates can be expected to pursue additional business opportunities with the entities whose investments we and our Financial Advisors recommend or make available to clients. Consistent with industry regulations, the services that we and our Affiliates provide include banking and lending services; sponsorship of deferred compensation and retirement plans; recordkeeping services; investment banking; securities research; institutional trading and prime brokerage services; custody services; investment advisory services; and effecting portfolio securities transactions for Funds and other clients. BofA Corp. is subject to the reporting requirements of the Exchange Act and additional information about it can be found in publicly available filings with the SEC. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships is publicly available in Regulation NMS Rule 606 reports we file with the SEC. From time to time, a shareholder of BofA Corp. may acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Account, such as buying or selling securities issued by the shareholder or its affiliates, may be limited. Participation in Affiliate Lending Programs and Margin. There are of conflicts of interest when we recommend that you use a loan secured by your Account assets as collateral. These conflicts exist with any of our Affiliate lending programs that may be available to you from an Affiliate lender. In the case of a loan from an Affiliate, including but not limited to the Loan Management Account® product (“LMA® account”), the Affiliate lender intends to derive a profit as lender based on interest and/or fees, if any, charged on the loan, and your Financial Advisor receives compensation based on a percentage of the loan revenue of the Affiliate lender for such loan. Financial Advisors may receive greater benefit if you borrow more under a margin or Affiliate lending program and if you are charged a higher interest rate. The lender, whether it be Merrill, or an Affiliate or a third-party lender, has a lien on your Account assets that are used as collateral for the loan. The lender will act to protect itself as lender in connection with the loan, and this may be contrary to your interests and/or investment objectives. Having a lien on your Account in connection with an Affiliate loan also creates a conflict of interest with respect to the recommendations we make to you. For example, your Financial Advisor may recommend that you allocate your investments to your Account that has an Affiliate lender’s lien rather than to another Account without such lien. Another example is that your Financial Advisor may recommend a less risky investment in order to minimize the risk of loss with respect to the Affiliate lender’s collateral. Furthermore, your Financial Advisor is compensated based on a percentage of the revenue on the loan and this means your Financial Advisor can benefit from your 42 MAS2A 0325Merrill Lynch Managed Account Service Brochure borrowing under the lending program, rather than liquidating assets held in the Account, and will receive a reduction in compensation earned by recommending you reduce your outstanding loan balance. Certain investment strategies can involve the use of margin. Merrill will receive compensation in connection with any assets purchased in an Account on margin or other extensions of credit by us, which is in addition to, and does not reduce, the MAS Fee. Financial Advisors will receive additional compensation in such circumstances, unless waived, as well as, in limited cases, from rights or tender offers. The additional economic benefit to us from the use of margin creates a conflict of interest. Activity by Merrill, its Affiliates and Personnel. We and our affiliates act in a variety of capacities to a wide range of clients. From time to time in the course of those duties, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. Similarly, we may give advice or take action with regard to certain clients, including MAS clients, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken with respect to certain securities, Funds or Investment Managers. In some instances, the actions taken by affiliates with respect to similar services and programs will conflict with the actions taken by us. This is due to, among other things, the differing nature of the affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. Certain of our affiliates may have investment banking or other relationships with certain publicly traded companies; from time to time, these relationships compel us to forego trading in the securities of these companies. In the course of investment banking and other activities, our affiliates acquire confidential or material nonpublic information that prevents us or our affiliates, for a period of time, from purchasing, selling or recommending particular securities for your account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. We do not receive payment for order flow from liquidity providers to which we route our customer orders in equity securities. We directly or indirectly (through our Affiliate) receive rebates from, and pay fees to, certain registered securities exchanges for providing or taking liquidity on those exchanges according to those exchanges’ published fee schedules filed with the SEC. In some cases, the rebates received by us from an exchange over a period of time will exceed the fees paid to the exchange. We directly or indirectly (through our Affiliate) also participate in the options order flow programs sponsored by options exchanges such as the NYSE American Options, NYSE Arca Options, and the Cboe options and Nasdaq options exchanges. These exchange-sponsored programs offer payments for listed option orders that are directed to such options markets. The rebates and payments from these third parties vary depending on the order and the exchange to which orders are directed and create a conflict of interest because we are incentivized to recommend transactions that provide us with greater rebates or payments from these exchanges. Related Managers may provide advisory services with respect to one or more strategies available for your selection. BofA Corp. is the ultimate parent company of and/or a direct or indirect substantial stockholder in Related Managers. If a Strategy provided by a Related Manager is selected, we and/or a Related Company will retain the entire MAS Fee. For this reason, a conflict of interest exists when our Financial Advisor selects or assists you in the selection of, as applicable, a Related Manager Strategy. We and our Affiliates provide some or all of the same services offered in the Program through other financial firms, either with Affiliates or with firms that are unaffiliated. Certain of these services have fee rates that differ from the MAS Fee. We or our Affiliates may have a position in or enter into “proprietary” transactions in securities purchased or sold for clients, including MAS clients. We or our Affiliates benefit from such securities positions or transactions. COVERED ENTITIES UNDER THE VOLCKER RULE We may provide certain entity clients that qualify as “family wealth management vehicles (“FWMV”)”, or FWMV clients, with both the services under the Program as well as lending services and to engage, where permitted, in principal transactions. In doing so, we rely on the exception under the Volcker Rule 43 MAS2A 0325Merrill Lynch Managed Account Service Brochure implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Client Agreement. For certain entity clients that are deemed “covered fund clients” under the Volcker Rule we are not permitted to offer both services under the Program and the availability of margin, lending or other extensions of credit from us or any of our Affiliates, including BANA, or engage in certain principal transactions. Certain other transactions between BANA or its Affiliates and the entity client will also be prohibited. REVIEW OF ACCOUNTS We do not review your Account on a periodic or other basis to monitor the trading of the Investment Manager or to confirm that Account transactions of the Investment Manager conform to your investment goals, risk tolerances or other instructions. We generally provide you with the opportunity to engage in periodic Account reviews in which your Financial Advisor reviews your Account’s progress toward goals. Because these reviews provide you with important and necessary information relating to your Account, you are strongly encouraged to take advantage of these opportunities to participate in these Account reviews. If you do not participate in your Account review, we may, in our discretion, terminate your Account from the Program. In addition, on a periodic basis, you are instructed, in writing, to provide us with current information regarding your Account. This would include changes in your financial situation or investment objectives, or if you would like to impose any reasonable restrictions or reasonably modify any existing restrictions. If the changes provided are material in nature, a review of your Account may be in order. As described in the section “Reasonable Investment Restrictions”, you may impose reasonable investment restrictions on your Account or modify any existing restrictions, but you must communicate such restrictions directly to your Investment Manager. You should understand that your Investment Manager, not Merrill, will be responsible for complying with your restrictions, if any, and we and your Financial Advisor shall not be responsible for implementing or monitoring your restrictions. Certain of our materials, including this Brochure, are compatible with various types of assistive devices, such as screen readers. Other program materials have varying degrees of compatibility with different assistive devices. If you experience difficulty in accessing a program document with an assistive device, please inform a Financial Advisor and request that the document be made accessible. When we act as custodian, you will receive an account statement in any month in which there is trading or other activity (or in any event quarterly). If you decide to use a custodian other than us, your custodian or trust company must provide periodic custodial or trust reports and settlement instructions to us (or our designee). We are not responsible for the accuracy of these statements and will rely upon the data and other information presented therein or in other reports provided to us by your custodian to prepare Performance Reports for you. You may also receive reports directly from your selected Investment Manager. As you direct in the Client Agreement or other writing, you may elect not to receive confirmation of transactions for your Account(s) on a trade-by-trade basis, except as required by rule or regulation, and, in lieu thereof, receive a periodic statement that will be furnished to you not less frequently than quarterly and that will contain the same information that would be included in the trade-by-trade confirmation for each transaction. Your election to receive periodic statements in lieu of trade-by-trade confirmations is entirely optional and will not affect the calculation of or amount of your MAS Fee; is not a condition to entering into or continuing participation in MAS and may be rescinded at any time by written notice to us with respect to your Account. We will send confirmations for transactions effected in your Account (or information contained therein) to you and your Investment Manager, as applicable. 44 MAS2A 0325Merrill Lynch Managed Account Service Brochure You may request, and we will provide to you at no additional cost, an interim update and further details concerning any transaction effected between periodic statements either by calling your Financial Advisor or, where you are enrolled in MyMerrill, by checking your account on MyMerrill. If you elect to receive periodic statements in lieu of trade-by-trade confirmations, you may later choose to receive, and we will provide to you at no additional cost, any confirmations for transactions effected for up to a one-year period preceding your last periodic statement and trade-by-trade confirmations for all subsequent transactions. CLIENT REFERRALS AND OTHER COMPENSATION Our Financial Advisors are not permitted to give to you or accept from you any fee, kickback, or other thing of value, including a MAS Fee Rate reduction, gifts, meals, or entertainment pursuant to any agreement or understanding, oral or otherwise, for receiving or referring business. We have entered or may enter into marketing arrangements with third parties who, for compensation, will provide certain services to us in connection with the marketing of our various advisory services for referring prospective clients to us. Each such marketing arrangement is or will be governed by a written agreement between us and the applicable third party, and will be disclosed to you, as required by law. We have entered into solicitation arrangements with certain third-party entities to refer prospective clients to us (“Solicitors”). Generally, the fees paid to Solicitors will be paid from investment advisory fees received and retained by us relating to your Account. This fee will generally be a percentage of the investment advisory fee ordinarily credited to your Financial Advisor for the applicable account. We will pay this fee to the Solicitor from the date you establish an account in the applicable program for as long as your account remains enrolled in MAS and the agreement between us and the Solicitor is effective. If we terminate the agreement with the Solicitor for certain reasons, we may continue to pay the Solicitor for a period of time after termination. We will not increase the fees you pay as a result of our payments to the Solicitor. The fees we charge will not be higher than our usual fees because of the payments to the Solicitor. Our employees may refer advisory clients to BANA and other affiliates for products and services. Similarly, employees of BANA and its affiliates may refer clients to us for brokerage or advisory services. These referrals may involve the payment of referral fees between Merrill and BANA or its affiliates. FINANCIAL INFORMATION Not applicable because (1) Merrill is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act (2) Merrill does not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (3) there is no financial condition of which we are aware that is reasonably likely to impair Merrill’s ability to meet contractual commitments. 45 MAS2A 0325Merrill Lynch Managed Account Service Brochure GLOSSARY “Account or “MAS Account” means each of the client’s securities accounts to which the Client Agreement applies and is managed by a single Investment Manager. “ADR” means American Depositary Receipt, which is a receipt for shares of a foreign company held by a U.S. financial institution that entitles you to rights and obligations of the underlying shares, including dividends and capital gains and losses. “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Affiliate” means a company that is controlled by, in control of, or under common control with, another company. “Affiliated Custodian” means an Affiliate of Merrill that provides custodial services. “AIPS” means the Merrill Automated Investment Program. “BANA” means Bank of America, N.A. “Bank Affiliate” means one or more bank depository institutions affiliated with Merrill. “Bank of America” or “BofA Corp.” means Bank of America Corporation, the parent company of MLPF&S, MAA and other Affiliates. “BofAS” means Bank of America Securities, Inc. “Brochure” means the Merrill wrap fee program brochure relating to MAS, as amended or updated from time to time. “Cash Sweep Program” means the program associated with your securities account whereby cash balances in your Account are automatically swept into a cash sweep vehicle in accordance with the terms of the program for your Account. “CIO” means the Chief Investment Office of MLPF&S. For certain managed strategies, CIO refers to the Chief Investment Office of BANA. “Client Agreement” means the agreement relating to MAS between the client and Merrill, as it may be amended from time to time. “Code of Ethics” means the Merrill Investment Adviser Code of Ethics. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. “ERISA Plan” means a plan subject to the fiduciary responsibility provisions of ERISA or any other entity deemed to hold assets of such a plan, including SIMPLE, SEP and other IRAs subject to ERISA’s fiduciary responsibility provisions. “ETF” means an exchange-traded fund. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “FDIC” means the Federal Deposit Insurance Corporation. “Financial Advisor” means the Merrill Financial Advisor who provides non-discretionary investment advice to the client in MAS. “Funds” means registered and unregistered investment companies, including mutual funds, closed-end funds, ETFs, exchange traded notes, Alternative Investment Funds, real estate investment trusts and other pooled investment vehicles. “Investment Company Act” means the Investment Company Act of 1940, as amended. “Investment Manager” means an investment adviser that is registered with the SEC or one or more state regulatory authorities, or which is exempt from the registration requirement. “Investment Manager” includes a Related Manager. “Investment Manager Fee” means the advisory fee that you pay the Investment Manager. “Legacy Managers” means Investment Managers that participated in a Previous Program. “Margin Agreement” means account documentation executed at account opening relating to the use of margin in your Account. “MLIAP” means the Merrill Lynch Investment Advisory Program. “Options and Margin Strategies” means those Strategies where the Investment Manager may employ margin, write uncovered options and/or sell securities short. “Program” means the Merrill Lynch Managed Account Service. “Previous Program” means a program or service sponsored by Merrill in which a Legacy Manager generally no longer participates because (i) the Legacy Manager removed itself from the program or service, (ii) Merrill removed the Legacy Manager from the program or service, or (iii) the program or service was itself terminated by Merrill and the Legacy Manager was not added to the roster of another Merrill service or program. “Referral-Arrangement Managers” are Investment Managers that compensate Merrill for referrals of clients. “REIT” means a real estate investment trust. “Related Company” means a company that is an Affiliate of Merrill or in which Merrill or an Affiliate of Merrill has a material ownership interest. “Related Fund” means a Fund sponsored, managed, or advised by Merrill or a Related Company. “Related Manager” means an Investment Manager that is a Related Company. 46 MAS2A 0325Merrill Lynch Managed Account Service Brochure “Retirement Account” means an ERISA Plan, a U.S. tax-qualified plan of self-employed persons, a U.S. individual retirement account, or any other plan, arrangement or entity subject to Section 4975 of the U.S. Internal Revenue Code of 1986, as amended. “Rule 12b-1 fees” means fees paid pursuant to a plan adopted under Rule 12b-1 under the Investment Company Act. “Sales Charges” means commissions, markups/markdowns, up-front sales charges and other sales charges or fees paid in connection with brokerage transactions. “SEC” means the U.S. Securities and Exchange Commission. “Securities Act” means the Securities Act of 1933, as amended. “Selling Broker Compensation” means commissions, markups, or markdowns, asset-based or subscription fees, mutual fund sales loads, Rule 12b-1 fees or other remuneration as may be described in the applicable confirmations, prospectuses, subscription agreements, or other offering documents. “SIPC” means Securities Investor Protection Corporation “SPA” means the Merrill Lynch Strategic Portfolio Advisor® Service. “Strategy” means one or more investment styles or disciplines or combinations of investment styles and disciplines offered by Investment Managers. “Unaffiliated Trade Counterparty” means a bank, broker or dealer other than Merrill or a Related Company. “Unrelated Custodian” means a custodian that is neither Merrill nor its Affiliate. Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. © 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated Printed in the U.S.A. 47 MAS2A 0325Merrill Lynch Managed Account Service Brochure

MERRILL EDGE ADVISORY ACCOUNT PROGRAM WRAP FEE PROGRAM BROCHURE Please retain for your records Managed Account Advisors LLC 101 Hudson Street Jersey City, NJ 07302 201.557.0504 Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 800.637.7455 www.ml.com This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and Managed Account Advisors LLC (“MAA”) relating to the Merrill Edge Advisory Account Program (the “Program”). If you have any questions about the contents of this Brochure, please contact us at 800.MERRILL (637.7455). Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about MAA and MLPF&S also is available on the SEC’s website at adviserinfo.sec.gov. The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (FDIC) or any other government agency; are not a deposit or other obligation of or guaranteed by MLPF&S, MAA or Bank of America Corporation (BofA Corp.) or any of its affiliates and are subject to investment risks, including possible loss of principal. March 21, 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as “MLPF&S” or “Merrill”) makes available certain investment products sponsored, managed, distributed or provided by companies that are affiliates of Bank of America Corporation (BofA Corp). MLPF&S is a registered broker-dealer, Member SIPC and a wholly owned subsidiary of BofA Corp. Investment products: Are Not FDIC Insured May Lose Value Are Not Bank Guaranteed Are Not Insured by Any Federal Government Agency Are Not Deposits Are Not a Condition to Any Banking Service or Activity MESPB 032025  ITEM 2. MATERIAL CHANGES On March 22, 2024, MLPF&S and MAA together filed their last annual update for its Merrill Edge Advisory Account program brochure (“Brochure”). The summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. It also sets forth changes as well as enhancements made in this annual update as well as those made since the 2024 annual update, which were previously communicated. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated Item 9 “Additional Information” at the heading “Disciplinary Information” to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our financial advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Item 9 Compensation, Conflicts of Interest and Material Relationships—Third-Party Firm Business Relationships and Support.” • We have updated our disclosures throughout the Brochure to make other enhancements. MATERIAL CHANGES AND ENHANCEMENTS MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes and Enhancements • We updated “Item 9 Additional Information” at the heading “Disciplinary Information” to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” • We have updated our disclosures throughout the Brochure to make other enhancements. Merrill Edge Advisory Account Program | 2 MESPB 032025 ITEM 3. TABLE OF CONTENTS ITEM 4. SERVICES, FEES AND COMPENSATION . . . . . . . . . . . 4 About Us and The Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Advice and Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Profiling and Creating a Target Asset Allocation . . . . . . . . . . . . . . . . . . . 4 Target Asset Allocation Categories and Monitoring . . . . . . . . . . . . . . . . 5 Multi-Account Portfolios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Program Guidelines. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Treatment of Cash Balances in your Account . . . . . . . . . . . . . . . . . . . . . . 5 Investment Strategy Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Selecting a Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Replacing a Strategy or Fund in a Strategy . . . . . . . . . . . . . . . . . . . . . . . 7 Registered Fund Prospectus Delivery . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Role of MAA and Investment and Trading Authority for Strategies . . . 7 Available Information Regarding Strategies and Funds. . . . . . . . . . 17 Advisory Services Provided by Merrill and Certain Affiliates. . . . . 17 Tailored Investment Advice. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Performance-Based Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Method of Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Voting Client Securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Investment Strategies and Risk of Loss . . . . . . . . . . . . . . . . . . . . . . . . 17 General Risks of Investing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Target Asset Allocation and Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . 18 Securities-Based Lending with your Account . . . . . . . . . . . . . . . . . . . . . 18 Use of Strategies Where Merrill Is the Manager . . . . . . . . . . . . . . . . . . 18 Role of a Program Advisor in the Program . . . . . . . . . . . . . . . . . . . . . . . 18 Information and Cyber Security Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 ESG themed Strategies or Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Funds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Reasonable Investment Restrictions . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Brokerage, Banking-Related and Custodial Arrangements and Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Brokerage Trading Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Margin Rules, Margin Loans and Securities Based Lending Programs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Cash Sweep Program and Other Banking-Related Services . . . . . . . . . . 9 Custodial Arrangements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 ITEM 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 ITEM 8. CLIENT CONTACT WITH PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 ITEM 9. ADDITIONAL INFORMATION. . . . . . . . . . . . . . . . . . . . . . 20 Disciplinary Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Other Financial Industry Activities and Affiliations. . . . . . . . . . . . . . 21 Conflicts of Interest and Information Walls. . . . . . . . . . . . . . . . . . . . . 21 Code of Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Compensation, Conflicts of Interest and Material Relationships . . 22 Proxy Voting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Account Preferences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Delivery of Trade Confirmations on a Periodic Basis. . . . . . . . . . . . . . . 10 Delivery of Certain Materials. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Electronic Delivery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Program Fee and Other Charges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Calculation of Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Deduction of Program Fees from Your Account . . . . . . . . . . . . . . . . . . . 11 Determination of how the Program Fee is Charged . . . . . . . . . . . . . . . 11 Fees and Expenses Not Covered by the Program Fee . . . . . . . . . . . . . . 11 Compensation and Benefits to Merrill, Program Advisors and Merrill Management Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Account and Program Choice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Variable Compensation by Product and Service . . . . . . . . . . . . . . . . . . . 23 Offering of Investments or Programs Managed by Us or Our Affiliates and Use of a Related Strategy in Your Account. . . . . 23 Compensation Received by Us for Sub-accounting Services . . . . . . . . 24 Mutual Fund Arrangements and Compensation . . . . . . . . . . . . . . . . . . . 24 Cash Sweep Program Compensation Received by Us and Our Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Other Compensation Received by Us and Our Affiliates. . . . . . . . . . . . 25 Compensation Received by Us and Our Affiliates for Principal Trading and Agency Cross Transactions . . . . . . . . . . . . . . . . . . . . . . . 25 Third-Party Firm Business Relationships and Support . . . . . . . . . . . . . 25 Provision of Diversified Financial Services by Us and Our Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Ability to Obtain Certain Services Separately and for Different Fees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Funding and Operation of Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Opening a Program Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Funding Your Account and Contributions . . . . . . . . . . . . . . . . . . . . . . . . 13 Special Note about Funding Your Account with Mutual Fund Shares . . 13 Withdrawals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Service Changes or Additions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Terminating Enrollment in the Program . . . . . . . . . . . . . . . . . . . . . . . . . 14 Cash Balances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Legal Matters and Related Notifications. . . . . . . . . . . . . . . . . . . . . . . . . 14 Your Responsibilities for Account Operation and Management. . . . . . 14 Tax Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Participation or Interest in Client Transactions and Conflicts of Interest. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Cash Balances and Cash Sweep Program . . . . . . . . . . . . . . . . . . . . . . . . 27 Participation in Affiliate Lending Programs and Margin . . . . . . . . . . . . 27 Activity by Merrill, Affiliates and Personnel . . . . . . . . . . . . . . . . . . . . . . 27 Trade Execution. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Covered Entities under the Volcker Rule . . . . . . . . . . . . . . . . . . . . . . . . . 28 Account Reviews and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Referrals and other Arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Financial Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 GLOSSARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 ITEM 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Client Eligibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Program Minimum . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Retirement Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ITEM 6. PORTFOLIO MANAGER SELECTION AND EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Selection and Review of Strategies and Funds Available in the Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Strategy Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 All capitalized terms used in the Brochure are defined in the body of this Brochure or in the Glossary. Merrill Edge Advisory Account Program | 3 MESPB 032025 Item 4. Services, Fees and Compensation ABOUT US AND THE PROGRAM This Brochure describes the Merrill Edge Advisory Account Program (the “Program”). Both Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and its Affiliate, Managed Account Advisors LLC (“MAA”), offer investment advisory services under the Program as discussed in this Form ADV brochure (“Brochure”). Both MLPF&S and MAA are registered with the U.S. Securities and Exchange Commission (“SEC”) as investment advisers and MLPF&S is registered as a broker dealer. Both Merrill and MAA provide services under the Program in our capacity as a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Our parent company, Bank of America Corporation (“BofA Corp.”) through Bank of America, N.A. (“BANA”), BofA Securities, Inc. (“BofAS”) and other of its Affiliates, provides integrated investment services and is a leading banking institution for consumers, corporations and institutions. When we use the terms “Merrill,” “we,” “our” or “us” in this Brochure, we are generally referring to MLPF&S. We also use the terms “Merrill,” “we,” “our” or “us” to apply to both MLPF&S and MAA for those aspects and services of the Program that MLPF&S and MAA perform jointly. We also indicate where certain services are provided by MAA in its separate capacity. Our Services as an Investment Adviser and Relationship with You under the Program. The Program is designed to help you pursue your investment goals by providing you with investment advice and guidance and access to a select set of investment solutions and our representatives. For Program services, you will work with our Merrill representatives who have the title or designation “Financial Solutions Advisor” (“FSA”) and who are available to you through our call center and at various bank branch locations. You will work with a Program Advisor to establish an appropriate target asset allocation for your enrolled Account, to select an aligned investment strategy available in the Program and to receive the other services described in this Brochure (“Services” or “Program Services”). In this Brochure, we use the term “Program Advisor” to refer to an FSA. We provide disclosure documents called the “Form ADV Part 2B—Brochure Supplements,” which describe information about Program Advisors and the role and the services they provide, among other things. We also provide Form ADV Part 2B-Brochure Supplements for other Merrill investment professionals who provide portfolio management services for the investment strategies we offer in your Program enrollment materials. To obtain the Services available through the Program, you must first enter into a written agreement with us (the “Client Agreement” or “Agreement”). The Client Agreement defines the scope of the investment advisory relationship with you and sets forth our obligations to you for accounts that you enroll in the Program (“Account”). This Brochure describes the advisory services that we provide, the fees you will pay, our role and that of our personnel, our other business activities and financial industry affiliations and the economic and other benefits and arrangements we have that create conflicts of interest in certain situations. You will be provided a Program Report and account statements that identify those of your Accounts enrolled in the Program. Termination of an Account’s enrollment in the Program will end that investment advisory fiduciary relationship with respect to that Account and will cause that account to be converted to, and designated as, a Merrill brokerage account. If you inform us that you wish to terminate the Agreement, we will terminate the Program enrollment of all Accounts which will end the investment adviser fiduciary relationship and such Accounts will be converted to brokerage accounts. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in our Client Relationship Summary on Form CRS (“Form CRS”) and in our Summary of Programs and Services, both of which are available at merrilledge. com/relationships or upon request. In addition, these documents provide a summary of the other available investment advisory programs we offer. Certain aspects of these investment advisory programs are similar to the Services available in the Program. Please refer to “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Under the Program, we are a fiduciary to you. Merrill and MAA each have certain fiduciary obligations to you in providing you the Services under the Program. As a fiduciary, we will act in your best interest and will endeavor to ensure that you are informed about and have access to material facts and information relating to the Program Services. This Brochure is a key element in meeting this disclosure obligation. The fiduciary standards we aim to follow are established under the Advisers Act and state laws, where applicable. In addition, for Retirement Accounts, we provide these Program services as a “fiduciary” under Section 3(21) of the Employee Retirement Income Security Act of 1974 (“ERISA”) and under the Internal Revenue Code of 1986 (the “Code”). For Retirement Accounts subject to ERISA, we provide the relevant Services as an “investment manager” under Section 3(38) of ERISA. Generally, the Program is designed for clients who are comfortable with the investment choice of a limited set of investment strategies complementary to their investment profile. The Program is generally not for clients who have more complex needs, desire access to a larger offering of investment solutions and strategies or have a preference for frequent in-person interactions with a dedicated advisor. While enrolled in the Program, your Account’s assets can be allocated to cash at various amounts for one or more investment and/or operational purposes at the same or different times as described throughout this Brochure. The Program is similar to the MGI with Advisor program, which provides enrolled clients with the ability to work with a Program Advisor through an interactive website. There are certain services and investment strategies that are only available in the MGI with Advisor Program and not the Program. ADVICE AND GUIDANCE Profiling and Creating a Target Asset Allocation. A Program Advisor will work with you to establish a recommended target asset allocation described below. To do so, a Program Advisor will gather from you, and/or confirm with you, important financial and personal information that will be used as a basis for our advice and guidance about your Account. Based on information you provide, your Program Advisor will recommend an allocation of your assets across one or more asset classes (the “Target Asset Allocation”) for each of your Accounts, taking into account: your risk tolerance for the Account (i.e., your ability and willingness to incur financial loss for some or all the assets in your Account in exchange for greater potential returns) and (2) the time horizon (determined by how long you expect to invest in order to achieve your investment goal). At Merrill, risk tolerance is expressed in three gradations: Conservative, Moderate and Aggressive and time horizon segmented into the time spans of 0–1 Years, 1–5 Years, 5–10 Years, and 10+ Years. For an Account with a retirement focus, the time horizon is based on a combination of your stated retirement age and how long you intend to use the assets in your Account aſter retirement. Any changes to your risk tolerance or time horizon for your Account may lead to a different recommended Target Asset Allocation and potential changes to the strategy for an Account. Your Merrill Edge Advisory Account Program | 4 MESPB 032025 Program Advisor will use your risk tolerance and time horizon, along with other information about you, including your investment objectives, goals, liquidity and preferences, to determine the strategies to recommend to you for your Account. It is your responsibility to ensure that the information you provide to a Program Advisor is complete and accurate and to notify a Program Advisor if any information we have about you is inaccurate or becomes inaccurate. By providing accurate and complete information, a Program Advisor will be better able to make suitable recommendations for you and your assets. This information helps determine whether this Program is, and continues to be, appropriate in light of your preferences and objectives. Your continued enrollment in the Program indicates your willingness and preferences to receive ongoing investment advice and guidance with respect to your Account, continued access to investment solutions, ongoing investment monitoring and other fiduciary services under the Program. Target Asset Allocation Categories and Monitoring. In general, the Target Asset Allocation categories, which have associated asset class allocation ranges are: (1) Conservative, (2) Moderately Conservative, (3) Moderate, (4) Moderately Aggressive and (5) Aggressive. A description of each of these categories is in the Glossary under the term “Target Asset Allocation.” There may be additional Target Asset Allocation categories added by us from time to time. Each of these categories have associated asset class allocation ranges. The associated allocation ranges and our method of monitoring activity may change from time to time and without prior notice to you. Our more conservative Target Asset Allocations typically recommend a greater percentage of your assets be allocated to the fixed income and cash asset classes, rather than to the equity asset class. Our more aggressive Target Asset Allocations typically recommend a greater percentage of your assets be allocated to the equity and alternative investment asset classes, rather than to the fixed income and cash asset classes. You should carefully consider the recommended Target Asset Allocation for your Account. You may choose a Target Asset Allocation that is more conservative than our recommendation by speaking with a Program Advisor. If you would like a more aggressive Target Asset Allocation, you must discuss with a Program Advisor whether certain information that we have about your Account accurately reflects how you want your assets managed, and a Program Advisor may recommend that you adjust your Account risk tolerance and/or time horizon to reflect your preference for a more aggressive Target Asset Allocation. We will use your Target Asset Allocation, along with certain other information provided by you, to assist in recommending an investment strategy for your Account. The Account will be managed according to the investment strategy that you select. We make available in the Program a select set of investment strategies (the “Strategies”) that are managed by Merrill through its Chief Investment Office (the “CIO”). The Strategies consist of diversified portfolios of exchange-traded funds (“ETFs”), mutual funds and an allocation to cash and/or money market mutual funds and other cash alternatives (referred to as a “cash allocation”) that are designed to meet a particular Target Asset Allocation. The CIO has discretion to select a money market mutual fund (“money market fund”) or other cash alternative available through the Program for a Strategy’s cash allocation. ETFs, mutual funds and money market funds are referred to collectively as “Funds”. The Strategy recommendations provided for each Account are intended to align with the specified Target Asset Allocation for the Account. At times your Account’s actual asset allocation may become misaligned with the Strategy allocation due to market movements or additions and withdrawals of assets from your Account, among other reasons. On a periodic basis, we will monitor the assets in each Account to the applicable Target Asset Allocation within certain parameters. Because your Account’s Target Asset Allocation is based on your Account risk tolerance and your Account time horizon, changes to these factors may result in a different recommended Target Asset Allocation and/or Strategy. In addition, keep in mind that the time horizon for your Account will change (become smaller) as time passes, and the Target Asset Allocation will change over time (except if your Account already has a recommended Target Asset Allocation of Conservative). If there is a prolonged misalignment, we will ask you to take action in order to remain in the Program, including updating your risk tolerance or time horizon, so that the Account meets the Program guidelines. If you decide not to take the requested action, we reserve the right to terminate your Account from the Program, which converts the Account to a brokerage account type. Multi-Account Portfolios. In our discretion, you will have the flexibility to direct us to manage multiple Accounts, each with a different Strategy, in a single portfolio (“Portfolio”). Your Portfolio assets in the aggregate should be aligned to the applicable Target Asset Allocation for the Portfolio. The Portfolio Target Asset Allocation applies to the assets held in the Portfolio. Because the Target Asset Allocation is determined at the Portfolio level, you should understand that each Account and the Funds held in each particular Account must be evaluated in the context of the overall Portfolio. The Accounts, Funds and other investment solutions that comprise a Portfolio will not necessarily be consistent with your Portfolio’s designated risk tolerance and/or time horizon if they are evaluated on an Account-level basis. Monitoring activity may change from time to time and without prior notice to you. Program Guidelines. We have established certain guidelines relating to the management of assets in the Program, including Target Asset Allocation guidelines, which are designed to help supervise and monitor on an on-going basis the activity in your Account. The Program guidelines change at our discretion or can be waived under certain circumstances for certain clients. In certain situations, you will be notified if your investment activity or holdings deviate from these internal guidelines and action may be required to comply with these guidelines. If you decide not to take the requested action, we have the right to terminate the Account from the Program. Taking this action will convert the Account to a brokerage or other account type. Our supervision and monitoring do not substitute for your own continued review of your assets and the performance of your investments in your Account. You are responsible for reviewing the Program communications, including performance reports, trade confirmations, periodic account statements that we send to you. If you identify any discrepancies or inaccurate information, you should promptly report them to a Program Advisor. In most instances it is solely your responsibility to determine whether you follow our recommendations. If you choose to invest your assets in a manner that differs materially from our recommendations, you may assume additional risks that result from your decisions. Treatment of Cash Balances in your Account. While enrolled in the Program and subject to Program guidelines, your Account will have an allocation to cash balances. This allocation can result from our decision to keep a cash balance for various purposes, such as your cash needs, market conditions or as a way to fulfill your cash allocation target. This allocation can also result from the decision of the CIO, as investment manager of the Strategy’s model portfolio selected for your Account, to keep a cash balance for operational and/or investment purposes as part of the Strategy. The cash allocation for the Strategy is based on a number of factors, including the nature of the investment strategy being implemented, the types of investments being purchased for the Strategy and the circumstances relating to the trading for those securities, market conditions as well as for trade execution facilitation, meeting operational contingencies and having funds available to pay the monthly fee charged for Program Services without generating trade activity in the Account. In certain circumstances, including periods of volatile or uncertain market conditions, any cash allocation may comprise all or a substantial portion of your Account assets based on, for example, concerns about the market or a decision to pursue a defensive investment strategy. Merrill Edge Advisory Account Program | 5 MESPB 032025 Your Account’s uninvested cash balance is automatically swept with your consent to a cash sweep option for your Account under the terms of your underlying brokerage account agreement (“Cash Sweep Program”). The available automatic cash sweep options under the Cash Sweep Program vary based on the Merrill account type and other criteria. Not all Merrill account types have the same cash sweep option. The only automatic cash sweep options currently available for Merrill account types eligible for enrollment in the Program are the Merrill Lynch Bank Deposit Program (“MLBD Program”) and, for retirement accounts, the Retirement Asset Savings Program (“RASP”). These programs provide for an automatic sweep of cash balances to bank deposits with BANA and other banks affiliated with us (“Bank Affiliates”). Please refer to your account agreement and related disclosures for additional information regarding the automatic cash sweep options for your type of Account. The Sweep Program Guide for Merrill Clients provides an overview of the automatic cash sweep options and how they work and a chart of automatic cash sweep options by Merrill account type. The current rates and yields for the cash sweep options are available at mymerrill.com and from us or a Program Advisor. Your cash balance and cash alternatives in your Account are subject to the Program Fee. You can elect to hold any cash balances in an account that is not enrolled in the Program (i.e., a brokerage account or bank account), and avoid the Program Fee, but you will not receive the Program Services with respect to cash held in an account that is not enrolled in the Program. We discuss the treatment of cash balances and other considerations relating to cash in various parts of this Brochure, including: (1) Item 4 at the sections “Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services,” “Program Fee and Other Charges—Determination of how the Program Fee is Charged,” “Program Fee and Other Charges—Fees and Expenses Not Covered by the Program Fee,” and “Funding and Operation of Accounts—Cash Balances” and (2) Item 9 at the sections “Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Participation or Interest in Client Transactions and Conflicts of Interest—Cash Balances and Cash Sweep Program.” INVESTMENT STRATEGY SERVICES Selecting a Strategy. Aſter we help you establish a Target Asset Allocation for your Account, a Program Advisor will recommend to you one or more Strategies available in the Program. There may be more than one Strategy that is suitable for your investment needs. Our recommendation will be based on the information you provide and what we believe will meet your investment needs and investment preferences for the management of your assets. The recommendation is limited by the stated and agreed-upon Target Asset Allocation for the Account, the Strategy, other applicable factors such as the type of Account you establish and any Account restrictions. Merrill determines which Strategies are included in the Program and when they will no longer be offered. As a general matter, we make these decisions based on a variety of factors, including client needs, available investment styles, platform capacity, client demand and the outcome of due diligence and evaluations reviews including with the assistance of the CIO. The Strategies used in the Program are designed to obtain exposure to the various asset classes of the Target Asset Allocations. A Strategy is constructed and/or implemented by Merrill in a single Account. The Strategies available in the Program are model portfolios of securities managed by the CIO to achieve one or more investment styles or disciplines. The Strategies are also rebalanced as needed based on CIO recommendations. See “Item 6 Portfolio Manager Selection and Evaluation.” The Strategies consists of ETFs and mutual funds, and cash and/or cash alternatives (referred to as a “cash allocation”). In addition to determining asset class level allocations and rebalancing frequencies, the CIO determines the ETFs and mutual funds for the equity and fixed income asset class exposures. A Strategy includes a cash allocation for operational and implementation and/or investment purposes as directed by the CIO. For the cash allocation, CIO determines whether to hold a cash balance and/or invest in a money market fund or other cash alternatives available for your Account through the Program. If no action is taken by the CIO to select a cash alternative, cash balances will automatically be swept under the Cash Sweep Program. The cash allocation will be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations, rebalancings, market conditions and the CIO’s cash management approach and market view and concerns. For more information, see the section “Funding and Operation of Accounts—Cash Balances.” Merrill, through the CIO, provides its investment recommendations relating to the Strategies to MAA in the form of model portfolios and investment guidelines and instructions (a “model-based Strategy”). MAA will generally implement the recommendations without change, subject to the application of any Reasonable Investment Restrictions (as defined below) which MAA has determined to accept as reasonable, cash commitments and other operational or investment considerations, including the frequency of rebalancing. MAA may determine, in light of operational or investment considerations in its sole discretion, to deviate from the model portfolio on a limited basis (i.e., to select another security or increase the cash allocation within a model portfolio). By selecting a model-based Strategy, as provided in the Agreement, you grant MAA investment discretion and trading authority for investments occurring in that Strategy. Through its trading authority, MAA has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. This authority will remain in place until we have received and accepted instructions to either change to a different available Strategy in the Program or terminate the Account from the Program. We make available information about each Strategy in a document known as a “Profile.” The Profile describes the relevant objectives, styles and risks of the particular Strategy. The Profile includes performance history and data as indicated in the Profile that consists of actual composite performance data developed by MAA in its implementation of the Strategy. The Strategy in which your Account is invested will be reflected in the Program Report that we will deliver to you upon enrollment. We may reference the Strategy or use the term “Managed Strategy” as a caption name or reference in the Program Report. You select the Strategy for your Account. This means that any change from one Strategy to another Strategy will require your consent, because you retain the Authority to select and implement any changes between Strategies. As we describe in detail below in the section “Role of MAA and Investment and Trading Authority for Strategies,” we will have full investment discretion and trading authority to implement the Strategy selected. In certain circumstances, the same or similar investment solution offered in the Program may be offered through other investment advisory programs or services sponsored by Merrill or our Affiliate channels, at a lower or higher than, or same cost as, the investment solution offered in this Program. The services that you receive by investing in such a solution through a different program, may or may not be similar to the services you receive through Merrill Edge Advisory Account Program | 6 MESPB 032025 the Program. You should discuss with a Program Advisor the investment solutions, services and Strategies available to determine which may be most appropriate. Please refer to the section “Ability to Obtain Certain Services Separately and for Different Fees.” Replacing a Strategy or Fund in a Strategy. Merrill has the authority to select the Strategies in the Program and to replace a Strategy with prior notice to you. It also has the authority to select the Funds in the Strategies and to change the included Funds without notice to you. Changes to a previously selected Strategy may be made in the following ways: (1) your instruction to replace a Strategy or (2) Merrill closing a Strategy from the Program for any reason. Where Merrill decides to close a Strategy to new investments and/or additional contributions from existing clients, in such event, Merrill may: • Replace the identified Strategy with another Strategy. • Maintain current positions in the identified Strategy and invest any new contributions and sale or redemption proceeds in a replacement Strategy. • Maintain in cash any new contributions or sale or redemption proceeds relating to the identified Strategy in cash until a replacement is chosen by us or you direct us to invest in an alternative Strategy selected by you. MAA is responsible for implementing our decisions and related actions. If we determine to replace the identified Strategy, we will endeavor to choose a replacement with an investment strategy that is managed in a manner consistent with your investment objective and goals for the Account. This replacement may include Funds with higher expenses than you had been paying. If you do not instruct us to the contrary, your continued participation in the Program after receiving written notice of such replacement or other action will be your consent to the action. If you do not agree with the replacement Strategy, you can terminate the Account from the Program. We generally will provide you with prior written notice of any discontinuation, closing or replacement event prior to it taking place. We, however, may provide you with notice of such event after we have already taken action in certain circumstances. Having the flexibility to act quickly helps enable us to take action where we believe the replacement and its timing are in clients’ best interest. Registered Fund Prospectus Delivery. When a fund that is registered under the Investment Company Act of 1940, as amended (a “Registered Fund”) is purchased for an Account that has selected the Strategy, in light of the discretionary authority you have granted to either Merrill or MAA, either of us are authorized to receive the Registered Fund prospectus in lieu of it being automatically delivered to you. If you would like a copy of the Registered Fund prospectus, you may obtain one by contacting a Program Advisor who will arrange for it to be sent to you free of charge. Notwithstanding the foregoing, Merrill may continue to send the Registered Fund prospectus to you in its sole discretion. Role of MAA and Investment and Trading Authority for Strategies. As described above, MAA has authority to make certain investment and trading decisions including: • Implementing, as applicable, the model-based recommendations or other investment guidelines and/or instructions of the CIO. • Processing all contributions including initial and any subsequent cash deposited in the Account, withdrawal requests and Account terminations. • Periodically rebalancing the Account as further described below. • Implementing your Reasonable Investment Restrictions, if any, described in the section “Reasonable Investment Restrictions.” • Implementing your tax-selling instructions (if any) where acceptable to MAA, as further described in the section “Tax Matters.” Merrill and MAA are authorized and directed by you to sell promptly any investments you contribute that are not eligible or not acceptable for a Program Service or a Strategy. Certain Strategies have target allocations and are subject to automatic rebalancing on a periodic basis. Others are dynamically managed and are not subject to periodic rebalancing in the same manner. In light of other considerations in an Account, MAA can effect rebalancing and other transactions even though they may generate tax liabilities, including short-term taxable income. In its discretion, MAA actively manages your Account and may decide not to process certain rebalancing transactions. Delays in the processing of any rebalancing activities that MAA undertakes can occur from time to time, based on, among other things, market conditions, illiquid securities, as well as the availability of Funds and other factors. MAA arranges for trades to be executed through Merrill or a Merrill Affiliate and may arrange for trades to be executed through a broker or dealer other than Merrill or a Merrill Affiliate (an “Unaffiliated Trade Counterparty”). In its discretion and subject to legal requirements, MAA may utilize its Affiliates and third party vendors for investment, trading and administrative support. MAA generally takes necessary actions consistent with implementing a Strategy, including for any investments subject to regulatory limitations and restrictions and related internal policies applicable to us and our Affiliates’ overall investment activities described further in the section “Activity by Merrill, Affiliates and Personnel.” REASONABLE INVESTMENT RESTRICTIONS You may request through a Program Advisor that we impose certain investment restrictions on the management of the assets in your Account relating to the purchase of a specific Fund in the Strategy. For a restriction to be acceptable under the Program, it must first be determined to be “reasonable” by us (a “Reasonable Investment Restriction”). MAA will determine whether a restriction request is reasonable and how to allocate investments based on a Reasonable Investment Restriction. MAA will generally allocate the assets that would have been invested in the security impacted by the Reasonable Investment Restriction in one of the following ways: (1) pro-rata across other investments held in the Account; (2) by using one or more replacement securities, which could include ETFs and/or (3) by remaining uninvested in cash. Please note that Reasonable Investment Restrictions will not apply to securities that are part of a Fund in the Strategy. If accepted, the Reasonable Investment Restriction that MAA is responsible for managing or implementing in your Account will be included in the Program Report or other periodic Program communications and will be applied to your Account until (1) you take action to change, withdraw or waive the restriction; (2) we determine that it is no longer a Reasonable Investment Restriction based on factors we deem relevant in our discretion, including for example, the level of the security holding percentage in the Strategy; or (3) we are no longer able to implement the restriction in our systems, changes in the security identifier or symbol, corporate action events, or otherwise. You may request to have different investment restrictions applicable to each of your Accounts. Merrill Edge Advisory Account Program | 7 MESPB 032025 We reserve the right to modify our practices regarding investment restrictions in our sole discretion at any time without notice. Further, we reserve the right to deem any requested investment restriction to be unreasonable and to not accept the requested investment restriction. If one or more investment restrictions are determined to be unreasonable, the restriction will not be applied and you should consider whether to remain in the Program or consider other more appropriate Strategies in the Program. Implementing certain Reasonable Investment Restriction result in securities in your Account being sold which could result in taxable events. If you elect to impose Reasonable Investment Restrictions, you accept any effect such Reasonable Investment Restrictions may have on the investment performance and diversification of the Strategy or your Account. The performance of an Account with Reasonable Investment Restrictions will differ from and may be lower than the performance of Accounts without such restrictions. In addition, your decision to impose a Reasonable Investment Restriction that alters the allocation of a Strategy or that results in a replacement security may result in exposure to additional (and potentially unforeseeable) risks that are inconsistent with the objective of your investment strategy. In addition, investment restrictions or any other limitations provided by you will not apply to the securities or other interests held in the portfolio of any Fund in your Accounts, even if the Fund provides public disclosure of the holdings within its portfolio; consequently, your ability to restrict investments in the Program will be limited. The termination or removal of an Account from the Program will terminate Reasonable Investment Restrictions for that account, and such Restrictions will not be applicable to the account as a brokerage account or other account outside of the Program. BROKERAGE, BANKING-RELATED AND CUSTODIAL ARRANGEMENTS AND SERVICES You are required to maintain a securities (brokerage) account with MLPF&S. The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance for your Account and access to the Strategies and ongoing monitoring. The Program Fee you pay covers these Program Services and your payment for the trade execution, clearance and settlement services. It also covers custody of assets. Note that certain fees unrelated to investment activity, like fees for banking-related or cash transfer activities, wire transfer fees, foreign currency wire and conversion fees, account service fees, transaction fees and certain transactional costs, are not covered by the Program Fee, including those described as such in the section “Program Fee and Other Charges.” Brokerage Trading Services. In effecting transactions for your assets in the Program, Merrill and its Affiliates will be acting exclusively as a broker- dealer and can arrange for trades to be executed through Merrill or a Merrill Affiliate or through an Unaffiliated Trade Counterparty. If we or one of our Affiliates effect the transaction through an Unaffiliated Trade Counterparty, we will take into account various factors, such as the nature and quantity of the securities involved, the markets involved, the reputation and perceived soundness of the firm, the firm’s clearance and settlement capabilities and other factors relevant to the selection of a broker-dealer for the execution of client securities transactions. Trades will be handled by MLPF&S as broker-dealer and MAA as an investment adviser consistent with their regulatory and best execution obligations. Even with these obligations, it is possible that you may be able to obtain better prices for transactions, if such trades were executed with other broker-dealers or third parties, including having smaller spreads (the difference between the bid and the offer price) or at more favorable net prices. We seek to effect transactions correctly, promptly and in the best interests of clients. In the event an error occurs in our handling of client transactions, we seek to identify and correct any errors as promptly as possible without disadvantaging you. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing you. In general, in instances where we are responsible for effecting the transaction, we may: (i) reimburse you for any losses directly resulting from trade errors; (ii) credit to you any profits directly resulting from such trade errors that are corrected aſter the settlement of the transaction; or (iii) retain for ourselves any profits directly resulting from such trade errors that are corrected prior to the settlement of the transaction. We may, but are not required to, aggregate orders for the sale or purchase of securities for your Strategies with orders for the same security for our other clients, proprietary accounts or the accounts of our employees (including a Program Advisor) and/or Related Companies, without your prior authorization. Where order aggregation is employed, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro-rata share of any fees. MAA’s ability to implement the recommendations of the CIO as to a particular Strategy may be affected by the liquidity of the security, market volatility, and any price limits that may be imposed by Merrill. This may in turn have a negative impact on the performance of a Strategy. In your Client Agreement, you appoint us to act as your agent and attorney-in-fact with such discretionary power and authority to buy, sell or otherwise effect transactions in securities or other property, in whole or in part and in your name for your Accounts. You also authorize and direct us to cause all transactions to be effected through Merrill or our Affiliates acting as agent, or as permitted by law, as principal. Principal transactions are only effected in accordance with Program guidelines and applicable regulations. You, and not we, will bear the cost of markups or markdowns that are not covered by the Program Fee and that are payable to Unaffiliated Trade Counterparties (including on fixed-income or over-the-counter transactions in which MLPF&S and its Affiliates act as agent). Margin Rules, Margin Loans and Securities Based Lending Programs. As a broker-dealer, MLPF&S is responsible for compliance with federal margin rules. Accounts in this Program are only set up as cash Accounts. This account notation means that margin is not permitted and purchases of securities must be fully paid for on the date of the trade. With a cash Account, if securities are sold before the payment for their purchase has settled, an event known as a “free-riding violation” has occurred. Freeriding is prohibited under margin rules and our Program guidelines. Having a “free-riding” violation may result in your Account being restricted for 90 days or “frozen.” The imposition of such a freeze could have a negative effect on your Account and performance. The risk of engaging in an inadvertent “free riding” violation and therefore freezing of your Account is enhanced: (1) when you change Strategies and reconstitute your investments or (2) when you withdraw cash from your Account when there is a pending order to purchase a security. Certain of your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through certain Affiliated loan programs (i.e., the Loan Management Account® and Mortgage 100®/ Parent Power® mortgage programs) or through unaffiliated loan programs (together, “Lending Programs”). The costs, risks and other features and conditions of a loan under the Lending Programs are more fully described in the separate lending documentation you receive in connection with any such loan and are not described in this Brochure. There are risks, costs, and conflicts of interests associated with Lending Programs. The costs, including interest, associated with a loan through any Affiliated Lending Program are not included in the Program Fee and will result in additional compensation to us, our Affiliates, and our financial advisors. The interest charges on any such margin loan or loan Merrill Edge Advisory Account Program | 8 MESPB 032025 combined with the fees charged for Program Services may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. See “Item 6 Investment Strategies and Risk of Loss— Securities-Based Lending with your Account” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Participation in Affiliate Lending Programs and Margin.” Cash Sweep Program and Other Banking-Related Services. As provided in the relevant brokerage account agreement and documents you executed to open your account, unless you elected the “No Sweep” option, you have consented to having cash held in your account being treated as a cash balance and being automatically “swept” on the day following the cash deposit to the cash sweep option applicable to your underlying brokerage account under the Cash Sweep Program. Unless the cash allocation is invested, either in a cash alternative or in other securities, the cash allocation will be treated as a cash balance in the Program Account subject to the automatic sweep functionality. “Bank Deposit” Sweep Option. Under the MLBD Program or RASP, an Account’s cash balance is swept to accounts held at our Bank Affiliates. Under each of the MLBD Program and RASP, Merrill as your agent establishes the bank deposit accounts on your behalf at the Bank Affiliate as provided for in your underlying brokerage account agreements. Bank deposits in the MLBD Program and RASP are insured by the Federal Deposit Insurance Corporation (“FDIC”). Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Certain conditions must be satisfied for deposit insurance coverage to apply when bank deposits are opened on your behalf in the name of Merrill as your agent. Merrill has in place business requirements and practices that are reasonably designed to satisfy those conditions, which include, but are not limited to, proper account titling and recordkeeping. The sweep deposit accounts at the Bank Affiliates in the MLBD Program and RASP are protected by FDIC insurance, up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership category, per bank. FDIC insurance covers both principal and credited interest, up to applicable limits. Any deposits maintained with a Bank Affiliate in the same account ownership category, whether directly, through other Merrill accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If your total cash balances in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of bank product (i.e., a certificate of deposit) of a Bank Affiliate in the MLBD Program or RASP exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Neither Merrill nor the Bank Affiliates manage or monitor the deposits swept under the MLBD Program or the RASP for FDIC insurance limit purposes. Deposits are not aggregated or limited under the MLBD Program and RASP based on the FDIC limits for the same depositor in the same bank across Merrill accounts. Merrill does not undertake through the Program or the Agreement or the underlying brokerage agreement to provide you notice that cash balances in your Account or Accounts or in any of your brokerage accounts exceeds the FDIC coverage limit for any of our Bank Affiliates. Monitoring FDIC insurance coverage limits is expressly not a Program Service. You are responsible for monitoring the total amount of deposits held at the Bank Affiliates in order to determine the extent of FDIC insurance. The agreements and disclosures that you received in connection with establishing your underlying Merrill brokerage account and the Sweep Program Guide for Merrill Clients include additional information about FDIC insurance. A paper copy can be obtained from your Program Advisor. For additional information on FDIC insurance, visit fdic.gov. Cash balances swept under the Cash Sweep Program to a bank deposit account of our Bank Affiliates will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts will be periodically set and reset by the Bank Affiliates in their discretion. The rate is variable and may change at any time after the account is opened without notice or limit. Under the MLBD Program and RASP, interest rates are tiered based upon a client’s relationship with Merrill. Accounts with the MLBD Program and RASP as their cash sweep vehicles that are enrolled in the Program and in other specified Merrill investment advisory programs receive the highest tier rate available under the MLBD Program or RASP. A brokerage account with cash swept into MLBD Program or RASP that enrolls in the Program will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. The interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. “No Sweep” Option. Certain account types have the option for you to select the “No Sweep” option under their underlying brokerage agreement which results in cash being held in the account as a cash balance and not ‘swept’ to any available sweep option under the Cash Sweep Program. The cash balance will not earn interest or dividends. The cash held in the Account will be covered by the Securities Investor Protection Corporation (“SIPC”) up to $500,000 per client, inclusive of $250,000 for cash. As a registered broker-dealer, Merrill benefits from the possession or use of cash balances, also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. Ability to Invest Cash Balances. The CIO as the Style Manager determines whether to hold a cash balance and/or invest in a money market fund or other cash alternatives available for your Account through the Program. If no action is taken by the CIO to select a cash alternative, cash balances will automatically be swept under the Cash Sweep Program. Conflicts of Interest related to the Cash Sweep Program. There are conflicts of interest associated with the Cash Sweep Program which are discussed in “Item 9 Compensation, Conflicts of Interest and Material Relationships— Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” Custodial Arrangements. MLPF&S will act as the custodian for the assets held in the Program. Your assets will be maintained in one or more central asset accounts established at MLPF&S through the applicable securities account. In the Client Agreement, you agreed to open any necessary securities accounts and execute the applicable MLPF&S securities account agreements. If you already have an existing MLPF&S securities account (“existing account”) and instruct us to open a similar type of account for the Program (“new account”), the Client Agreement and related documentation for your existing account will apply to your new account. From time to time, MLPF&S (doing business as Merrill Edge) may offer to clients or potential clients certain promotions or rewards in connection with opening, maintaining or adding assets to an MLPF&S securities account. Such promotions or rewards may include, by way of example, the payment of a cash reward. The promotions may require a client to request to receive or participate in the promotion or reward, and/or require a client to meet various Merrill Edge Advisory Account Program | 9 MESPB 032025 eligibility criteria. While these promotions or rewards may extend to a client’s MLPF&S securities account that holds assets in the Program, participation in the Program is not a condition for these promotions or rewards. Any assets held in the Program must be and remain free from any lien, charge or other encumbrance (other than a lien, charge or other encumbrance in favor of us or our Affiliates), unless we agree otherwise. You must notify us in writing prior to effecting loans secured by securities in the Program (including loans by our Affiliates) (commonly referred to as “collateralizing”). We will not provide advice on or oversee any of your collateral arrangements. Unless we otherwise agree, the terms of the Client Agreement will prevail in the event of any conflict between the terms of the Client Agreement and your collateral arrangements. You must also disclose to any lender the terms of the Client Agreement. No specific securities in your Account should be held as collateral to secure your loan. There are adverse effects of collateralizing an Account, including, but not limited to, the fact that the lending institution may require additional collateral or liquidation of securities to meet a call, as well as the related tax consequences. You must promptly notify us of any default or similar event under your collateral arrangements as defined in the respective collateral arrangements. PROXY VOTING You have the right to vote proxies for securities held in your Account and you will retain proxy voting authority for your Account. You cannot delegate to us and we do not accept or assume any proxy voting authority for securities held in your Account. Since you retain proxy voting authority, we will promptly send you proxy ballots and related shareholder communications that we receive, as well as any other information intended for distribution to you. You are responsible for taking any actions. If your Account is an ERISA Plan, you represent that plan documents and applicable law authorize voting authority to be reserved to the trustee(s) either in the discretion of the trustee(s) or pursuant to the discretion of a named fiduciary. If we do not receive voting instructions from you, we will comply with the rules of the SEC and applicable self-regulatory organizations relating to such matters, as required by law. As a broker dealer, MLPF&S uses a third-party service provider for certain proxy-related functions, including processing and forwarding proxy and other issuer related materials, and receives amounts collected by the vendor for the costs of these services as permitted by applicable securities regulations. ACCOUNT PREFERENCES General. You are able to set certain “Account Preferences” for each of your Accounts in the Program, including Frequency of Trade Confirmation Statements; Electronic Delivery of Certain Materials; and Reasonable Investment Restrictions. You should discuss these Account Preferences with a Program Advisor. You may be asked to complete additional documentation. Delivery of Trade Confirmations on a Periodic Basis. You will receive trade-by-trade confirmation for transactions in your Accounts; however, you may elect to receive transaction information on a periodic basis (at least quarterly) in lieu of trade-by trade confirmations. To receive periodic trade information, you must make an election in your Client Agreement or provide us with a separate written letter of authorization. The election to have periodic delivery of trade information will apply to the eligible Accounts you designate until you instruct us to the contrary. You can rescind this election at any time. Your Program Report will indicate whether you have elected the periodic delivery of trade confirmations option. If you elect to receive trade information on a periodic basis, we will send copies of trade-by-trade confirmation information to you, including through account statements, in accordance with applicable law. Making this election will not result in any change to the Program Fee and is not a condition to receiving the Program Services. You may request to receive, at no additional cost, trade-by-trade confirmations for transactions effected for your Account for up to one year aſter we send the last periodic statement reflecting those transactions. You may request interim updates and further details concerning any transaction effected between periodic statements either online (if you’re enrolled) or by calling a Program Advisor. Delivery of Certain Materials. When you enroll in the Program, you acknowledge in the Client Agreement that you received certain Program materials such as this Brochure, a Program Advisor’s and any other Merrill Brochure Supplements, any Profiles, any applicable Fund materials, and, for Retirement Accounts, the Retirement Account Addendum. Additional copies may be requested from a Program Advisor at any time and will be provided without charge. For your reference and convenience, we have posted this Brochure and other information at merrilledge.com/advisory-account-program-brochure. Certain of our materials, including this Brochure, are compatible with various types of assistive devices, such as screen readers. Other Program materials have varying degrees of compatibility with different assistive devices. If you experience difficulty in accessing a Program document with an assistive device, please inform a Program Advisor and request that the document be made accessible. Electronic Delivery. You may also separately arrange for the electronic delivery of certain Program materials, including the Brochure, any Account specific documents (and any changes or amendments) as well as other Program notices and materials, by signing up for electronic delivery via our internet website at merrilledge.com. If you consent to electronic delivery at that website, you will generally authorize us to deliver Program documents, disclosures and notices to you electronically. Electronic delivery through this process may not be available for all Program related communications, and in that case, we will send paper copies to you. There are separate procedures for enrollment and unenrollment through merrilledge.com. You may revoke your consent to electronic delivery of the Program Brochure and receive paper copies of that document by contacting a Program Advisor. From time to time, we may deliver paper copies of documents relating to your Account notwithstanding your Account preference. PROGRAM FEE AND OTHER CHARGES You agree to pay to us a non-negotiable annual asset-based fee (“Program Fee”) for the Services provided in the Program under the Client Agreement. The Program Fee is payable monthly in advance and is based upon an annual Program Fee rate of 0.85%. The Program Fee does not include all of the charges that may apply to your Account. Please see the section “Fees and Expenses Not Covered by the Program Fee” in this section for a list of other fees and expenses that you may be charged and are not included in the Program Fee. The Program Fee rate will be set forth in the fee schedule section of your initial Program Report provided to you upon enrollment. Upon your request, and at no charge, we will provide to you additional detailed information regarding your Program Fee. Please contact a Program Advisor if you would like to receive this more detailed Program Fee information. Merrill Edge Advisory Account Program | 10 MESPB 032025 The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance for your Account. The Program Fee you pay covers the Program’s Services, including investment advisory services described in this Brochure, as well as trade execution, clearance and settlement of transactions and custody of assets. The Program Fee covers a range of services, as described above, that are intended to be supplemental and enhance the investment advisory services you receive. The full amount of the Program Fee payable under the Client Agreement will be charged in accordance with its terms, regardless of your use of any of the services offered or of the amount of transactions effected in your Account. Certain of these services are not available in all types of securities accounts, Strategies and/or the jurisdiction in which you reside. Please speak with a Program Advisor about the availability of these services. We offer similar programs and/or investment strategies in different sales channels and at different fee levels. The Program Fee may be higher or lower than the fees for another investment advisory program and/or the cost of similar services offered through other financial firms. See “Ability to Obtain Certain Services Separately and for Different Fees” in this Item 4. You may be eligible for benefits such as Program Fee discounts, rebates or credits under certain promotional programs (“Bank programs”) that BANA offers from time to time for its banking product clients who also use the products or services of its Affiliates, including Merrill. In general, you must be a banking client of BANA, elect to participate in these Bank programs, and meet certain eligibility criteria of the Bank programs in order to receive the benefits available to clients of Merrill under these Bank programs. For additional information on these Bank programs, please contact us at 855-488-5249. Calculation of Fees. The Program Fee is calculated monthly as follows: • For each calendar month, the Program Fee rate that will be applied to your Account will be one twelſth of the annual Program Fee rate. In certain instances and in our discretion, we may waive or reduce your Account’s Program Fee for a particular month. • When you enroll a new Account in the Program, an initial Program Fee will be assessed during the week following the date on which you have contributed the required minimum level of assets to the Account for the Strategy selected by you. The initial Program Fee will be calculated and paid to Merrill based on: (1) the value of the assets in your Account as of the earlier to occur of the last business day of the week or the last business day of the month following required funding; and (2) one twelſth of the annual Program Fee rate applicable to such value and prorated based on the number of days remaining in the month from the date of required funding. • Aſter the initial Program Fee, the Program Fee is typically charged to your Account during the first week of the current calendar month; and the Program Fee will be calculated and paid to Merrill based on: (1) the value of the assets in your Account as of the last business day of the previous calendar month; and (2) one twelſth of the annual Program Fee Rate applicable to such value. • If you or we terminate your Account we will refund to you a pro-rata portion of the Program Fee based on the number of calendar days remaining in the month. The refund, if any, will be applied to your Account typically during the week following Account termination. See the section “Terminating Enrollment in the Program” for further information. Deduction of Program Fees from Your Account. You have agreed in the Client Agreement as follows: • Unless otherwise agreed to between you and Merrill in writing, the Program Fee (and any other fees payable under the Client Agreement) will be deducted directly from your Account. You may be able to pay the Program Fee from assets held outside of your Program Account. You should contact a Program Advisor for additional information. • Merrill is authorized to deduct the Program Fee (and any other fees payable) from the assets held in your Account, to the extent permitted by law, if full payment of such fees has not been timely received or, if earlier, at the time the Account is terminated. • The Program Fee and any other fees for your Account will be payable, unless otherwise indicated, first from the liquidation or withdrawal of your shares of any money market funds or balances in any money market or bank deposit account(s), as you authorize in the Client Agreement or other document, and second from free credit or cash balances, if any, in your Account. • You will make timely payment of all amounts due to Merrill under the Client Agreement, and any unpaid Program Fees may result in the termination of your Account(s). To the extent permitted by law, all assets in your Account or otherwise held by Merrill or its Affiliates for you will be subject to a lien for the discharge of your obligation to make timely payment to Merrill of the Program Fee (and any other fees payable under the Client Agreement), and Merrill may sell assets in your Account to satisfy this lien. If free credit or cash balances within the alternate account you have designated for your Program Fees to be deducted from are not available in that alternative account, the Program Fee will be deducted from your Program Account. Determination of how the Program Fee is Charged. Except as noted, you will be charged the Program Fee on all assets in your Account, including cash and cash alternatives. Generally, all Account values used to determine the Program Fees described above are based on the value of the assets in your Account, as determined by us. In calculating such Account values, we will use a variety of pricing sources, including our Affiliates. The Program Fee will be applied to any cash and cash alternatives held in your Account. This includes money market funds and other cash alternatives held as part of the Strategy, cash that is treated as a cash balance which is automatically swept into a cash sweep vehicle in accordance with the Cash Sweep Program for your Account, and cash in your Account due to your having chosen the “No Sweep” as provided for in the Merrill brokerage account agreement. The Program Fee is in addition to other compensation that Merrill and its Affiliates will earn on cash and cash alternatives held in your Account. Depending on interest rates and other market factors, the yield that you earn on cash balances and cash alternatives has been, and can be in the future, lower than the Program Fee that you pay on assets held in your Account. You will experience negative performance on the cash asset allocation for your Account if the Program Fee charged for your Account is higher than the return you receive on any cash and cash alternatives. For more information about the Cash Sweep Program, including compensation and benefits we and our Affiliates receive, see “Item 4 Funding and Operation of Accounts—Cash Balances” and in “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest—Cash Balances and Cash Sweep Program.” Fees and Expenses Not Covered by the Program Fee. Your Program Fee does not cover the following expenses, charges and costs, some of which are discussed in more detail below: • Dealer spread charges, mark-ups or mark-downs charged with respect to any principal transaction effected by MLPF&S or our Affiliate or effected by any executing broker-dealer for transactions in which Merrill or its Affiliate acts as agent. Merrill Edge Advisory Account Program | 11 MESPB 032025 • Underwriting discounts, selling concessions or other transaction charges with respect to any principal transaction effected by MLPF&S or our Affiliate. • Fees, expenses and charges charged by Funds or by the managers or sponsors of Funds, including fees, expenses and charges of the constituent Funds used in the Strategies. • Exchange fees, alternative trading system fees, required SEC fees or similar fees charged by third parties, including issuers. • Transfer taxes. • Electronic fund, wire and other Account transfer fees, including any fees or markups charged for foreign currency exchange or conversions relating to transfers or wires to or from your Account. • Any other charges imposed by law or otherwise agreed to with regard to the Account, including those charges payable to Merrill and/or third parties as described in the Brochure. The Program Fee does not include certain fees and charges relating to transfers and terminations, certain corporate actions and banking-related services like lending, check-writing services, money transfers, wire transfers, foreign currency wire transfers and conversions. Certain of these fees and charges are detailed on the Merrill Advisory Center Schedule of Miscellaneous Account document and Service Fees. Please see the securities account agreement and account enrollment documents relating to brokerage services and related transactions and account fees for your Merrill account. If you have any questions about any charges or fees applicable to your Account, please consult with your Program Advisor. For investments in Funds, you generally will purchase shares that have no front-end sales load or contingent deferred sales charge, or for which such loads or charges are waived. However, as a Fund investor, you will bear your proportionate share of such Fund’s fees and expenses including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. Any Fund redemption or other fees imposed by a Fund manager as a result of you redeeming the Fund to invest in a particular Program Strategy will be separate from the Program Fee. The Program Fee does not cover or offset any of the fees and expenses that any Fund may incur for transactions occurring within the Fund itself, including commissions and other transaction-related charges incurred by the Fund, even if we effect these transactions for the Fund. Except as otherwise provided for Retirement Accounts, the Program Fee will not be reduced even if Merrill or its Affiliate effects transactions for the Funds or otherwise provides services to the Funds for compensation. ABILITY TO OBTAIN CERTAIN SERVICES SEPARATELY AND FOR DIFFERENT FEES You may be able to obtain some of the same or similar Program Services or types of investments through a brokerage account or other investment advisory programs and services offered by Merrill. Many of the tools and analytics that are used to support services provided through the Program are also available through Merrill without enrolling in the Program and paying the Program Fee. However, while clients can obtain similar products and services from Merrill without enrolling in the Program, they would not receive the Program Services, including Account monitoring services and access to Strategies. Depending on your Strategy selection, certain investment products and managed investment strategies are available to you outside of the Program for more or less than you would pay in the Program. You may also be able to obtain some or all of these types of services from other firms, and if they are available, the fees associated with them may be lower or higher than the fees we charge. When you compare the Strategies, account types and programs and their relative costs, you should consider various factors, including, but not limited to: • Your preference for an investment advisory or brokerage relationship. • Your preference for a discretionary or a non-discretionary relationship. • Your preference for a fee-based or commission-based relationship. • Your preference for access to Program Advisors compared to an online-only (digital) relationship. • Your preference to work with a Program Advisor by utilizing an online interactive website or not. • Your preference to work with a Program Advisor compared to having a dedicated financial advisor. • The nature and breadth of the offering and services provided in the programs you are comparing. • The types of investment vehicles and solutions that are available in each Strategy, Merrill program or service. • Whether a particular investment solution offered in one Strategy or service is available through another Strategy or Merrill program or service at a lower or higher cost. • Whether you wish to invest in mutual funds or ETFs and which mutual funds and ETFs (if any) are available in particular Strategies or programs. • The frequency and type of client profiling reports, performance reporting and account reviews that are available in each program or service. You should discuss the brokerage and investment advisory services we make available with a Program Advisor to determine which may be most appropriate for you. There are important differences among this Program and these other programs to keep in mind. We have provided you with materials that help to explain the various platform and programs we offer, including the Form CRS and the “Summary of Programs and Services” at merrilledge.com/ relationships. Additional copies of these materials are available from a Program Advisor upon request. We offer other investment advisory programs, including: • Merrill Guided Investing (“MGI”), making available, through an online, self-guided interactive website, a selected list of investment strategies, including certain of those available in this Program, for an annual asset-based fee of 0.45%. • Merrill Guided Investing with Advisor (“MGI with Advisor”), offering a selected list of investment strategies, including certain of those available in this Program, certain other services and access to a Program Advisor for investment advice and guidance and an interactive website for an annual asset- based fee of 0.85%. • Merrill Lynch Investment Advisory Program (“IAP”), providing investment advice and guidance from a dedicated financial advisor and access to a comprehensive range of investment solutions, including certain of the Strategies available in this Program, for a negotiated annual asset based fee. The services that are available to you from these other investment advisory programs are different from the Services you receive through the Program in a number of important respects, including the range of strategies and solutions and the involvement and the nature of such involvement of a Merrill financial advisor. Merrill Edge Advisory Account Program | 12 MESPB 032025 FUNDING AND OPERATION OF ACCOUNTS Opening a Program Account. The Client Agreement allows you the flexibility to open or enroll into the Program an Account and any subsequent Accounts in the same account ownership capacity with verbal, electronic or written instructions. You may need to sign a separate Client Agreement if you want to open an Account in any other account ownership capacity. Examples of different account ownership capacities include an individual, a joint ownership capacity, a trustee of a trust, a guardian for a minor, a business entity (e.g., corporation, partnership), and a non-IRA retirement plan. The effective date of the Client Agreement for each of your Accounts will be the date of its acceptance by us and will be set forth in the Program Report you receive. The effective date of a Strategy change will be the date that the change is entered and noted into our systems. The Client Agreement will not apply to any Account that is not reflected in the applicable Program Report. Any preliminary discussions or recommendations provided to you before we accept the Client Agreement do not constitute investment advice under the Advisers Act and should not be relied on as fiduciary investment advice. Your request to enroll in the Program or to initiate a Strategy change is not considered a market order due to the requirements for enrollment including funding as well as the administrative processing time needed to implement enrollment instructions. We will initiate Program Services for new Accounts after your execution of any required Account documentation, approvals and funding of the Account and expect such enrollment to occur promptly. The investment of assets of an account will only occur when all operational requirements have been met. Account acceptance may be delayed or rejected if the account is underfunded or funded with ineligible assets. Funding Your Account and Contributions. There is typically a short delay between Account inception and initial investment transactions. Until we initiate Program services with respect to a new account, your assets will be held in a brokerage account for which you will be solely responsible for making any investment decisions with respect to the assets. During such time, we will not act as an investment adviser with respect to the assets. You may fund your Account by depositing cash and/or securities acceptable to us. We may determine in our sole discretion that certain assets, including securities or pending orders relating to securities, are ineligible for the Program or otherwise unacceptable. If we determine any contributed asset is not eligible or is unacceptable, the Client Agreement allows us to transfer this asset to a Merrill securities brokerage account or sell the asset as promptly as practicable, including on a principal basis, and charge you a commission for the sale of the asset. We also may request that you take action to transfer the ineligible assets out of an Account. Failure to comply with the request to transfer such assets out of an Account enrolled in the Program may result in that Account’s termination from the Program. Contributions of cash and securities to your Account may be made at any time. There may be a delay between the date that cash or securities are contributed to an Account and the date that MAA invests such cash (or liquidates contributed securities if applicable). Except as otherwise provided in the Agreement, we will not be liable for any lost opportunity profits that may result from a delay in investing or liquidating any contributed funds or securities in order to invest the proceeds into a Strategy. As a general matter, we will sell any assets you may have in your Account in order to invest in accordance with the Strategy. If we determine not to sell the particular asset, are unable to sell the asset or if you specifically direct us in writing to not liquidate the asset (before it has been liquidated), we have the right to transfer the asset to a Merrill securities brokerage account or other account. We will not act as a fiduciary or an investment adviser in connection with these sale transactions. You are responsible for all tax liabilities arising from any sale of such ineligible or unacceptable assets. Special Note about Funding Your Account with Mutual Fund Shares. Before contributing mutual fund shares to the Program, you should consider the fact that you may have paid a front-end sales charge or may be obligated to pay a contingent deferred sales charge or redemption fee if the mutual fund shares are redeemed by us in order to invest in the Strategy you have selected. These fees, where applicable, will remain your responsibility and will be in addition to the Program Fee. Each mutual fund has its own system of mutual fund share classes for certain types of clients and accounts. The Program-eligible mutual fund share classes vary depending on the mutual fund, its roster of share classes and our agreements with the mutual funds. In general, the share classes that are eligible for the Program do not have any sales loads and annual asset-based fees. Annual asset-based fees include “service fees” or “12b-1 fees” charged by mutual funds. There are some mutual funds available in the Program that have such annual asset-based fees due to share class availability. If you contribute or hold mutual fund shares that we deem to be ineligible for the Program but within a Strategy’s holdings, we will either sell them and purchase the share class eligible for the Program or we will exchange them (under the authority provided to us under the Client Agreement, mutual fund prospectus rules and our own policies) into the Program-eligible share class as promptly as practicable. We may also require you to remove them from the Account if not in a Strategy’s holdings. We may not elect to exchange particular share classes of a mutual fund if, for example, there is no equivalent class eligible for the Program or if other circumstances exist. Depending on your Program Fee, by contributing mutual fund shares to your Account in the Program, you could be subject to higher expenses overall once the shares are exchanged into a class we deem to be eligible or if you held them in your brokerage account. Prior to contributing any mutual fund shares to your Account, you should discuss the impact of a sale or exchange of these shares with a Program Advisor. Withdrawals. For withdrawal requests, the liquidation of certain securities will be required. Withdrawal requests will be implemented as promptly as practicable, although implementation of the withdrawal may be delayed in certain instances, such as during periods of extreme market volatility. The following will apply to our handling of a withdrawal request: • We require at least five business days, prior notice before you withdraw assets from an Account. In certain situations, it may take longer than five business days before you can access your requested funds. MAA’s ability to liquidate may be impacted by market conditions and events or pending re- balancing or other actions being taken for the Account. • Your withdrawal request will be handled as promptly as practicable given other activities that may be occurring at the same time in an Account like changes to a Strategy, any rebalancing transactions in process and other activity affecting the Account. • If you do not withdraw the proceeds received from a requested liquidation from the Account within 15 calendar days after the proceeds have settled in the Account, MAA may take action to reinvest the proceeds without notifying you in accordance with the Strategy. • We reserve the right to terminate any Account that falls below the required minimum asset size as reflected in the applicable Profile. Merrill Edge Advisory Account Program | 13 MESPB 032025 • We reserve the right to terminate any Account that falls below the required minimum asset size as reflected in the applicable Profile for a Strategy. If your account balance is not sufficient to fully implement the Strategy selected for the Account, we may request additional funds or terminate the Account’s enrollment in the Program. • We reserve the right to terminate any Account that falls below the required Program minimum as outlined in this Brochure. • We reserve the right to liquidate, redeem or exchange Funds and other securities that are transferred from an Account to a brokerage account. • We will charge the Program Fee on the value of your Account investments until the proceeds from any sale or redemption have moved out of the Account. • Taxable gains and losses may be realized as a result of your withdrawal instructions. • Frequent withdrawals from your Account may affect the achievement of investment objectives for the Strategy you selected. Service Changes or Additions. You may change or add a Service or add Accounts to your Portfolio, subject to approval by us, by contacting a Program Advisor. We will implement any approved changes that you select as soon as reasonably possible. You will not be able to use Visa® cards or write checks on an Account while it is enrolled in the Program. Terminating Enrollment in the Program. The Client Agreement may be terminated at any time by either us or you, with verbal or written notice to the other party. The termination of the Client Agreement will terminate all Accounts. You may also terminate any Accounts subject to the Client Agreement by giving us notice of such termination. Your termination of a particular Account will not automatically terminate any of your other Accounts. Termination of the Client Agreement will not affect or preclude the consummation of any transaction initiated prior to termination. Termination of your Account will be effective following the completion of processes that may be required to terminate the Account, including any required liquidations. We will not be responsible for market fluctuations in your Account from the time of termination until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient liquidation of an Account include, but are not limited to, size and types of securities, liquidity of the markets and market-makers’ abilities. Due to the administrative processing time needed to terminate an Account, termination requests cannot be considered market orders. It could take up to several business days under normal market conditions to process your request. Upon termination of an Account or the Client Agreement, a pro-rata adjustment to the Program Fees for the remainder of the billing period will be made, which may result in a refund of your Program Fee monthly payment. In addition, your Account will be converted to, and designated as, a brokerage account that will be subject solely to the terms and conditions of the Merrill securities brokerage account agreement. The termination of the employment of a Program Advisor with Merrill or a change in the role of your Program Advisor who had been assisting you with your Account will not automatically terminate the Client Agreement. In the event that a particular Program Advisor is no longer able to service your Account, we will transfer that Account to a different Program Advisor. The Account will remain in the Program and incur the Program Fee until you instruct us otherwise. Merrill reserves the right to take action under its Program guidelines to terminate the Account from the Program or to authorize or preclude Program Advisors from taking action in respect of your Account if we are unable to obtain instructions from you as to your Account in a timely manner. If your Account is terminated and converted to a brokerage account, the brokerage services and activities will be limited. You (or any other party acting on your behalf) will have the sole responsibility for the investment of assets in the brokerage account. In the event of a termination, the Account assets will not be liquidated but will be held in your brokerage account, except where the holding of such security in that account is not permitted. For certain mutual funds, the advisory share class of such funds are not eligible to be held in an account that is not enrolled in the Program. Upon Account termination or termination of the Client Agreement or if you or we move or transfer the Fund shares from your Account to a brokerage account, we will automatically liquidate, redeem or exchange these shares into another appropriate share or unit class in accordance with applicable offering materials and our own policies, without providing prior notice. Any liquidation, redemption or exchange will generally be effected as soon as practicable, which may be as soon as the close of the next business day following termination or transfer. Additional fees and expenses may apply upon any such liquidation, redemption or exchange. Brokerage share classes generally will have higher operating expenses than advisory share classes that are eligible for the Program and will charge sales loads and annual asset-based fees, which will be used to compensate Merrill or one of its Affiliates. Cash Balances. The CIO will determine the cash allocation for the Strategies. The cash allocation can be held in the form of cash balances or investments in money market funds, which have a one-day settlement period, or other cash alternatives. At times, your Account will have an allocation to cash balances that will be automatically swept to the cash sweep option applicable to your Account under the Cash Sweep Program because we have made a decision to keep a cash balance for various purposes, such as your cash needs or as a way to fulfill your cash asset allocation target. The CIO determines whether to keep a cash balance for operational and/or investment purposes as part of a Strategy. We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See “Item 9 Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Item 9 Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” You can hold cash in a separate brokerage account or in a deposit account at a Bank Affiliate or at other banking institution. This cash will not be subject to the Program Fee and will not receive any Program monitoring and other Program Services. We will not be an investment adviser or fiduciary with respect to such cash. Legal Matters and Related Notifications. We will not advise or act for you with respect to any legal matters for securities held in your Account, including bankruptcies or class actions. In its role as a broker-dealer, MLPF&S will endeavor to send you any documents received with respect to such matters. We will respond to corporate actions for securities in the Account. Corporate actions for a client’s account can include any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. Your Responsibilities for Account Operation and Management. You must notify a Program Advisor promptly of any material change in financial circumstances, investment objectives, or investment restrictions (if any) that may affect the nature of the investment advice and services provided to Merrill Edge Advisory Account Program | 14 MESPB 032025 Program Accounts. You are responsible for monitoring the total amount of deposits held at any one bank, including at any of our Bank Affiliates, for FDIC insurance limits. See “Item 4 Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services.” There is more detailed information about FDIC insurance and limits in the Sweep Program Guide for Merrill Clients. Tax Matters. You are responsible for all tax liabilities and tax-return filing obligations arising from the transactions in your Account enrolled in the Program. We do not, and will not, offer tax advice to you and we strongly encourage you to seek the advice of a qualified tax professional in all instances for tax advice. We are not responsible for attempting to obtain any tax credit or similar item or preparing and filing of any legal document on your behalf. You should be aware that tax consequences may arise when Strategy changes occur in your Account such as rebalancing, liquidations and redemptions. Except to the limited extent described in this section, we specifically disclaim any undertaking of tax management of your Account or investments and assume no responsibility for any resulting tax consequences. Additionally, if you direct us by contacting a Program Advisor (or by contacting us by telephone at 888.654.6837) to take certain actions for tax related reasons, there is no assurance that your desired tax effect will be realized. For example, if you direct us to realize gains in your Accounts, when we resume normal trading activity, such activity could generate new taxable losses or gains, and the same or similar securities may be repurchased. Similarly, if you direct us to realize losses in your Account, when we resume normal trading activity in your Account, such activity could generate new taxable losses or gains. Upon your request to realize losses within an Account, we will attempt to undertake the following: (1) restrict purchases of substantially identical securities in the Account for a minimum of thirty-one calendar days following the sale of securities at a loss in the Account; restrict sales of substantially identical securities in the Account that are currently at a loss for a period of thirty-one calendar days following the purchase of securities in the Account; and (3) at our discretion, engage in strategies to invest the available proceeds for varying time periods in substitute securities, current holdings, and/or alternative securities such as ETFs. We also could determine to hold cash in certain circumstances. We do not make any guarantee that these actions will be successful in recognizing the losses. MAA will generally accept specific tax gain and loss requests for taxable Accounts but the extent to which it implements such a request may be affected by its qualitative assessment of market liquidity. MAA can reject a client’s request for tax-related trades in whole or in part at its discretion. We do not make any guarantee that these actions will be successful in recognizing these losses. We are not providing any tax advice with respect to the effects of these transactions including whether a loss has been recognized under the wash sale rules under the Code. We do not take into account the trading activity in any of your other accounts, including your other Accounts in the Program or any accounts you have with Merrill or its Affiliates or third parties. You should consult your own professional tax advisor regarding the tax consequences of these transactions. You should be aware that as a result of these transactions, a higher than normal cash position may result for a period of time. In addition, this type of transactional activity may adversely affect Account performance and may increase the volatility of its results. Item 5. Account Requirements and Types of Clients CLIENT ELIGIBILITY Merrill requires that all clients who wish to enroll in the Program enter into the Agreement, which sets forth the services that Merrill and/or MAA will provide to the client. The Agreement sets forth the terms and conditions that govern the handling of the client’s Account or Accounts and the investment advisory relationship between the client and Merrill. Clients generally eligible to participate in the Program include individuals, trusts, estates, corporations and virtually all other types of business as defined by us. Not all Merrill account types are eligible for enrollment in the Program and not all types of clients are eligible for each Strategy. PROGRAM MINIMUM There is a minimum asset requirement of $20,000 to enroll into the Program. We may waive or alter this minimum at our discretion. The Strategies in the Program each require an initial minimum investment amount as reflected in the applicable Profile. Following enrollment, an Account must maintain a minimum asset amount set by us in our discretion in order for us to provide Program Services. If your Account’s assets do not meet this minimum, we may request that you contribute additional funds to your Account. If you decide not to take the requested action, we reserve the right to terminate your Account from the Program, which converts the Account to a brokerage account type. We may change these minimums at any time. RETIREMENT ACCOUNTS The sub-accounting service or distribution fees received from the mutual fund or a fund service provider or its Affiliate relating to mutual fund or other securities holdings in a Retirement Account will be credited to the Retirement Account on a periodic basis. In the future, your Retirement Account may invest in shares of mutual funds which are Related Funds that we may offer from time to time. If a Retirement Account invests in a mutual fund that is a Related Fund, then any advisory fee or other compensation paid to Merrill or our Affiliates that is incurred in connection with the investment in a Related Fund, will be credited to the Retirement Account on a periodic basis, to the extent required by law. If you contribute to a Retirement Account or hold in a Retirement Account mutual fund shares that we deem to be ineligible for the Program, such shares will be converted into a class of shares of the same mutual fund we deem to be eligible and will then be subject to the Program Fee. The timing of any such conversion is determined by us in our sole discretion. Prior to contributing any mutual fund shares to your Retirement Account, you should discuss the impact of a conversion of these shares with a Program Advisor. Item 6. Portfolio Manager Selection and Evaluation SELECTION AND REVIEW OF STRATEGIES AND FUNDS AVAILABLE IN THE PROGRAM Through the Program, we make available Strategies with various investment styles and corresponding risk levels, in each case that we decided in our discretion to make available in the Program. The determination to include the Strategies selected in, or to remove them from, the Program is made by us based on a variety of factors, including client needs, investment styles available in the marketplace, platform capacity, client demand and the outcome Merrill Edge Advisory Account Program | 15 MESPB 032025 of reviews conducted by or under our auspices, including through the CIO. The CIO is a Merrill business group providing investment solutions, portfolio construction advice and wealth management guidance to Program Advisors and clients, and it is separate from MAA and from the Merrill business group that administers the Program. We perform, through our product teams’ internal business processes, initial and periodic reviews of Strategies and Funds available in the Program. In addition to these business processes, we have in place an investment review, referred to as the “CIO Review Process”, conducted by or under the auspices of personnel of the CIO of Funds, including those to be included in the Strategies (“constituent Funds”). The CIO Review Process consists of proprietary processes conducted by the CIO and those processes and reviews provided by third-party reviewers that we have engaged for this purpose. The third-party reviewer processes and reviews are generally consistent with the review processes that the CIO deploys but they are not identical. We, through the CIO, have reviewed such third-party reviewers’ processes and believe they are reasonable and appropriate in light of the objectives of the Program. Once we identify a need for a particular investment management style or strategy, a quantitative and qualitative due diligence process is employed, including but not limited to, the organizational structure and stability of the investment manager or Fund manager or sponsor, adherence to investment style, including sustainability or ESG attributes, where relevant, evaluation of risk and volatility, investment professional and strategy resources, investment philosophy and process, portfolio construction, performance, and operating and administrative capability. Based on these factors and using the information collected, the CIO Review Process involves quantitative and qualitative analytical methods, some of which may be subjective. Generally no single factor will be determinative. Our reviews may involve in-person visits, telephone conference calls, reviews of performance, and updates of certain Fund documents and information. We may also conduct periodic analysis of composite performance to determine whether that performance generally appears to be consistent with that of the Funds. We do not perform audits of Funds to verify past performance information that the Funds provide to us. For each Strategy, we will periodically evaluate factors related to the Strategy and Fund investments included in the Strategy that we deem appropriate. These reviews may occur as part of the CIO Review Process or otherwise. In addition, for each Fund available at Merrill, including those included in the Strategy, we will periodically evaluate factors related to the Fund investments that we deem appropriate. In addition, we may initiate reviews based on various factors determined by us and the CIO to be appropriate, including the level of assets in a Strategy or Funds in client accounts at Merrill or our Affiliate, the number or percentage of Merrill or Affiliate clients in a Strategy or its included Funds and the asset class involved. If we identify concerns regarding a Strategy or a Fund that we find significant or important, we may choose not to accept any new investments in that Strategy or the Fund. A driſt or variation of the style of management of a particular Strategy or constituent Fund from the stated style does not require a removal from our Program offering. Merrill retains the decision-making authority to add or remove a Strategy or a constituent Fund, regardless of or in light of the results of any review conducted, including the CIO Review Process. Our product teams’ internal business review and the CIO Review Process form the basis for Merrill determining whether to make ETFs available for use in the Program. In addition, the CIO Review Process determines whether ETFs will be included in a Strategy constructed and implemented by the CIO. The CIO Review Process and conclusions from that process do not rely on or otherwise use the research reports and ratings related to certain ETFs of the BofA Global Research Group (Research Ratings) as an input or factor. The CIO, BofA Global Research and other business units of BofA Corp. apply different methodologies in their review of ETFs and may arrive at different or inconsistent conclusions. Note that Fund managers include as part of their Fund’s investment portfolios individual equity and fixed income securities based on their own review and portfolio management processes and determinations. These individual securities may not be covered, and are not required to be subject to, the CIO Review Process. Our review of the Strategies and Funds does not substitute for your ongoing monitoring of your Account and the performance of your investments. STRATEGY CONSTRUCTION Through the Program, we, through the CIO, will construct the Strategies and select the Funds and the allocations or allocation ranges for each Strategy. Please refer to the Profile for additional information about the Strategy you select. In general, we develop the Strategies in an effort to strike a balance between current income and growth, unless otherwise noted in the Profile for the particular Strategy. The CIO selects the constituent Funds for the particular Strategy and, when doing so, selects only those subject to the CIO Review Process and those that are considered to have sufficient assets under management and to meet minimum trading volume parameters. In addition, it considers and evaluates their share price or net asset value, along with the corresponding allocation weighting, in light of the Strategy’s investment minimum. The CIO determines the allocations or allocation ranges for the Strategies. It develops the strategic asset allocations for the Strategies based on its long- term expected return, risk and correlation assumptions for each asset class (“capital market assumptions”), its view of the appropriate long term allocation guidelines to follow in light of market conditions, expected trends and, as applicable, corresponding tactical asset allocation adjustments. The tactical asset allocation adjustments are applied to those long-term asset allocations based on the CIO’s near-term market, economic, and asset class expectations. These tactical adjustments overweight or underweight specific asset classes, incorporating its investment views on how market dynamics, phases of the economic or business cycle, and particular investment themes may affect the Strategies. In order to determine tactical asset allocations, the CIO utilizes internal as well as third-party research and data at both the macro and micro levels. Once the Strategies are constructed, the CIO regularly monitors and reviews them and makes adjustments based on asset allocation changes. The Funds used in the Strategies are also periodically reviewed to ensure they continue to meet the criteria for inclusion. The Strategies are subject to internal governance and oversight processes on a periodic basis, which may include a review of Strategy performance against expectations as well as any applicable investment or regulatory restrictions. The offering of the Strategies is also subject to internal governance processes and applicable legal requirements. The Program does not currently offer any Related Funds. However, to the extent any Related Funds become available, we may determine to include them in a Strategy. The conflicts of interest and other considerations arising from the use of Strategies constructed, implemented and managed by Merrill or any of its Affiliates or Related Companies are discussed in “Item 9 Compensation, Conflicts of Interest and Material Relationships.” Merrill Edge Advisory Account Program | 16 MESPB 032025 AVAILABLE INFORMATION REGARDING STRATEGIES AND FUNDS We make available additional guidance to Program Advisors through regular or ad hoc internal publications. This may include information that reflects our internal opinions and views with respect to a Strategy or Fund, notices of a particular event that may lead to these being closed to new investments or terminated from a Strategy, or other information. You should discuss with a Program Advisor any questions you may have about our views with respect to a particular Strategy or Fund. You should review any investment materials available from your Program Advisor about investments in your Account, including any prospectuses and other offering material produced by issuers and sponsors of investment products. You will generally be provided with a Profile for each Strategy made available to you through the Program. You should carefully read the Profile provided and understand the relevant objectives, styles and risks. The Profile will also describe the role of MAA and any related Account requirements with respect to the Strategy. The Profiles for the Strategies include performance information from MAA. We make no claim that the Profile performance information has been calculated according to any industry standards. Please note that any past performance shown on the Profile is not indicative of future results and your investment performance for any Strategy in your Account may differ from the information presented in the Profile for that Strategy. Account performance also may differ for a variety of other reasons, including timing of enrollment in the Program, client-imposed Reasonable Investment Restrictions and Firm restrictions and other considerations. ADVISORY SERVICES PROVIDED BY MERRILL AND CERTAIN AFFILIATES Merrill and MAA act as the portfolio manager for your Account as described in “Item 4 Investment Strategy Services.” We act as both the wrap fee program sponsor and portfolio manager for the Strategies offered through the Program and receive the Program Fee as described in this Brochure. Merrill receives the entire Program Fee as described in this Brochure. We also act as the portfolio manager in other wrap fee programs sponsored by us. We act as an investment adviser in certain investment advisory programs, such as MGI and MGI with Advisor, which provide investment advisory services that are similar to the Program Services but are not the same. Additional information is available in “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” The CIO releases information and analyses about a Fund to Merrill, MAA, our Affiliates and financial advisors, including Program Advisors, at the same time, it is possible that our Affiliates and other investors act on that information before Merrill or MAA has had the chance to evaluate and act on those changes. Accounts that commence trading aſter the release of such information will be subject to price movements, particularly with large orders or where securities are thinly traded, that would cause them to receive prices that are less favorable than those obtained by Affiliates or other investors. TAILORED INVESTMENT ADVICE As described in “Item 4 Advice and Guidance,” we will recommend a Target Asset Allocation based on certain information provided by you, and you will be able to select a Strategy for your Account. You also can request that we impose Reasonable Investment Restrictions. If you have an investment policy statement or other investment guidelines (“IPS”), it is your responsibility to ensure that the IPS is properly reflected in your responses inputted into your discussion with a Program Advisor, including any investment restrictions. We do not have any responsibility to review, monitor or adhere to any IPS relating to your Account. Adherence to your IPS is solely your responsibility. To the extent the terms of such IPS conflict with a Strategy you select under the Program, by signing the Client Agreement, you have agreed that the terms of such IPS were amended to incorporate by reference such investment or Strategy. PERFORMANCE-BASED FEES The Program does not charge performance-based fees. Certain Funds that may be included in the Strategy you select, however, may be subject to performance-based fees or varying Fund expense charges that are imposed by the Fund’s manager, adviser or other party that are based on performance of the Fund. METHOD OF ANALYSIS The implementation and management of any CIO Strategy will be dependent upon the CIO’s investment expertise, philosophy and process and will be supplemented by the Program Advisor understanding the Strategies and providing advice and guidance to you. We have made available various resources to the Program Advisor, including investment guidance and management research and publications from the CIO covering macroeconomic and market events and Strategies and Funds and information and assistance from other Merrill internal specialists and support teams. The use of such guidance and proprietary model portfolios does not assure or guarantee that investment performance will necessarily be profitable or consistent with the proprietary model portfolio. VOTING CLIENT SECURITIES You have the right to vote proxies for securities held in your Account(s) and will retain proxy voting authority for such securities. You cannot delegate to us and we do not accept any proxy voting authority for securities held in your Account. INVESTMENT STRATEGIES AND RISK OF LOSS Set forth below is a summary description of material risks related to the Program Services provided in the Program and significant or unusual risks. The information provided below is meant to summarize certain risks and is not inclusive of each and every potential risk associated with each Strategy or applicable to a particular Account. Therefore, you should not rely solely on the descriptions provided below and are urged to speak with a Program Advisor and ask questions regarding risk factors applicable to a particular Strategy, read all disclosures and determine whether a particular Strategy is suitable for your account in light of your specific circumstances, investment objectives and financial situation. General Risks of Investing. All investments involve risk, the degree of which may vary significantly. Investment performance can never be predicted or guaranteed; and the values of your assets will fluctuate due to market conditions and other factors. Investments made, and the actions taken, respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Merrill Edge Advisory Account Program | 17 MESPB 032025 Strategies that consist of Funds comprised of equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Funds that are comprised of fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain Strategies have constituent Funds that invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) by Funds are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the Fund may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. You should review the offering materials and other disclosure available for each relevant Strategy and/or Fund to get an appreciation of its associated risks and fees. You are assuming the risks involved with investing in the Strategies and the Funds. There is no assurance that the performance results of any benchmark or index used in connection with a Strategy, including those shown in a Profile, can be attained. Market movements and other factors may result in significant differences between the performance of your Account, your Account’s Target Asset Allocation and the Strategy selected for your Account. You should review any investment materials available from your Program Advisor about investments in your Account, including any prospectuses and other offering material produced by issuers and sponsors of investment products. Target Asset Allocation and Monitoring. Any target asset allocations (including your Target Asset Allocation) or benchmarks, as applicable, referred to in connection with your Strategy, Account or Portfolio are not intended to be an assurance or guarantee of the performance of any investments in the Strategy or the Strategy itself. There is no assurance that the performance results of any benchmark or index used in connection with a Strategy, including those shown in a Profile, can be attained. Market movements and other factors (including withdrawals from an Account) may result in significant differences between the performance of any Strategy and any Target Asset Allocation for your Account. In addition, if accepted by us, you can impose restrictions on your Account that may result in your Account being concentrated in Funds invested in one or a few sectors, industries or securities. Concentrated portfolios typically increase the risk and volatility of an Account and may result in a decrease in diversification. We may determine not to accept such guidelines and/or restrictions. See the “Reasonable Investment Restrictions” section for more information. Securities-Based Lending with your Account. You may take action to make your Account assets “pledged” or used as collateral (if we consent) in connection with Lending Programs. Risks to your Account may be heightened in the event you pledge your Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. The lender has the right to protect its own commercial interests and to take actions that adversely affect the management of your Account and related performance. Regardless of whether the lender is us or an Affiliate or a third-party lender, the lender’s lien is senior to any rights we may have on the assets in the Account. As such, the lender has the right to sell securities in the Account that serve as collateral, if needed. Neither you nor any of us (including our Affiliates), if applicable, may be provided with prior notice of a liquidation of securities or transfer of interests in your pledged Account. Furthermore, neither you nor we are entitled to choose the securities which are to be liquidated or transferred by the lender. Use of Strategies Where Merrill Is the Manager. The Strategies currently available in the Program are those that are constructed and managed by Merrill (through the CIO) and implemented for Accounts by MAA. These Strategies are not subject to the same level of review that is applicable to third- party manager strategies that Merrill offers in its other investment advisory programs. The Strategies in the Program are subject to internal governance processes and any applicable legal restrictions. Role of a Program Advisor in the Program. A Program Advisor’s view of the Strategies will be an important factor in determining which Strategies are recommended to you or purchased for your Account. Information and Cyber Security Risks. With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly, BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of a process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities, the Funds and Fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents directed at BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents as well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we or our service providers, will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Merrill Edge Advisory Account Program | 18 MESPB 032025 Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory and operational reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. ESG themed Strategies or Funds. There is an increasing number of products and services that purport to offer environmental, social, and governance (“ESG”) investment related strategies (“ESG Strategies”). The variability and imprecision of industry ESG definitions and terms can create confusion. Fund managers and sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. You should review the offering materials and Profiles to gain an understanding of how they define and use ESG screens and restrictions in connection with their investment products. Merrill and MAA generally do not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the Fund manager) other than as part of the CIO Review Process. ESG Strategies, including ESG-related Funds, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. Certain ESG Strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by the CIO or fund manager, will align with your ESG-related beliefs or values. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the CIO’s or Fund manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities and, as a result, investment performance could suffer. When evaluating investments for an ESG Strategy, the CIO or Fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment of an investment’s ESG or sustainable attributes. Neither Merrill nor MAA guarantees or validates any third-party data, ratings, screenings or processes. Funds. The Strategies you select may invest in shares of, or interests in, ETFs. As an ETF shareholder, you, along with other shareholders of the ETF, will bear a proportionate share of the ETF’s expenses, including, as permitted by applicable law, certain management and other fees, which may be payable to us or a Related Company. An ETF’s prospectus contains a description of its fees and expenses. A copy of an ETF’s prospectus is available from your Program Advisor upon your request. When you invest in an ETF, you will indirectly pay a proportionate share of the ETF’s costs for services that may be similar to, or duplicative of, Services rendered as part of the Program and paid for directly through the Program Fees. Below is a summary of certain risks relating to investing in ETFs that may apply to all or certain types of ETFs offered through the Program. Please refer to the particular ETF prospectus for more information about the risks applicable for a particular ETF. If you would like a copy of a particular ETF prospectus, you may obtain one by contacting a Program Advisor who will arrange for it to be sent to you free of charge. ETFs are subject to risks relating to market trading that include the potential lack of an active market for ETF shares and disruptions in the creation and redemption process. Although ETF shares are listed on a national securities exchange, it is possible that an active trading market in the shares of a particular ETF may not develop or be maintained, particularly during times of severe market disruption. If ETF shares need to be sold when trading markets are not properly functioning, the ETF shares may be sold at a significant discount to their Net Asset Value (“NAV”). In some cases, it may not be possible to sell ETF shares in the secondary market. For example, an unanticipated closing of the national securities exchange on which an ETF’s shares are listed or one or more markets on which either the ETF’s shares trade or the ETF’s portfolio holdings trade or the inability of such markets to open for trading during normal business hours, such as in response to a natural disaster or other event causing severe market disruption, could result in the inability to buy or sell shares of the ETF and the ETF’s inability to buy and sell exchange-traded portfolio securities during that period, or in a disruption of the ETF’s creation and redemption process, and may make it difficult for the ETF to accurately price its investments, thereby potentially affecting the price at which ETF shares trade in the secondary market. All of these events could adversely affect the performance of the ETF. Trading in ETF shares also may be halted by an exchange or other markets because of market conditions or other reasons. If a trading halt occurs, an investor may temporarily be unable to purchase or sell shares of the ETF. Similarly, an exchange or other markets may issue trading halts on specific Merrill Edge Advisory Account Program | 19 MESPB 032025 securities or derivatives, which will affect the ability of the ETF to buy or sell certain securities or derivatives. In such circumstances, the ETF may be unable to rebalance its portfolio or accurately price its investments and may incur substantial trading losses. ETF shares also may trade on an exchange or on other markets at prices below their NAV. The NAV of ETF shares will fluctuate with changes in the market value of the ETF’s holdings and the exchange-traded prices of the ETF’s shares may not reflect these market values. Only an authorized participant may engage in creation or redemption transactions directly with an ETF. To the extent that these institutions exit the business or are unable to proceed with creation and/or redemption orders with respect to an ETF and no other authorized participant is able to step forward to create or redeem, ETF shares may trade at a discount to NAV and possibly face delisting. This risk is exacerbated if an ETF has a limited number of institutions that serve as authorized participants. Certain ETFs may effect creations and redemptions for cash, rather than in-kind. As a result, an investment in such an ETF may be less tax-efficient than an investment in a more conventional ETF. ETFs generally are able to make in- kind redemptions and avoid being taxed on gains on the distributed portfolio securities at the ETF level. An ETF that effects redemptions for cash, rather than in-kind distributions, may be required to sell portfolio securities in order to obtain the cash needed to distribute redemption proceeds. If the ETF recognizes gains on these sales, this generally will cause the ETF to recognize gains it might not otherwise have recognized, or to recognize such gains sooner than would otherwise be required if it were to distribute portfolio securities in-kind. ETFs generally intend to distribute these gains to shareholders to avoid being taxed on the gain at the ETF level and otherwise comply with the special tax rules that apply to it. This strategy may cause shareholders to be subject to tax on gains they would not otherwise be subject to, or at an earlier date than, if they had made an investment in a different ETF. Moreover, cash transactions may have to be carried out over several days if the securities market is relatively illiquid and may involve considerable brokerage fees and taxes. These brokerage fees and taxes, which will be higher than if the ETF sold and redeemed its shares principally in-kind, will be passed on to purchasers and redeemers of creation units in the form of creation and redemption transaction fees. In addition, cash transactions may result in wider bid-ask spreads in shares trading in the secondary market as compared to ETFs that transact exclusively in-kind. ETFs that seek to track the performance of a specified underlying index (“Index ETFs”) are not actively managed and the investment advisers of such ETFs do not attempt to take defensive positions in declining markets. Therefore, Index ETFs may be subject to greater losses in a declining market than a fund that is actively managed. A number of factors may affect an Index ETF’s ability to achieve a high degree of correlation with its underlying index, and there can be no guarantee that an ETF will achieve a high degree of correlation with its underlying index either on a single trading day or for a longer time period. Factors such as ETF expenses, imperfect correlation between the ETF’s investments and the components of the underlying index, rounding of share prices, changes to the composition of the underlying index, regulatory policies, a high portfolio turnover rate, and the use of leverage all contribute to tracking error and correlation risk. Failure to achieve a high degree of correlation may prevent an ETF from achieving its investment objective and cause the ETF’s performance to be less than you expect. Among other services provided, we or our Related Companies may effect transactions for any of the ETFs offered through the Program, and any compensation paid to us or our Related Companies by the ETF, or its Affiliates, is in addition to the Program Fee. Due to the additional economic benefit to us or our Related Companies when assets in your Account are invested in an ETF that pays compensation to us or our Related Companies, a conflict of interest exists. We attempt to address this conflict by selecting ETFs based on the investment merits of the particular investment products and not based on the compensation that we and our Related Companies earn and through the disclosure in this Brochure. The CIO may determine to include shares of or interests in Non-traditional Funds (“NTFs”) in the Strategies. NTFs are mutual funds and ETFs registered with the SEC that we classify as “Alternative Investments” as an asset class because their principal investment strategies utilize alternative investment strategies (including short selling, leverage and derivatives as principal investment strategies) or provide for alternative asset exposure as the means to seek their investment objectives. NTFs may not have the same type of non-market returns as other types of Alternative Investments since NTFs have a relatively liquid and accessible structure with daily pricing and liquidity, are subject to a more structured regulatory regime and offer lower initial and subsequent investment minimums. Item 7. Client Information Provided to Portfolio Managers As part of the enrollment process, we elicit information about your financial circumstances, investment objectives, risk tolerance and other relevant information relating to your Accounts and Portfolios. We do not generally provide this information to Funds. In managing your Portfolio, we rely on information you provide and it is your responsibility to notify promptly your Program Advisor of any updates to such information. In the Agreement, you represent to us that you have provided us and will provide us with information that is accurate and complete. Failure to do so could affect the suitability of the services being provided under the Program. We are not required to verify the accuracy of the information. Item 8. Client Contact with Portfolio Managers MAA has agreed to make one or more of its advisory or investment personnel reasonably available for consultation with Program Advisors and with you by request. Item 9. Additional Information DISCIPLINARY INFORMATION The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill Lynch’s Form ADV at: adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, Merrill Edge Advisory Account Program | 20 MESPB 032025 specifically its use of the MLBD Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease- and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self- reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’ remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through BofAS, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. MAA, an indirect wholly-owned subsidiary of BofA Corp., is a registered investment adviser that provides investment advisory services to clients that establish accounts under the Program and other investment advisory programs, including IAP, MGI and MGI with Advisor. As registered investment advisers, MLPF&S and MAA complete Form ADVs, which they publicly file with the SEC (available at adviserinfo.sec.gov). For purposes of Form ADV Part 2, certain MLPF&S and/or MAA management persons are registered as registered representatives or associated persons of MLPF&S. In the future, certain MLPF&S and/or MAA personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of MLPF&S to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning; asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) research across the following disciplines: global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act and additional information about BofA Corp. can be found in publicly available filings with the SEC. CONFLICTS OF INTEREST AND INFORMATION WALLS Merrill, MAA and their parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or Merrill Edge Advisory Account Program | 21 MESPB 032025 related clients at the same time while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within BofA Corp. possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., BofAS, MLPF&S and MAA evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. CODE OF ETHICS Each of MLPF&S and MAA has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services under the various investment advisory programs for which they are a registered investment adviser. Each Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that each of MLPF&S and MAA follows in conducting our business with integrity and professionalism. Each Code of Ethics covers requirements that all employees comply with all applicable securities and related laws and regulations; the reporting and/or clearance of employee personal trading; the prevention of misuse of material nonpublic information and the obligation to report possible violation of the Code of Ethics to management or other appropriate personnel. All covered personnel must certify to receipt of the Code of Ethics. The Merrill Investment Adviser Code of Ethics is available at mymerrill.com/ADV/materials or we will provide a copy of each of the Code of Ethics to you upon request. MLPF&S and MAA have each imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions, as well as those of all our employees. Our requirements impose certain responsibilities on Program Advisors and their trading. COMPENSATION, CONFLICTS OF INTEREST AND MATERIAL RELATIONSHIPS Compensation and Benefits to Merrill, Program Advisors and Merrill Management Personnel. Merrill earns revenue from the Program Fee you pay to us under the Program for our Program Advisors providing Program Services, as well as, from commissions, mark-ups and mark-downs, up-front sales charges and other sales charges or fees (“Sales Charges”) paid in connection with brokerage transactions that are effected in brokerage accounts. Merrill also earns revenue from other fees and payments you may make and from what it receives from its Affiliates and from fund managers, product distributors and sponsors and other product providers (“Third-Party Firms”) related to transactions in your Account. Merrill may also receive revenue from Third-Party Firms depending on the investment products in which you invest, which is not part of a financial advisor’s, including a Program Advisor’s, compensation. We (including our Affiliates), the Program Advisors whom you interact with and other of our employees benefit from the fees and charges paid by you and other clients for the Services described in this Brochure. In addition, we earn revenue from the referrals to our Affiliates (including referring to an Affiliate for banking products or services). The amount of revenue we receive varies depending on the type of account relationship you have with us, whether your account is enrolled in the Program or is a brokerage account and investment products in which you invest and the services you use. The revenue we receive from your enrollment in the Program may also be more or less than the revenue that would be received if you had instead participated in other of our investment advisory programs or if you had engaged in the investment activities in a brokerage account. The more assets there are in your Account, the more you will pay in fees, creating a financial incentive for us and your Program Advisor to recommend that you increase the assets in your Account. In the Program, we make more revenue based on the level of assets in the Account. There is a conflict of interest when your Program Advisor recommends an account or program type or investment strategy where it is expected that Merrill will earn greater revenue over another account or program type or investment strategy and therefore will earn more compensation. Program Advisors receive compensation from MLPF&S in the form of a base salary and certain incentive awards related to the amount invested in the Program and in other advisory accounts. Having Accounts enrolled in the Program helps Program Advisors meet certain performance goals. However, Program Advisors do not receive transaction-based compensation nor do they receive a portion of the Program Fee as compensation. Program Advisors are eligible to participate in incentive and recognition programs that are based on meeting certain performance and service goals and such other criteria as MLPF&S may establish from time to time. Program Advisors who recommend or complete the rolling over assets (a “Rollover”) from an employer-sponsored retirement plan (such as a 401(k) plan) or from a retirement account at another firm into an Individual Retirement Account (IRA) and enrolling that IRA into the Program receive compensation or benefit based on the amount of funds transferred. There is a financial incentive for a Program Advisor to recommend a Rollover because the enrollment into the Program will generate revenue to Merrill and benefit the Program Advisor. Program Advisors have a financial incentive to recommend or complete a Rollover because the subsequent or related enrollment into the Program will increase the number of accounts serviced by the Program Advisor and help them achieve certain performance goals. Elements of our field management compensation are based on revenues to Merrill and based on the Program Advisors whom they manage meeting performance and service goals and such other criteria as Merrill may establish from time to time. Management personnel and other employees of Merrill, MAA and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is an incentive for our field management team to encourage Program Advisors to meet their performance and service goals that can result in more revenue to Merrill. There is a financial incentive for Merrill management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. Merrill Edge Advisory Account Program | 22 MESPB 032025 We address the compensation conflicts described in this “Compensation and Benefits to Merrill, Program Advisors and Merrill Management Personnel” section and in other sections of the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure, by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and program choices, account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, our Program Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. We engage in oversight and supervision of particular account type relationships and program choices and we provide account and product disclosures. We maintain policies and procedures and supervisory and review processes that are reasonably designed to ensure that Program Advisors meet the standard of conduct applicable to each client and that compensation plans and referral compensation and criteria have been designed and implemented to mitigate any incentive or conflict to favor any one security type or investment product or service. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. Account and Program Choice. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. You have the ability to enroll accounts in the Program holding some or all of your investment assets and to have brokerage accounts for some or all of your assets. The various programs we offer and ways to interact with Merrill are outlined in our Form CRS, this Brochure and in our Summary of Programs and Services. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. There are differences among the programs and account relationships. You may be able to obtain the same or similar Services or types of investments you obtain in the Program through a brokerage account or other investment advisory programs and services offered by Merrill. These may be available at lower or higher fees than, or the same as, the Program Fee you pay. You may also be able to obtain some or all Services from other firms and at fees that may be lower or higher than the Program Fee we charge. A recommendation of the type of account relationship creates a conflict of interest for us. The amount of revenue we receive depends on the type of account and relationship you choose. In the Program, you will pay the Program Fee. The Program Services provided include ongoing investment advice and guidance for your Account, access to Strategies and ongoing monitoring as described in this Brochure, as well as the services of trade execution, clearance and settlement of transactions and custody of assets. In the Program, the amount of compensation paid to us depends on the level of assets in your Account as well as certain indirect compensation outlined in this Brochure. In a brokerage account, you will pay per trade Sales Charges to purchase and sell securities. In a brokerage account, the amount of revenues we receive depends on the level of trading activity in the Account, the applicable Sales Charges as well as other indirect compensation. Your brokerage account agreement and documents will provide you with information about certain brokerage services and related transaction and account fees for your Merrill account. Certain of the Strategies are available to you outside of the Program for more or less than you would pay in the Program. There are important differences between this Program and our other available investment advisory programs in terms of the services, structure and the applicable fees. When you compare the account types and investment advisory programs and their relative costs with what is available in the Program, you should consider the various factors outlined in the section “Ability to Obtain Certain Services Separately and for Different Fees.” Certain of these factors relate to your preferences regarding the relationship, whether you are seeking ongoing monitoring services provided for in the Program, how you want to pay for investment services, the Program Fee, the level of service and the managed investment solutions you are interested in investing in. A recommendation of the type of account relationship creates a conflict of interest for us and a Program Advisor. We address these conflicts through the disclosure in this Brochure and the Agreement and by providing clients with upfront information about our available programs. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Moreover, our Program Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. Variable Compensation by Product and Service. The revenues we receive from a securities transaction vary based on the type of security or investment product and its terms. For certain securities or investment products, Third-Party Firms make payments to us as compensation for various services and support. These payments also vary depending on the type of security or investment product. In addition, we receive certain payments from mutual fund providers when a mutual fund is used to provide exposure to the investment strategy, like sub-accounting fees. For additional information, please review the “Compensation Received by Us for Sub-accounting Services,” “Mutual Fund Arrangements and Compensation,” and “Other Compensation Received by Us and Our Affiliates” in this section below. Certain of these securities and investment products provide access to similar investment strategies. For example, certain indexed mutual funds may offer an investment approach that is substantially similar to that provided by certain ETFs and there may be an actively managed ETF that provides a substantially similar investment approach to that provided by a mutual fund. However, these are different types of securities and have different product features associated with them, as well as different fees. Not all securities and investment products make payments to us or our Affiliates. The variable nature of third-party payments creates a conflict of interest because we are incentivized to recommend products for which we earn greater compensation rather than other alternatives. We address this conflict through the disclosure in this Brochure and by the CIO selecting investment products and Funds based on the investment merits of the particular investment products and not based on the compensation we receive in providing certain services or under certain arrangements with third- party product providers. Program Advisors do not have an incentive to recommend certain Strategies over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we select investment products and solutions that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Offering of Investments or Programs Managed by Us or Our Affiliates and Use of a Related Strategy in Your Account. We reserve the right to have Merrill, a Merrill Affiliate or a Related Company construct (or provide investment management and advisory services for) a Strategy and charge a separate manager fee. We do not currently offer any Related Funds. We may, however, include Related Funds as an investment product available in the Program in the future. If a Strategy that charges a separate manager fee or a Related Fund is offered as an eligible investment in the Program, we would Merrill Edge Advisory Account Program | 23 MESPB 032025 benefit from our economic interest in such Strategy or Related Fund. A conflict of interest exists when we or your Program Advisor selects or assists you in the selection of, as applicable, a Related Strategy. We address this conflict through disclosure in this Brochure. Our Program Advisors do not have an incentive to recommend certain Strategies over others because they do not receive additional compensation as a result of these types of arrangements. Our Affiliates and related business divisions, such as BANA, offer their own managed products or wrap programs that are similar to this or other Merrill programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including as to recommendations and review determinations. This is due to, among other things, the differing nature of our Affiliate’s investment advisory services and differing processes and criteria upon which determinations are made. The CIO releases information and analyses about a Fund to Merrill, MAA, our Affiliates and financial advisors, including Program Advisors, at the same time. It is possible that our Affiliates and other investors act on that information before Merrill or MAA has had the chance to evaluate and act on those changes. Accounts that commence trading aſter the release of such information will be subject to price movements, particularly with large orders or where securities are thinly traded, that would cause them to receive prices that are less favorable than those potentially obtained by Affiliates or other investors. Compensation Received by Us for Sub-accounting Services. We only make available as part of a Strategy those mutual funds and money market funds (each, a “fund”) and share classes of funds that pay us to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges, dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping, services (together, “sub-accounting services”). Under agreements with each of these funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services to the holders of these funds maintaining shares in an Account as well as in other Merrill securities accounts and receive the agreed upon sub-accounting services fee. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by fund types, fund and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. Due to applicable regulation, we do not retain compensation for sub-accounting services for funds held in Retirement Accounts. For U.S. mutual funds, depending on the specific arrangements, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market mutual funds, the sub-accounting services asset-based fee is generally 0.005% per annum. We have a conflict of interest in selecting certain fund products (or share classes) for inclusion as part of our product offering available to you. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of our product menu but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting services fees that we charge will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the sub-accounting services fees for these services varies among funds and, in certain instances, between share classes of individual funds. This results in a conflict of interest because it creates an incentive for us to recommend that you invest in funds and share classes that pay higher fees. We will receive higher sub-accounting fee payments from fund families that have higher fund assets held in our clients’ accounts if the service fee calculation is based off of the level of the asset holdings. Additionally, there is a benefit to us because the aggregate amount of the sub-accounting fees exceeds the costs to provide these services. We address these conflicts of interest in the following ways. We disclose the nature of our sub-accounting service arrangements. We also determine the compensation paid to our Program Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Program Advisors do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we and our Affiliates select funds that are available on our investment advisory platform and offered through the Program as well as in our brokerage offering based primarily on the CIO Review Process and business reviews. Mutual Fund Arrangements and Compensation. For the mutual funds that are part of a Strategy, your assets are generally invested in the lowest cost share class eligible for the Program. The Program-eligible mutual fund share classes vary depending on the mutual fund, its roster of share classes and our agreements with the funds. In general, the share classes that are eligible for the Program allow for the payment to us of the sub-accounting services fee and do not have annual asset-based fees like Rule 12b-1 fees (although there are some mutual funds that have such fees due to legacy positions that are pending conversion to an eligible share class). Accordingly, you should not assume that you will be invested in the share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. It is generally in your best interest to purchase lower-fee share classes because your returns are not reduced by additional fees and expenses. For clients in the Program, neither the CIO managing the Strategies’ models nor a Program Advisor has an incentive to recommend or select share classes that have higher expense ratios because their respective compensation is not affected by the share class selected. From time to time a fund may authorize us to make available to clients participating in the Program a class of shares of such fund with a lower fee structure that we believe is more beneficial to you than the class of shares previously made available in the Program. Where such exchange is available, under the authority provided to us under the Client Agreement, we will effectuate an exchange to the other class of shares of the same fund with the lower fee structure as promptly as practicable. For additional information on mutual funds and money market funds you can review our “Mutual Fund Investing at Merrill” document available at ml.com/funds and through a Program Advisor upon request. Cash Sweep Program Compensation Received by Us and Our Affiliates. Merrill benefits financially when you hold cash balances in the bank deposit accounts affiliated with the Cash Sweep Program. Merrill receives payments from our Bank Affiliates on a per account basis for each account that sweeps to one of our Bank Affiliates relating to offering and supporting the Cash Sweep Program. The fees we receive from the Bank Affiliates is one of many factors that affect the interest rate paid by the Bank Affiliates on your swept cash balances under the Cash Sweep Program. If you choose the “No Sweep” option, we also benefit from the custody or use of uninvested cash balances also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. For deposits unrelated to the Cash Sweep Program to our Bank Affiliates relating to referrals, we are entitled to receive a fee directly from each Bank Affiliate based on the daily deposit balance, which fee can be waived in whole or in part. Merrill Edge Advisory Account Program | 24 MESPB 032025 The Bank Affiliates benefit financially from the Cash Sweep Program. Through the Cash Sweep Program, they receive a stable, cost-effective source of funding. They use the cash funds deposited in the bank deposits to fund their current and future lending, investment and other business activities. The participation of the Bank Affiliates in the Cash Sweep Program increases their respective deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” they earn on the deposits— the difference between the interest paid on the bank deposits and other amounts paid to Merrill related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in your Account (a result of a recommendation from the CIO) that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more our Bank Affiliates benefit. Cash balances swept to a bank deposit account of our Bank Affiliates under the Cash Sweep Program will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts is periodically set and reset by the Bank Affiliates in their discretion. Interest rates for the MLBD Program and RASP are tiered based upon your relationship with Merrill and Accounts that enroll in the Program and in specified Merrill investment advisory programs receive the highest tier rate available under the Cash Sweep Program. The interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. We address the conflicts of interests associated with the Cash Sweep Program and the deposit accounts in a variety of ways, including through disclosure in this Brochure, by requiring clients to affirm their interest for the Cash Sweep Program options in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to your participation in the Cash Sweep Program. Program Advisors do not receive any additional compensation for assets held in the Cash Sweep Program as opposed to another cash alternative product. We have adopted various policies and procedures reasonably designed to prevent the cash sweep arrangement compensation and other business arrangements from affecting the nature of the advice we and our financial advisors provide. Other Compensation Received by Us and Our Affiliates. Separate and apart from the Program, Merrill, through its Program Advisors, may suggest or recommend that you use the Merrill securities account and our execution and custody or other services for other of your investment activity or use the services of our Affiliates. Similarly, Program Advisors may suggest or recommend that you purchase our products or those of our Affiliates. Where you use or purchase our or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Except as otherwise noted below, our Program Advisors will not receive compensation related to the Affiliate revenues that are earned or compensation that is paid to the Affiliate. We address the conflicts of interest presented by these Affiliate transactions by determining the compensation for Program Advisors based on a salary and not on revenues we receive from such transactions and having in place various policies and procedures reasonably designed to prevent the receipt of compensation by Merrill and its Affiliates and other business arrangements from affecting the nature of the advice we provide, although such policies and procedures do not eliminate such conflicts of interest. Compensation Received by Us and Our Affiliates for Principal Trading and Agency Cross Transactions. Where permitted by regulation, Merrill may execute certain transactions on a principal basis through its Affiliates (including BofAS). Transactions that are considered principal transactions include our new issue offerings where we or our Affiliates act as an underwriter, selling group member or placement agent. In addition, our Affiliates can act in a principal capacity under certain circumstances when we execute transactions for your Account. In a trade executed in a principal capacity, our Affiliate acts as your trade counterparty and it can act as a market maker for, or have a proprietary position in, the securities that are the subject of the transaction. We and our Affiliates receive compensation in connection with principal transactions, including markups, markdowns, underwriting discounts, selling concessions and other compensation. We and our Affiliates can profit from transacting as your counterparty or having proprietary positions in the subject securities. Moreover, we have an incentive to recommend a transaction in a security that our Affiliate maintains in inventory that is otherwise difficult to sell. Except where prohibited by law, Merrill may engage in agency cross transactions. Other than transactions in a Retirement Account, Merrill may engage in agency cross transactions when it acts as agent for both buyer and seller in a transaction. If this type of trading execution occurs, since Merrill generally receives compensation from each party to an agency cross transaction, there is a conflict of interest between our obligations to you and to the other party to the transaction. Third-Party Firm Business Relationships and Support. We and our Affiliates have business relationships with Third-Party Firms, which include third- party managers of Funds available in the Program as well as Funds, investment strategies, insurance companies and other product providers offered in other of our investment advisory programs and in brokerage accounts. We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for funds and product vehicles managed or sponsored by them (e.g., mutual funds and ETFs). We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates by a Third-Party Firm is additional compensation to us for services we and our Affiliates provide. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Program Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our Program Advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, we select Strategies and constituent Funds that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and Merrill Edge Advisory Account Program | 25 MESPB 032025 procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our financial advisors provide. Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (“Conferences”) for invited Merrill financial professionals. These financial professionals include financial advisors, including Program Advisors, employees who work for a Merrill branch, market or division to support the financial advisors (“Field Management Employees”) and employees who cover product, Chief Investment Office and home office support functions (“Non-Field Employees”). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third-Party Firms participate (“Client Events”). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending financial advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with a number of Conferences and Client Events in the amount of approximately $21 million. Certain Third-Party Firms periodically host or participate in meetings (“Manager Meetings”) where they provide certain financial advisors, Field Management Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending financial advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of charitable events and causes that we requested or initiated with the Third-Party Manager in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives to recommend products of participating Third-Party Firms. They give those participating in Conferences, Client Meetings, Manager Meetings and charitable events with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for Field Management Employees to approve those recommendations and for non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our financial advisors, including Program Advisors, to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Management Employees to approve recommendations of products and services of those participating Third-Party Firms. Furthermore, we do not incentivize Non-Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. Third-Party Firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs of Conference and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Representatives of Third-Party Firms will, from time to time, meet and work with our financial advisors and other employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third- Party Firms from providing or paying for, and our financial advisors and other employees, from receiving, gifts and entertainment (including meals) other than as permitted by and subject to the limits established under Merrill internal policies. In general, they may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting Third-Party Firm representatives access to our financial professionals and providing gifts and entertainment present a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. It can also create incentives for Field Management Employees to approve recommendations of a financial advisor, where required. Furthermore, providing gifts and entertainment to Non-Field Employees creates incentives to approve the investment products of the Third-Party Firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. Provision of Diversified Financial Services by Us or Our Affiliates. BofA Corp. is a diversified financial services company that generally provides, through us and our Affiliates, a wide range of services to retail and institutional clients for which it receives compensation. As a result, we, BofA Corp. and our Affiliates, can be expected to pursue additional business opportunities with the entities whose Funds we make available through the Program. Consistent with industry regulations, these services that we and our Affiliates provide include (but are not limited to): banking and lending services, sponsorship of deferred compensation and retirement plans, recordkeeping services, investment banking, securities research, institutional trading and prime brokerage services, custody services, investment advisory services, licensing arrangements involving indices and effecting portfolio securities transactions for Funds and other clients. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships is publicly available in Regulation NMS Rule 606 reports we file with the SEC. Merrill Edge Advisory Account Program | 26 MESPB 032025 PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND CONFLICTS OF INTEREST There are various ways that we can be viewed as participating or having an interest in client transactions. These situations and any conflicts of interest arising from such activities, execution approach or other capabilities we offer in the Program are discussed in this section and throughout the Brochure. Cash Balances and Cash Sweep Program. The Sweep Program Guide for Merrill Clients provides information on the fees that Merrill receives from the Bank Affiliates for each account, including Program Accounts, that sweeps to the MLBD Program and the RASP. These fees are up to $100 per year for each account received from the Bank Affiliates. This compensation is subject to change from time to time, and Merrill may waive all or part of it. Merrill may benefit from the possession or use of cash balances, also known as free credit balances, in your accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. See “Item 9 Compensation, Conflicts of Interest and Material Relationships— Cash Sweep Program Compensation Received by Us and Our Affiliates.” Participation in Affiliate Lending Programs and Margin. There are conflicts of interest when you use a loan from Merrill or one of its Affiliates secured by your Account assets as collateral. These conflicts exist with a margin loan from Merrill or with any of our Affiliate lending programs that may be available to you from an Affiliate lender. In the case of a loan from our Affiliate, including but not limited to the Loan Management Account® product (“LMA® account”), the Affiliate lender intends to derive a profit as lender based on interest and/or fees, if any, charged on the loan. The lender, whether it be Merrill or its Affiliate, has a lien on your Account assets that are used as collateral for the loan. The lender will act to protect itself as lender in connection with the loan, and this may be contrary to your interests and/or investment objectives. Having a lien on your Account in connection with an Affiliate loan also creates a conflict of interest with respect to the recommendations we make to you. For example, your Program Advisor may recommend that you allocate your investments to your Account that has an Affiliate lender’s lien rather than to another Account without such lien. Please refer to “Item 6 Investment Strategies and Risk of Loss” for additional information. Activity by Merrill, Affiliates and Personnel. As part of a global financial services firm, Merrill will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by Merrill or any of its Affiliates, it or its Affiliates’ roles in connection with other clients and in the capital markets, its internal policies, and/or potential reputational risk. As a result, client accounts managed by Merrill may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by BofA Corp. From time to time in the course of our and our Affiliates’ business dealings described in this Brochure, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. See ”Conflicts of Interest and Information Walls” in this Item 9. We and our Affiliates act in a variety of capacities to a wide range of clients. We may give advice or take action with regard to certain clients, including clients in the Program, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken for certain securities, Funds or investment managers. In some instances, the actions taken by Affiliates for similar services and programs will conflict with the actions taken by us. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. In addition, potential conflicts of interest also exist when Merrill maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon Merrill or its Affiliates by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude, the inclusion of particular securities, Funds or financial instruments in a client’s Accounts where Merrill and its financial advisors or MAA provide discretionary management services, even if the securities, Fund or financial instruments would otherwise meet the investment objectives of such Account. Merrill and its Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs by Merrill, its Affiliates and those of their clients that have granted discretion to Merrill, its Affiliates and/or Merrill financial advisors (discretionary clients) to avoid potential restrictions on the ability of Merrill and its Affiliates to engage in principal trading and other transactions with such funds. Registered Funds identified by us for these limitations from time to time are referred to as “In-Scope Funds.” A portion of the aggregate ownership limit is attributed to our Affiliates. When Merrill and its Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to Merrill or its Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because Merrill’s and its Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest for Merrill in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. We reserve the right to have Merrill, a Merrill Affiliate or a Related Company construct (or provide investment management and advisory services for) a Strategy and charge a separate manager fee. In such case, we and/or the Merrill Affiliate or Related Company retain both the Program Fee and the manager fee. We and our Affiliates provide some or all of the same services offered in the Program through other financial firms, affiliated or unaffiliated with us, which offer programs similar to the Program at fee rates that differ from the Program Fee. We or one of our Affiliates may have a position in or enter into “proprietary” transactions in securities purchased or sold for clients, including clients participating in the Program. We or our Affiliates may benefit from such securities positions or transactions. From time to time, however, a Fund selected for a Strategy may invest in securities issued by BofA Corp. or its Affiliates in seeking to achieve its investment objective. Any such investments by a Fund are required to comply with the applicable provisions of the Investment Company Act of 1940, as amended, including limitations on investments in securities-related businesses, and will not be influenced by MLPF&S or MAA. Our employees, including Program Advisors, may refer clients to BANA, BofAS and other Affiliates for financial services that they provide, including transaction execution and investment banking services and products (including banking products). Similarly, employees of BANA and its Affiliates may refer clients to us for brokerage and investment advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. As permitted by applicable law, Program Advisors receive compensation for referring clients to our Affiliates, the amount of which varies by service and product and can be significant. This results in a conflict of interest because we are incentivized to introduce services that provide us or our Affiliates additional compensation. Merrill Edge Advisory Account Program | 27 MESPB 032025 From time to time, a shareholder of BofA Corp. could acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Account, such as buying or selling securities issued by the shareholder or its Affiliates, will be limited. We address these conflicts in a variety of ways, including through disclosure in this Brochure. In addition, our Program Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for each client based upon investment objectives, risk tolerance and financial situation and needs. We also have a variety of restrictions, procedures and disclosures designed to address potential conflicts of interest – both those arising between and among Accounts as well as between Accounts and our business (e.g., personal trading preapprovals, self-reporting, restrictions on our personnel detailed in our policies and procedures and Code of Ethics). We have also adopted various policies and procedures reasonably designed to prevent the receipt of any referral compensation and other business arrangements from affecting the nature of the advice we and our Program Advisors provide, although such policies and procedures do not eliminate such conflicts of interest. Trade Execution. We or our Affiliate may execute transactions in your Account on a principal basis (that is, when we or our Affiliate sell a security to you, or buy a security from you, for our own account) as permitted by law, and upon your consent (when required by applicable regulations). Principal transactions may give you access to investment opportunities or trade executions that might not otherwise be available to you, such as trading of fractional shares within your Account. Principal transactions may not be effected for Retirement Accounts, except in accordance with applicable law. There are conflicts of interest present when we execute transactions in your Account on a principal basis. If Merrill effects a principal transaction for your Account, then in addition to the Program Fee, we receive a commission, markup or markdown, underwriting fee or selling concession, or other compensation with respect to the transaction, which would result in additional compensation or other benefit to us or our Affiliate. We also benefit from the “spread” or the difference between the price we pay for a security and the price at which we sell it to you, or between the price we may pay for a security that we may buy from you and the price for which we may later sell it. In addition, we have an incentive to recommend a transaction in a security that we maintain in our inventory that is otherwise difficult for us to sell. The receipt of additional compensation and an incentive to recommend a transaction involving our inventory present conflicts between our interest and yours. The types of securities that may be purchased or sold on a principal basis in your Account pursuant to the terms of your Client Agreement may change in the future and could become more limited. We may, at times, have the opportunity to act as agent for both buyer and seller in a transaction for your Account. This is called an agency-cross transaction. Since we generally will receive compensation from each party to an agency-cross transaction, there is a potential conflict between our responsibilities and loyalties to you and to the other party to the transaction. Any compensation we receive will be in addition to the Program Fee. The Client Agreement generally gives us permission to engage in agency cross transactions for your Account, except where prohibited by law. You may revoke your consent at any time by notifying us in writing. At times, we may consider a security being sold by one investment advisory client to be appropriate for purchase by another investment advisory client account. In such cases, we may arrange to transfer or “cross” the security directly between the affected accounts. Any cross transactions in your Account would be effected in accordance with applicable law and your Client Agreement. Cross transactions generally will be effected at an independently determined market price and will not result in any additional compensation to us. For a Retirement Account that is subject to ERISA or the Code’s prohibited transaction rules, transactions, including agency-cross transactions, will be effected by or through Merrill or our Affiliates in compliance with ERISA Section 408(b)(19), U.S. Department of Labor Prohibited Transaction Exemption 86-128, or otherwise in a manner that is not prohibited by ERISA or the Code. We do not receive payment for order flow from liquidity providers to which we route our customer orders in equity securities. We directly or indirectly (through our Affiliates) receive rebates from, and pay fees to, certain registered securities exchanges for providing or taking liquidity on those exchanges, according to those exchanges’ published fee schedules filed with the SEC. In some cases, the rebates received by us from an exchange will, over a period of time, exceed the fees paid to the exchange. The rebates and payments from these third parties vary depending on the order and the exchange to which orders are directed and create a conflict of interest because we are incentivized to recommend transactions that provide us with greater rebates or payments from these exchanges. Covered Entities under the Volcker Rule. We may provide certain entity clients that qualify as “family wealth management vehicles,” or FWMV clients, with both the Program Services as well as lending services and to engage, where permitted, in principal transactions. In doing so, we rely on the exception under the Volcker Rule implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Client Agreement. For certain entity clients that are deemed ”covered fund” clients under the Volcker Rule, we are not permitted to offer both Program Services and the availability of margin, lending or other extensions of credit from us or any of our Affiliates, including BANA, or engage in certain principal transactions. Certain other transactions between BANA or its Affiliates and the entity client will also be prohibited. ACCOUNT REVIEWS AND REPORTING An important part of the Program relationship involves providing you with the opportunity to engage in periodic reviews with a Program Advisor. These reviews provide updates on the progress of your Account towards your goals and other important information about your investments. This review is also an opportunity to ensure that the information you provide is complete, accurate and reflects your financial situation and objectives for the Accounts enrolled in the Program. We will contact you to request that you review your information for each of the Accounts in the Program and ensure that it is up to date. As noted above, if there are multiple owners on this Account, the information you provide should reflect the views and circumstances of all owners on the Account. If you are the fiduciary of this Account for the benefit of the account owner or account holder (e.g., the trustee for a trust or custodian for an UTMA), please keep in mind that these assets will be invested for the benefit of such account owner or account holder. A periodic review of your Account should typically occur on an annual basis; however, under our Program guidelines, we have the ability to extend or defer the timing of the review under certain circumstances and for certain periods of time. Because these reviews provide you with important and necessary information relating to your Account, you are required to take advantage of these opportunities to participate in Account reviews. If you do not participate in your Account review, we may terminate your Account from the Program in our discretion. Merrill Edge Advisory Account Program | 28 MESPB 032025 We will periodically communicate to you important information about how we are managing your assets in the Program. The primary means through which we will communicate with you and memorialize in writing the important terms, conditions and information about your Portfolios, Accounts and Strategies, is through a Program Report. You will receive your first Program Report from us aſter we accept your enrollment in the Program and each time you make changes to certain of the Services you elect, including, but not limited to, when you add Portfolios or Accounts, add or change Strategies in each Portfolio and change your Target Asset Allocation. You should review each Program Report we send to you carefully to ensure that the information reflected therein is accurate and you should contact a Program Advisor if you believe any of the information is, or becomes, inaccurate. We will send you periodic updates that contain information about your Portfolios and Accounts, including trade confirmation information and account statements. We will also provide you with periodic performance reports to help you monitor and assess the performance of your Portfolios, Accounts and the Strategies you select. These reports contain information regarding investment return, risk and selected benchmark comparisons for your assets in each Strategy you select. You should review all such materials carefully and promptly report any discrepancies to a Program Advisor. We reserve the right to change the format, content and nature of the presentation of information in the Program Report in our sole discretion. The Program Report or other Program communications, including those prepared or delivered in a digital or electronic format, may also include information about your accounts that are not subject to the Agreement, including, in our discretion, your brokerage accounts, other investment advisory program accounts and banking relationships and accounts held at other financial institutions. Their inclusion in a Program Report or other materials is provided for your information only and does not change the nature of our obligations to you under agreements related to those accounts and relationships. The Program Fee will not apply to these accounts or relationships, and we will not be an investment adviser or a fiduciary with respect to the assets in such accounts, solely by virtue of their inclusion in a Program Report or other materials we provide. Any such included accounts will continue to be subject to the terms and conditions of the applicable securities or other account agreements. Any advice that we may provide to you with respect to the assets in such accounts, including asset allocation advice, will be incidental to the services that we provide to you under the other applicable securities or other account agreements. REFERRALS AND OTHER ARRANGEMENTS Our Program Advisors are not permitted to give to you or accept from you any fee, kickback, or other thing of value, including, gifts, meals, or entertainment pursuant to any agreement or understanding, oral or otherwise, for receiving or referring business. Our employees may refer advisory clients to BANA, including its private bank, BofAS and other of our Affiliates for products and services. Similarly, employees of BANA and its Affiliates may refer clients to us for brokerage or advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. For more information, see the section “Participation or Interest in Client Transactions and Conflicts of Interest— Activity by Merrill, its Personnel and Affiliates.” We enter into marketing arrangements with third parties who, for compensation, provide consulting or other services to us in connection with the marketing of our various advisory programs. Any such marketing arrangement is governed by a written agreement between us, as applicable, and the third party, and will be disclosed to you, as required by law. FINANCIAL INFORMATION Not applicable because (1) Merrill is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act (2) Merrill and MAA do not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (3) there is no financial condition of which we are aware that is reasonably likely to impair Merrill’s or MAA’s ability to meet contractual commitments to its clients; and (4) Merrill or MAA each has not been the subject of a bankruptcy petition at any time during the past 10 years. Merrill Edge Advisory Account Program | 29 MESPB 032025 Glossary “Account” means each of the securities accounts to which the Client Agreement applies and that are enrolled in the Program, and as set forth in the Program Report. “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Affiliate” means a company that is controlled by, in control of, or under common control with another company. “Alternative Investments” means such investments as we designate from time-to-time in our sole discretion whose risk and return characteristics generally are not correlated with more traditional investments (i.e., equities, fixed income and cash). This term includes non-traditional mutual funds. “Annual asset based fees” means those fees imposed by mutual funds on an annual basis, like service fees and Rule 12b-1 fees. “Authority” means the authority to make certain investment and trading decisions with respect to the assets in an Account as described in “Item 4 Investment Strategy Services.” “Bank Affiliate” means Bank of America, National Association (BANA) or other banks that are affiliated with us. “BofAS” means BofA Securities, Inc., an Affiliate of Merrill. “Cash Sweep Program” means the program provided as part of your securities account whereby cash balances in your Account are automatically swept into a cash sweep option available for your Account type. “CIO” means the Chief Investment Office. The CIO is a Merrill business group providing investment solutions, portfolio construction advice and wealth management guidance to MLPF&S financial representatives and clients. “Client Agreement” means the investment advisory agreement relating to the Program among the Client, MAA and MLPF&S, as it may be amended from time to time. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “FDIC” means the Federal Deposit Insurance Corporation. “FINRA” means the Financial Industry Regulatory Authority, Inc. “Fund” means registered investment companies that are mutual funds and ETFs. “MLBD Program” means the Merrill Lynch Bank Deposit Program. “NTF” means a nontraditional mutual fund or ETF registered with the SEC that is classified as an Alternative Investment by us because its principal investment strategies utilize alternative investment strategies or provide for alternative asset exposure as the means to seek to meet its investment objectives. “Offering Materials” means the prospectus or other offering and disclosure documents relating to a Fund. “Program” means the Merrill Edge Advisory Account Program. “Program Advisor” means a Merrill Lynch representative with the title or designation of “Financial Solutions Advisor”. “RASP” means the Retirement Asset Savings Program. “Reasonable Investment Restrictions” means one or more reasonable investment restrictions accepted by us that you would like to impose for any Account, such as identifying a Fund that should not be purchased. “Registered Fund” means any Fund that is registered under the Investment Company Act of 1940, as amended, including mutual funds, closed-end funds, ETFs and money market funds. “Related Company” means a company that is an Affiliate of BANA or in which BANA or an Affiliate of BANA or of BofA Corp. has a material ownership interest. “Related Fund” means any Fund sponsored, managed, or advised by us, a Related Company or any of our Affiliates. “Retirement Account” means an ERISA Plan, a U.S. tax-qualified plan of self-employed persons, a U.S. individual retirement account, or any other plan, arrangement or entity subject to Section 4975 of the U.S. Internal Revenue Code of 1986, as amended. “Rule 12b-1 Fees” means fees paid for the distribution of mutual funds pursuant to a plan made under Rule 12b-1 under the Investment Company Act of 1940, as amended. “SEC” means the United States Securities and Exchange Commission. “Services” means the services provided in the Program described in this Brochure. “Strategy” means an investment strategy developed by the CIO to align to a particular Target Asset Allocation. “Target Asset Allocation” means a recommended allocation of assets in a portfolio across one or more asset classes. The Target Asset Allocation categories used in this Program are: • Conservative — primary focus is on portfolio stability and preservation of capital with the achievement of low or negative investment returns in exchange for reduced risk of loss of principal and liquidity. • Moderately Conservative — primary focus is to achieve a modest level of portfolio appreciation with minimal principal loss and volatility. • Moderate — primary emphasis is to strike a balance between portfolio stability and portfolio appreciation with the assumption of moderate level of risk and level of volatility and principal loss. • Moderately Aggressive — primary emphasis is on achieving portfolio appreciation over time with the assumption of a fair amount of risk, and high level of volatility and risk of principal loss. • Aggressive — primary emphasis is on achieving above-average portfolio appreciation over time with the assumption of substantial risk and a significant level of portfolio volatility. “Unaffiliated Trade Counterparty” means a bank, broker or dealer other than an Affiliate of Merrill. L-03-25 Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. ©2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated. Printed in the U.S.A. Merrill Edge Advisory Account Program | 30 MESPB 032025

Merrill Lynch Institutional Investment Consulting Program NON-WRAP FEE PROGRAM BROCHURE Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 (800) 637-7455 www.ml.com This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or “Merrill”) relating to the Merrill Lynch Institutional Investment Consulting Program. If you have any questions about the contents of this Brochure, please contact us at 800.MERRILL (800.637.7455). Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about MLPF&S also is available on the SEC’s website at https://www.adviserinfo.sec.gov/. The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency, are not a deposit or other obligation of or guaranteed by MLPF&S, Bank of America Corporation (“BofA Corp.”) or any of its affiliates and are subject to investment risks, including possible loss of principal. March 21, 2025 Workplace Benefits is the institutional retirement and benefits business of Bank of America Corporation (“BofA Corp.”) operating under the name “Bank of America.” Investment advisory and brokerage services are provided by wholly owned non-bank affiliates of BofA Corp., including Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as "MLPF&S" or "Merrill"), a dually registered broker-dealer and investment adviser and Member SIPC. Banking activities may be performed by wholly owned banking affiliates of BofA Corp., including Bank of America, N.A., Member FDIC. Investment products: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value  Merrill Lynch Institutional Investment Consulting Brochure MATERIAL CHANGES On March 22, 2024, Merrill filed its last annual update for its Merrill Lynch Institutional Investment Consulting Program brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated the “Disciplinary Information” section to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our Advisors, field management employees and non-field employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Client Referrals and Other Compensation” at section “B. 1. Relationships With Third-Party Firms - Third-Party Firm Office Access, Gifts and Entertainment.” MATERIAL CHANGES MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes • We updated the “Disciplinary Information” section to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over- exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” Institutional Investment Consulting Brochure | I  Merrill Lynch Institutional Investment Consulting Brochure TABLE OF CONTENTS I MATERIAL CHANGES ..................................................................................................................................................... TABLE OF CONTENTS 1 .................................................................................................................................................. ADVISORY BUSINESS About Merrill Lynch, Pierce, Fenner & Smith Incorporated Institutional Investment Consulting Summary Description of Services Investment Advisory Agreement Detailed Description of Services Asset Allocation .................................................................................................................................................. ...................................................................................... ............................................................................................................................. ......................................................................................................................... .......................................................................................................................... ........................................................................................................................... ........................................................................................................................................... .............................................................................................. ......................................................................................................... ........................................................................................................ ............................................................................................... ................................................................................................. ............................................................................................................ Strategeic Allocation Modeling Service Asset Liability Modeling Service Ongoing Asset Allocation Advice Investment Policy Statement (“IPS”) Service Manager Searches and Recommendations Investment Performance Reporting Limitation of Services Termination Qualifications of Designated Advisors Other Investment Advisory Programs .......................................................................................................................................... ........................................................................................................................................................ ................................................................................................................ ................................................................................................................ ......................................................................................................................................... Assets Under Management 4 4 4 4 5 6 6 6 7 7 8 8 9 10 11 11 11 12 FEES AND COMPENSATION Program Fees Calculation of Program Fees Asset-Based Fee Rate Fixed Dollar Fee Initial Billing of Program Fees Billing Upon Termination of Service ...................................................................................................................................... ................................................................................................................................................................ ....................................................................................................................................... ........................................................................................................................ ................................................................................................................................ ............................................................................................................................. ................................................................................................................... ........................................................................................................................................... ............................................................................................................................................ ............................................................. ...................................................................................................................................................... ........................................................................................................................ 12 12 13 13 13 13 13 14 14 14 14 14 Payment of Program Fees Other Fees and Expenses Compensation for the Sale of Securities or Other Investment Products Sources of Revenue Conducting Business Through Merrill ......................................................................... PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 15 .................................................................................................................................................... TYPES OF CLIENTS 15 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Asset Allocation ........................................................... ............................................................................................................................................................ ................................................................................................................ ............................................................................................................................. .................................................................................... ................................................................................................................. ................................................................. ................................................................................................................. Strategic Allocation Modeling Service Monte Carlo Simulation Merrill’s Capital Market Assumptions Framework Expected-Return Methodology Standard Deviation and Correlation Coefficient Methodology Forecasted Annualized Returns 15 15 15 15 16 16 17 17 Institutional Investment Consulting Brochure | 1  Merrill Lynch Institutional Investment Consulting Brochure Market Risks Risks in Alternative Investments Risks in Private Equity Past Performance is No Guarantee of Future Results Asset Liability Modeling Service Investment Policy Statement Service Manager Searches and Recommendations Manager Identification Report IIC Eligible Strategies Review Process Information Available to Designated Advisors Regarding IIC Eligible Strategies Status Change of IIC Eligible Strategies Portfolio Evaluation, Review, and Reporting .............................................................................................................................................. ................................................................................................................ ................................................................................................................................ ............................................................................... ......................................................................................................................... ....................................................................................................................... ............................................................................................................. ........................................................................................................................... ........................................................................................................................................... .......................................................................................................................................... ....................................... ...................................................................................................... ............................................................................................. ...................................................................................................................................................... ............................................................................................................. ......................................................................................................................... ............................................................................................................................... 17 17 18 19 19 20 21 21 22 22 23 23 23 24 24 25 26 Pricing of Securities Risks Associated With Certain Investments Information and Cybersecurity Risks ESG-themed Strategies or Funds .................................................................................................................. IMPORTANT CLIENT RESPONSIBILITIES 27 DISCIPLINARY INFORMATION .................................................................................................................................. 28 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .............................................................................. 29 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Conflicts of Interest and Information Walls Code of Ethics Compensation, Conflicts of Interest and Material Relationships Sales Compensation – Benefits to Merrill and Designated Advisors from Enrolling in IIC Compensation and Benefits to Merrill and Designated Advisors Field Management and Merrill Management Compensation Account and Program Choice Mutual Fund Related Compensation; Other Compensation Participation or Interest in Client Transactions Related Persons Covered Entities Under the Volcker Rule Securities Trading by Merrill and Our Personnel ......... .............................................................................................................. ................................................................................................................................................................ ......................................................................... ................................. ....................................................................... ............................................................................ ............................................................................................................................. .............................................................................. ........................................................................................................ ............................................................................................................................................................ .................................................................................................................. ...................................................................................................... 30 30 31 31 31 32 33 34 34 35 36 36 37 BROKERAGE PRACTICES 37 .......................................................................................................................................... REVIEW OF ACCOUNTS ............................................................................................................................................. 37 CLIENT REFERRALS AND OTHER COMPENSATION Compensation for Client Referrals Other Compensation Relationships with Third-Party Firms ................................................................................................ ............................................................................................................................. .................................................................................................................................................... .................................................................................................................. ...................................................................... 38 38 38 38 38 Provision of Diversified Financial Services by Us and our Affiliates Third-Party Firm Business Relationships and Support Participation and Sponsorship by Third-Party Firms for Merrill Conferences, Manager Meetings ...................................................................................................................... and Charitable Events ........................................................... Third-Party Firm Office Access and Gifts and Entertainment .................................................................... 39 40 40 CUSTODY 41 .................................................................................................................................................................... Institutional Investment Consulting Brochure | 2  Merrill Lynch Institutional Investment Consulting Brochure INVESTMENT DISCRETION ........................................................................................................................................ 41 VOTING CLIENT SECURITIES ..................................................................................................................................... 41 FINANCIAL INFORMATION ........................................................................................................................................ 41 GLOSSARY ................................................................................................................................................................. 42 All capitalized terms used in the Brochure are defined in the body of this Brochure and/or in the Glossary. Institutional Investment Consulting Brochure | 3  Merrill Lynch Institutional Investment Consulting Brochure This Brochure, as amended or updated from time to time relates to the Merrill Lynch Institutional Investment Consulting Program (the “Program” or “IIC”) offered by Merrill Lynch, Pierce, Fenner & Smith Incorporated (referred to in this Brochure as “Merrill,” “MLPF&S,” “we,” “us,” or “our”). For purposes of this Brochure, “client,” “you,” or “your” refers to the client enumerated in the Institutional Investment Consulting Client Agreement (the “Client Agreement”). ADVISORY BUSINESS A. ABOUT MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED Merrill, an indirect wholly-owned subsidiary of Bank of America Corporation (“BofA Corp”), is a global financial services firm that offers a broad range of brokerage, investment advisory, retail and other services. Merrill is registered with the U.S. Securities and Exchange Commission (“SEC”) as a broker-dealer and has been registered as an investment adviser since 1978. Investment advisory and brokerage services are separate and distinct, and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in our Client Relationship Summary on Form CRS (“Form CRS”), and in the “Summary of Programs and Services”, available upon request from your Advisor. B. INSTITUTIONAL INVESTMENT CONSULTING Merrill agrees in the Client Agreement to provide non-discretionary investment advice as an investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”) to you under the Program. If your investment portfolio is subject to Employee Retirement Income Security Act of 1974, as amended (“ERISA”), Merrill also agrees in the Client Agreement to provide non-discretionary investment advice as a fiduciary under section 3(21)(A)(ii) of ERISA to you under the Program. 1. Summary Description of Services Under the non-wrap fee Program, a client receives certain asset allocation services for an investment portfolio, investment policy statement services, and investment manager and strategy review and recommendation services along with periodic investment reporting. If a client’s investment portfolio is for a defined benefit plan, a client also receives an asset liability modeling service provided the investment portfolio meets certain requirements and the client requests such services. Merrill provides the Program services through a select group of Merrill Advisors who are designated to provide Program services (“Designated Advisor”). We provide a disclosure document called the "Form ADV Part 2B - Brochure Supplement" which describes information about the Advisor you are working with, their designation, role and the services they can provide, among other things. We can change our designations, roles and services for our Advisors at our discretion and at any time. Before you select the Program, we want to highlight the following to you: • You enter into a Client Agreement with Merrill for the Program services you receive; • As described in detail in this Brochure, you agree to pay Merrill a fee which will be an annual fixed dollar amount or an annual amount resulting from an annual asset-based fee rate applied to your investment portfolio as defined in your Client Agreement Institutional Investment Consulting Brochure | 4  Merrill Lynch Institutional Investment Consulting Brochure • The Program fee is based on the totality of the services and is negotiable depending on a number of factors (see sections “Fees and Compensation: Program Fees” and “Compensation, Conflicts of Interest and Material Relationships: Sales Compensation - Benefits to Merrill and Designated Advisors from Enrolling in IIC” and “Compensation and Benefits to Merrill and Designated Advisors” for details) • You will need to enter into a separate agreement with each of your selected investment managers and these investment managers will each charge you a separate investment management fee for services; • As long as you are a client in this Program and your investment portfolio is subject to ERISA, Merrill and its Affiliates may not accept you as a client in other investment advisory programs or brokerage accounts. • • We are not responsible for the management of your investment portfolio assets through the Program. The investment manager you select and retain is exclusively responsible for the management of the assets in your investment portfolio that you assign to such investment manager. If your investment portfolio is not subject to ERISA, you may elect to implement Program recommendations through another investment advisory program offered by Merrill and its Affiliates: o You will sign a separate investment advisory agreement for the services provided through that program. o You will be charged a separate fee through other investment advisory programs and the fee calculation and billing methodology will differ from that of this Program. o The profiling process, program guidelines and requirements of other investment advisory programs will differ from that of this Program. o o Advice and/or recommendations and investment solutions available in other investment advisory programs are not limited by the investment policy statement (“IPS”) created through this Program or if using your own IPS, the written confirmation of your investment guidelines that you will receive from Merrill, and may not align to IIC Eligible Strategies. (see Methods of Analysis-Manager Searches and Recommendations) If implementation in other investment advisory programs results in a misalignment with the Program guidelines, we may, at our discretion and with notice to you, terminate you as a Program client. This Program is available to charitable organizations, pension, welfare benefit and profit sharing plans, corporations, high net worth individuals, trusts, and estates. A more detailed description of the Program is provided elsewhere in this Brochure, along with other material information about Merrill. Before selecting this Program, please review this Brochure carefully and speak with your Designated Advisor if you have any questions. Investment Advisory Agreement 2. With respect to the Program, the scope of any investment advisory relationship we have with you is defined in the Client Agreement that you sign. Under the Program, we act as your investment adviser only for the investment portfolio specifically identified by you. We will not act as an investment adviser for you for any other assets or accounts, including any other employee benefit plans, unless otherwise separately agreed to by Merrill and you in writing. Our advisory relationship begins when we enter into the Client Agreement with you, which occurs when we accept your signed Client Agreement. Preliminary discussions or recommendations, including any Request for Proposal or Request for Information responses before we enter into the Client Agreement with you are not intended as investment advice and should not be relied upon as such. By participating in the Program, you acknowledge that the services we are providing in the Program are Institutional Investment Consulting Brochure | 5  Merrill Lynch Institutional Investment Consulting Brochure non-discretionary and that you have retained, and will exercise, final decision-making authority and responsibility for all matters concerning the investment portfolio as well as for the selection of an investment manager and implementation of any investment strategy resulting from the services provided under the Client Agreement. If your investment portfolio is subject to ERISA, Merrill agrees that it will be an ERISA fiduciary to the extent that we render investment advice within the meaning of section 3(21)(A)(ii) of ERISA to you regarding your investment portfolio, including but not limited to the recommendation of IIC Eligible Strategies as defined below. You may make decisions with respect to your investment portfolio that are contrary to our recommendations, or make your own decisions without the benefit of our advice, including retaining an investment manager or strategy we do not review or recommend. However, if you disregard our advice, we may, at our discretion and with notice to you, terminate you as a Program client. 3. Detailed Description of Services What follows is a detailed description of the services included in the Program: ASSET ALLOCATION Strategic Allocation Modeling Service Merrill will assist you in identifying an appropriate long-term strategic asset allocation for your portfolio’s specific investment goals and objectives. The recommendation of a strategic asset allocation will be provided by your Designated Advisor to you in a report. Please note that alternative asset allocations based on different assumptions, such as different risk tolerances, may be presented for comparison purposes in your report. However, these alternative asset allocations are not intended to be our recommendation. Under this service, sophisticated computer models are used to construct asset allocations and to project potential ranges of returns and market values over various time periods and using various cash flows. The modeling uses our forward-looking capital market assumptions of risk, return, and correlations for the different asset mixes. (see Methods of Analysis, Investment Strategies and Risk of Loss, Asset Allocation - Strategic Allocation Modeling Service for further information) Your Designated Advisor will collect certain information from you through a questionnaire, such as your portfolio’s investment objectives, risk tolerance, and projected cash flows in order to provide this service. However, you are responsible for providing all necessary information, particularly any limitations imposed by law or otherwise. We rely upon information provided by you to create the report as well as to provide the other Program services described in this Brochure. You should provide prompt written notice to your Designated Advisor of any change in your portfolio’s investment goals, risk tolerance, guidelines, restrictions, or similar information, which could materially change the information previously provided by you and used by us to create the report or provide other Program services described in this Brochure. It is your responsibility to select the final strategic asset allocation and to determine whether to implement any asset allocation strategy. After you select a strategic asset allocation, it is important that you periodically review your portfolio’s actual asset allocation to verify that it remains in line with your investment guidelines. (see Important Client Responsibilities for further information) Institutional Investment Consulting Brochure | 6  Merrill Lynch Institutional Investment Consulting Brochure Asset Liability Modeling Service If you are or are acting on behalf of a single-employer sponsored defined benefit plan with an investment portfolio under the Program of at least $50 million, we will provide the Asset Liability Modeling Service to you upon your request. Merrill will assist you in identifying an appropriate strategic asset allocation for your portfolio’s specific investment goals and objectives in meeting future defined benefit plan payment obligations. The recommendation of a strategic asset allocation will be provided by your Designated Advisor to you in a report. Please note that alternative asset allocations based on different assumptions, such as different risk tolerances, may be presented for comparison purposes in your report. However, these alternative asset allocations are not intended to be our recommendation. Under this service, we provide a report with a comprehensive stochastic modeling of plan assets and liabilities using Monte Carlo simulations to forecast pension metrics, if applicable: annual contributions (according to the plan sponsor’s funding policy), profit and loss expense, funded status on an ERISA basis, and balance sheet funded status – for various efficient strategic asset allocations and plan constraints. The modeling uses our forward-looking capital market assumptions of risk, return, and correlations for the different asset mixes and liability calculations during the forecast period. The report also includes a liability driven investment glide path, if applicable, with clearly defined trigger points that correspond with dynamic asset allocation changes which seek to limit swings in the plan’s funded status, changes in contribution requirements, and balance sheet volatility, where applicable. Your Designated Advisor will collect certain information from you, such as your portfolio’s investment objectives, risk tolerance, and projected cash flows, through a questionnaire in order to provide this service. Your Designated Advisor will also request that you provide certain actuarial reports in order to provide the service. However, it is your responsibility to provide all necessary information and actuarial reports, particularly any limitations imposed by law or otherwise. We rely upon information provided by you to create the report as well as to provide the other Program services described in this Brochure. You should provide prompt written notice to Merrill of any change in your portfolio’s investment goals, risk tolerance, guidelines, restrictions or similar information, which could materially change the information previously provided by you and used by us to create the report or provide other Program services described in this Brochure. It is your responsibility to select the final strategic asset allocation and to determine whether to implement any asset allocation strategy. After you select a strategic asset allocation, it is important that you periodically review your portfolio’s actual asset allocation to verify that it remains in line with your investment guidelines. (see Important Client Responsibilities for further information) Ongoing Asset Allocation Advice We will also periodically report to you, in writing, the actual asset allocation of your portfolio relative to the strategic asset allocation you selected for your portfolio. Your portfolio’s actual asset allocation may deviate from the strategic asset allocation you selected for many reasons, such as market movements, additions and withdrawals of assets from your portfolio, changes in investment managers and strategies, and the purchase and sale of certain securities within those investment strategies. Your Designated Advisor will review your portfolio’s actual asset allocation with you on a periodic basis and may make a recommendation to realign your actual asset allocation with the strategic asset allocation you selected. As noted above, you should notify Merrill of any change in your portfolio’s investment goals, risk tolerance, guidelines, restrictions or similar information as such change may change our strategic asset allocation recommendation to you. Should you disregard our recommendations, we may, at our discretion and with notice to you, terminate you as a Program client. (see Important Client Responsibilities for further information) Institutional Investment Consulting Brochure | 7  Merrill Lynch Institutional Investment Consulting Brochure INVESTMENT POLICY STATEMENT (“IPS”) SERVICE Merrill will assist you in creating a written IPS which will describe the investment goals and objectives of your portfolio, and certain policies governing the investment of assets. As with the Strategic Allocation Modeling Service and the Asset Liability Modeling Service, your Designated Advisor will use the information collected from you through a questionnaire to assist you in creating an IPS for your portfolio. Your Designated Advisor will also discuss with you minimum and maximum ranges for each asset class which will be used for realigning your portfolio to your selected strategic asset allocation based on investment goals and objectives. Your Designated Advisor will provide a draft IPS for your investment portfolio to you for review that will include your selected strategic asset allocation, as well as a recommendation for the minimum and maximum ranges for realigning your portfolio to your selected strategic asset allocation. If you have an existing IPS and do not choose to create a new IPS through the Program, your Designated Advisor will review your existing IPS and provide guidance including minimum and maximum ranges for the selected strategic asset allocation. You will also receive written confirmation of your investment guidelines including but not limited to your risk tolerance, time horizon and selected strategic asset allocation and minimum and maximum ranges. The information set forth in the initial and each subsequent written confirmation of your investment guidelines is how we reflect our understanding of your investment guidelines for the Program. You should review each written confirmation of investment guidelines we send to you carefully to ensure that the information reflected therein is accurate and you should contact your Designated Advisor if you believe any of the information is, or becomes, inaccurate. Merrill will not have discretion or any authority over implementation of your strategic asset allocation or IPS, under this Program. (See Other Investment Advisory Programs and Participation or Interest in Client Transactions) The acceptance and adoption of the IPS created for you through this Program, as well as ensuring your portfolio’s adherence to your IPS, is your responsibility. You are also responsible for ensuring that investment managers and strategies that you select can accommodate any investment restrictions reflected in your IPS and are properly captured through any Merrill investment advisory program or any other program you select for implementation. If the information you provided to Merrill changes, it is your responsibility to inform your Designated Advisor of those changes so we may work with you to update the IPS created for you through the Program or the written confirmation of investment guidelines. Notification typically can occur during the portfolio reviews with your Designated Advisor. However, if you consider the changes to be significant, it is your responsibility to notify your Designated Advisor prior to the portfolio review. We strongly encourage that you utilize your other professional advisers, such as attorneys and/or accountants prior to your acceptance of the IPS. (see Important Client Responsibilities for further information) MANAGER SEARCHES AND RECOMMENDATIONS Merrill and your Designated Advisor will assist you in your evaluation, review, and selection of investment managers and strategies for your portfolio, specifically IIC Eligible Strategies as described below. Your Designated Advisor will not provide investment manager and strategy recommendations for certain asset categories which are designated as Excluded Assets. Excluded Assets are private equity funds, hedge funds, limited partnerships, or other illiquid assets that may be held by you, as a part of the investment portfolio. (See Limitation of Services) IIC Eligible Strategies will include those strategies that meet Merrill’s due diligence standards. As a general matter, your Designated Advisor selects IIC Eligible Strategies based on a variety of factors, including investment styles available in the marketplace, platform capacity, client demand, and the outcome of due diligence reviews. The initial and periodic reviews of IIC Eligible Strategies are performed through an Institutional Investment Consulting Brochure | 8  Merrill Lynch Institutional Investment Consulting Brochure investment review conducted by or under the auspices of personnel of our Chief Investment Office (the “CIO”) (see Methods of Analysis, Investment Strategies and Risk of Loss for further information). The CIO is a business group that provides investment solutions, portfolio construction advice and wealth management guidance to our clients. It is a separate division from the business group that administers the Program. Your Designated Advisor and Merrill will use either your IPS created through the Program or the written confirmation of your investment guidelines that was sent to you, as well as information gathered from you through a questionnaire to recommend a list of IIC Eligible Strategies by asset class, except for Excluded Assets (See Limitation of Services). This list will be provided in the Manager Identification Report (“MID”). Upon specific written request of a client, and for comparison purposes only, an investment manager or strategy that is not an IIC Eligible Strategy may be included in the MID. Merrill expresses no opinion about the investment manager or strategy and the inclusion of the investment manager or strategy in the MID is not an endorsement or recommendation of the investment manager or strategy. Merrill will not assume any liability for any loss, claim, damage or expense attributable to your selection of an investment manager or strategy not included in the IIC Eligible Strategy universe. It is your responsibility to negotiate directly with independent third-party investment managers (not retained through any Merrill investment advisory program) the terms of any investment manager agreement and applicable fees. You may select an investment manager or strategy (or continue the use of an investment manager or strategy) without receiving a recommendation from Merrill. Merrill and its Affiliates offer other managed products or wrap programs. Recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including advice related to the recommendation of certain investment managers and strategies. This is due to, among other things, the differing nature of the other investment advisory services and differing processes and criteria upon which determinations are made. (see Related Persons) Your Institutional Performance Report, as described below, will highlight any investment managers or strategies that are not IIC Eligible Strategies. Replacement recommendations of IIC Eligible Strategies will be provided by your Designated Advisor for any investment managers and strategies in a portfolio that are not IIC Eligible Strategies. (See Advisory Business - Investment Performance Reporting and see Methods of Analysis, Investment Strategies and Risk of Loss - Status Change of IIC Eligible Strategies). You may make investment-related decisions contrary to our recommendations. However, if you disregard our advice, we may, at our discretion and with notice to you, terminate you as a Program client. (see Important Client Responsibilities for further information) INVESTMENT PERFORMANCE REPORTING Merrill will provide a periodic portfolio-level report called the Institutional Performance Report (“IPR”) to assist you in reviewing your actual asset allocation versus your selected strategic asset allocation, and the performance of your investment portfolio. The investment returns in your portfolio will be compared to the returns of the benchmarks recommended by us, for IIC Eligible Strategies. There are circumstances for certain IIC Eligible Strategies where you and the investment manager determine a custom benchmark for your portfolio. For these investment strategies that require a custom benchmark, Merrill will use the benchmark provided by the investment manager but will not validate the appropriateness of the benchmark. For strategies that are not IIC Eligible Strategies, account returns are compared with the returns of appropriate market indices, as specified by you. We will rely upon the data supplied by your custodian or third-party investment manager in preparing the IPR. Merrill will not be held responsible for the accuracy of the data provided by your custodian, if other than Institutional Investment Consulting Brochure | 9  Merrill Lynch Institutional Investment Consulting Brochure Merrill, or third-party investment manager. We also use outside information sources in preparing the IPR, including computer and data analysis firms. This information is obtained from sources believed to be reliable. When making performance comparisons, you should note that: • Past performance is not indicative of future results • Differences in transaction costs among accounts will affect account comparisons; and • The benchmarks shown in the IPR do not include transaction costs. If available, an actual investment in these benchmarks, or in the securities comprising the benchmarks, would require an investor to incur transaction costs. Performance would be reduced by such costs and their compounded effect. Performance information from third-party sources or performance reports provided by Merrill for accounts enrolled in other Merrill investment advisory programs may differ from that shown in the IPR. These differences may be due to different methods of analysis, different pricing sources, treatment of accrued income or different accounting procedures. For example, infrequently traded fixed-income securities may be priced according to yields calculated on a matrix system, which may vary among pricing sources. As another example, if sufficient data is available and the IPRs are prepared on a trade date basis, their performance information may differ from reports prepared on a settlement date or other basis. You should use the report to evaluate your investments and progress towards your investment goals. Your Designated Advisor will be available to assist you in understanding the format and content of the report, which includes graphic and tabular presentations of performance, and will assist you in reviewing and evaluating the reports. The IPR will not include any performance information for assets held in a Merrill brokerage account. The reports provided to you by Merrill on a periodic basis in the normal course of the delivery of services will be available via web access. You are responsible for reviewing and accessing the provided information through web delivery means, including the establishment of user ID’s and passwords. (see Important Client Responsibilities for further information) 4. Limitation of Services Universe of Investment Managers and Strategies – Investment managers or strategies recommended for your portfolio are limited to the IIC Eligible Strategies. Our recommendations therefore will not include every investment option available in the industry, including investment strategies offered through other Merrill investment advisory programs. Under the Program, BofA Corp and Merrill and its Affiliates do not and will not act in a fiduciary capacity under the Adviser’s Act, ERISA, or otherwise with respect to your decision to purchase, sell or hold any BofA Corp or Merrill affiliated products or services. Without limiting the generality of the immediately foregoing, Merrill may provide periodic investment performance reporting for any such affiliated investments or service providers, which you agree is not a fiduciary act of Merrill. Excluded Assets (“Excluded Assets”) – Merrill will not assist the client in the evaluation, review and selection of investment managers and strategies under the Program with respect to Excluded Assets. Excluded Assets are private equity funds, hedge funds, limited partnerships, or other illiquid assets held by the client as a part of the investment portfolio under the Program. Institutional Investment Consulting Brochure | 10  Merrill Lynch Institutional Investment Consulting Brochure BANA Discretionary Investment Management Services – BANA furnishes investment management services to personal trusts, estates, private foundations, philanthropic institutions, and other non-profit organizations. The Investment management services are provided on a fully discretionary basis and BANA acts as a co- trustee or co-fiduciary. Clients receiving discretionary investment management for a portfolio through BANA are not eligible for participation in the Program for the same portfolio. Other Investment Advisory Programs and Brokerage Accounts - Merrill offers a wide variety of advisory services. (See Advisory Business – Other Investment Advisory Programs) If your investment portfolio is subject to ERISA, your plan assets, including your investment portfolio under the Client Agreement, must be held at a custodian other than Merrill and may not be held in a brokerage account or enrolled in any investment advisory program offered by Merrill or its Affiliates. If your investment portfolio is not subject to ERISA, we may terminate your participation in the Program if you hold any investment portfolio assets under the Program in, or implement Program recommendations through, a brokerage account at Merrill or its Affiliates. 5. Termination The Client Agreement may be terminated at any time by you or Merrill by giving notice as described in the Client Agreement. IIC services will continue until the effective date of termination of the Client Agreement. 6. Qualifications of Designated Advisors Designated Advisors are registered as broker-dealer and investment adviser representatives. To become designated to provide Program services, Advisors are required to demonstrate specialized experience and meet certain qualification requirements. These requirements include the Certified Investment Management Analyst® (CIMA) certification through the Investment Management Consultants Association® or the Chartered Financial Analyst® credential through the CFA Institute. In addition, Advisors must complete training administered by Merrill. Those Advisors who meet Merrill’s criteria are designated to provide Program services. 7. Other Investment Advisory Programs We offer other investment advisory programs, including, but not limited to, the following: Merrill Lynch Investment Advisory Program, Merrill Lynch Fiduciary Advisory Services, Merrill Lynch Advice Access, Merrill Guided Investing, Merrill Guided Investing with Advisor program, Merrill Edge Advisory Account program, Merrill Personal Retirement Strategy, and Merrill Lynch Strategic Portfolio Advisor® Service. We also offer general information not directed to and not tailored to the specific needs of any individual or individual clients in the form of publications or research. More information about these programs and services is contained in the applicable Merrill brochure (or Merrill Form ADV, Part 2A) and is available upon request or through the SEC’s website at https://www.adviserinfo.sec.gov/. If your investment portfolio is not subject to ERISA, you may elect to engage an investment manager or strategy recommended by us through another Merrill investment advisory program. If you enroll in another investment advisory program, you will sign an investment advisory agreement for the services provided through that program and your final Program Fee will be pro-rated. You will no longer be charged a fee under this Program following enrollment in another investment advisory program. You will be charged a separate fee through another Merrill investment advisory program and the profiling process, program guidelines, fee calculation and billing methodology will differ from that of this Program. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance Institutional Investment Consulting Brochure | 11  Merrill Lynch Institutional Investment Consulting Brochure provided in connection with this Program, including advice related to the recommendation of certain investment managers and strategies. For more information about those programs, please review the applicable brochure as described above. You may make investment-related decisions contrary to our recommendations. However, if you disregard our advice, we may, at our discretion and with notice to you, terminate you as a Program client. (see Important Client Responsibilities for further information) Also, if you elect to engage an investment manager or strategy recommended by us through another Merrill investment advisory program and hold assets in a brokerage account at Merrill, you must agree to terms and conditions of the applicable brokerage account agreement. The brokerage account agreement will include terms and conditions for an automatic cash sweep program. An automatic cash sweep program is a program provided as part of your brokerage account agreement whereby cash balances in your brokerage account are automatically swept into a cash sweep option available for your account type that you select (“Cash Sweep Program”). Under this Program, Merrill will not recommend a cash sweep option under the Cash Sweep Program for your brokerage account. Please refer to your account agreement and related disclosures for additional information regarding the automatic sweep options for your type of account. You can obtain a paper copy of these disclosures from your Advisor. C. ASSETS UNDER MANAGEMENT As of December 31, 2024, Merrill had assets under management of $1,511.09 billion, of which $388.43 billion was managed on a discretionary basis and $1,122.66 billion was managed on a non-discretionary basis. Assets related to this Program are not included in this data. FEES AND COMPENSATION A. PROGRAM FEES For services provided in the Program, clients will pay a fee (“Program Fee”). The Program Fee will equal an annual fixed dollar amount or an annual asset-based fee rate applied to certain portfolio assets. The Program Fee is subject to a Program minimum and maximum annual fee amount. The Program minimum annual fee amount is $1,500. The Program maximum annual fee amount is an amount resulting from an annual asset- based fee rate of 0.45% of your portfolio assets under the Program, which includes Excluded Assets but, for clients with an investment portfolio not subject to ERISA, excludes any portfolio assets under the Program that are held in other Merrill advisory programs or Merrill brokerage accounts. The Program Fee may be negotiated with your Designated Advisor depending on a number of factors. The extent to which we negotiate the Program Fee is solely within our discretion. Unless otherwise agreed to by us, all fees are payable quarterly, in arrears. As noted above, the Program fee is negotiable subject to the maximum rate that can be charged. Merrill compensates your Designated Advisor on an ongoing basis from, and based on, the Program fee that is agreed to for your Plan. When proposing a Program fee to you, your Designated Advisor typically will consider a number of factors, including the type and size of your Plan, the breadth of your relationship with Merrill, the range of services your Designated Advisor anticipates providing, competitive considerations and the Designated Advisor’s own compensation considerations. Your Designated Advisor has a financial interest in the level of the Program fee. Merrill has business and compensation policies that result in Designated Advisors receiving lower compensation if the agreed-upon Program fee is lower than certain established levels. Therefore, Designated Advisors also have a financial incentive not to reduce fees below those levels. You may accept or reject any proposed rate by your Designated Advisor as part of the negotiation Institutional Investment Consulting Brochure | 12  Merrill Lynch Institutional Investment Consulting Brochure process. For more information on Designated Advisor compensation and conflicts of interest, see section “Compensation, Conflicts of Interests and Material Relationships - Compensation and Benefits to Merrill and Designated Advisors”. If a client has chosen to enter into another Merrill investment advisory agreement, the fees for the services provided under that agreement will be separate and distinct from those for the Program. For a more detailed discussion of the methodology used to calculate the fees charged for any other Merrill investment advisory program, please see the applicable brochure. B. CALCULATION OF PROGRAM FEES If Merrill cannot commence delivery of IIC services, your account may be terminated, in which case a refund for IIC fees that may have been paid will be processed upon termination. The program fee will not be adjusted for your use of or failure to use services. Unless otherwise agreed to by us, the following describes the calculation of the Program Fee. Asset-Based Fee Rate Asset-based fees are calculated and payable quarterly, in arrears, based upon the market value of the portfolio assets on the last business day of each calendar quarter as displayed in the IPR, including any Excluded Assets but, for clients with an investment portfolio not subject to ERISA, excluding any portfolio assets held in another Merrill investment advisory program or a Merrill brokerage account. For Excluded Assets, the most recent available market values supplied by your custodian or third-party investment manager will be displayed in the IPR. The fee rate applied will be one quarter of the annual asset-based fee rate. Fixed Dollar Fee Fixed dollar payments equal to one quarter of the agreed upon annual fee are due quarterly, in arrears. 1. Initial Billing of Program Fees For all clients, for the first quarter in which the client is enrolled in the Program, the fees charged will be calculated on a pro-rata basis, based on the number of calendar days enrolled during the quarter and according to the Client Agreement. For asset-based fee arrangements, the market value of the last business day of the calendar quarter displayed in the first IPR will be used to calculate the fee, including any Excluded Assets but, for clients with an investment portfolio not subject to ERISA, excluding any portfolio assets held in other Merrill investment advisory programs or Merrill brokerage accounts. 2. Billing Upon Termination of Service For all clients, in the event of termination, the Program Fees payable hereunder shall be prorated based upon the effective date of termination. For asset-based fee arrangements, the market value as of the last business day of the calendar quarter displayed in the final IPR will be used to calculate the final fee, including any Excluded Assets but, for clients with an investment portfolio not subject to ERISA, excluding portfolio assets held in other Merrill investment advisory programs or Merrill brokerage accounts. For additional information, see Advisory Business-Institutional Investment Consulting-Termination section. Institutional Investment Consulting Brochure | 13  Merrill Lynch Institutional Investment Consulting Brochure C. PAYMENT OF PROGRAM FEES Program Fees are calculated and invoiced quarterly in arrears according to the Client Agreement and based upon the market value of your assets including any Excluded Assets but, for clients with an investment portfolio not subject to ERISA, excluding any portfolio assets held in other Merrill investment advisory programs or Merrill brokerage accounts. The following methods are acceptable for paying your Program Fees: • Check • Wire Transfer Merrill will provide you with mailing and wire instructions on your quarterly invoice. D. OTHER FEES AND EXPENSES The Program Fee only covers the Program services described in this Brochure. For further information, see Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Conflicts of Interest and Information Walls below. E. COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS We and our employees, including your Designated Advisor, benefit from compensation paid to us, and may directly or indirectly receive a portion of the fees and other compensation paid by Program clients for other services. Clients may also use other products or services available from or through us and in such case pay additional fees. Designated Advisors offering these other services or programs will, in turn, receive compensation from Merrill. In particular, we and your Designated Advisor will receive additional compensation if you choose to use a Merrill investment advisory program to implement any Program recommendations and the fees for that investment advisory program are higher than the fees under the Program. This practice creates a conflict of interest that gives us and our Designated Advisors an incentive to recommend advisory services based on the compensation received. Fees and commissions are higher for some products or services, and the remuneration and profitability to us and our Designated Advisors resulting from transactions on behalf of our management of certain accounts will be greater than the remuneration and profitability resulting from other advisory accounts, products or services. We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways including the disclosure of the conflicts in this Brochure. Moreover, our Designated Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for you and in your best interest based upon your investment goals, risk tolerance and financial situation and needs and considering cost. In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest – both those arising between and among accounts as well as between accounts and our business. F. SOURCES OF REVENUE As a broker-dealer, Merrill offers a wide variety of products and services. Our principal sources of income, which include commissions and other compensation for the sale of investment products, are derived from our business as a broker-dealer. Less than 1% of our gross revenues are expected to be generated from the Program on an annual basis. G. CONDUCTING BUSINESS THROUGH MERRILL You should discuss the investment advisory services we make available with your Designated Advisor to Institutional Investment Consulting Brochure | 14  Merrill Lynch Institutional Investment Consulting Brochure determine which is most appropriate for you. Program fees may be higher or lower than the fees charged by other firms for comparable services, assuming such services are available. Your Designated Advisor can provide you with a Summary of Services document which outlines the differences between IIC and other Merrill investment advisory programs. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Neither we nor our Designated Advisors receive performance-based fees for the Program. The investment recommendations provided in connection with the Program do not raise the conflicts associated with the side-by-side management of accounts. TYPES OF CLIENTS This Program is available to charitable organizations, pension, welfare benefit and profit sharing plans, corporations, high net worth individuals, trusts, and estates. The Program is typically available for clients with $20 million or more in assets. The minimum asset threshold can be waived, at our sole discretion. The Program’s Asset Liability Modeling Service is available if you are or are acting on behalf of a single-employer sponsored defined benefit plan with an investment portfolio under the Program of at least $50 million. As part of the enrollment process, we elicit information about your financial circumstances, investment objectives, risk tolerance, time horizon and other information relating to your account. We leverage this information to provide program services to you as included in the “Detailed Description of Services” section. In managing your account, we rely on information you provide and it is your responsibility to notify promptly your Designated Advisor, as the case may be, of any updates to such information. In the Client Agreement, you represent to us that you have provided us and will provide us with information that is accurate and complete. Failure to do so could affect the suitability of the services being provided under the Program. We are not required to verify the accuracy of the information. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. ASSET ALLOCATION 1. Strategic Allocation Modeling Service Merrill will assist you in identifying an appropriate long-term asset allocation for your portfolio based upon your risk tolerance, investment goals and objectives, liquidity needs, tax status, time horizon, portfolio initial investment value, and investment constraints. These inputs are used in conjunction with our forward-looking capital market assumptions and a probabilistic modeling approach known as Monte Carlo simulation to recommend a strategic asset allocation to you. Monte Carlo simulation is a statistical modeling technique in which a set of future outcomes are forecasted based on the variability or randomness associated with historical occurrences. We use Monte Carlo simulation when producing a range of simulated asset allocations for comparison with your current strategic asset allocation. Each asset allocation (current and simulated) is accompanied by the range of expected returns, volatility estimates, potential portfolio values, and yield projections over various investment horizons. The recommended strategic asset allocation for your portfolio will be presented to you in a report by your Designated Advisor. a. Monte Carlo Simulation Monte Carlo simulations are the result of running a large number of random scenarios in an attempt to determine the most probable performance results of a given portfolio. These simulations may be based not only on past performance information, which is not indicative of future results, but they may also be based on Institutional Investment Consulting Brochure | 15  Merrill Lynch Institutional Investment Consulting Brochure Merrill long term capital market assumptions. Note that this does not imply that these results are actually the best and worst cases that one will actually experience. Monte Carlo simulations do not purport to represent the actual performance of any portfolio, but attempt to illustrate the probabilistic range of hypothetical performance results of a large number of different hypothetical portfolios. No actual portfolio has performed in the manner indicated in the Monte Carlo simulations, and the hypothetical scenarios used in the simulation may omit entire categories of relevant scenarios. There can be no assurance that any given portfolio will in fact perform in a manner materially consistent with the probabilities indicated by the simulation. No representation is or could be made that the probabilities indicated by these simulations are based on any fundamental economic or market characteristics, and in the absence of such characteristics, there is no reason that these probabilities will be representative of any actual portfolio. Hypothetical or simulated performance results have certain inherent limitations. Unlike an actual performance record, simulated results do not represent actual trading. Also, since the trades have not actually been executed, the results may have under-or over-compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated trading programs in general are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any recommendation or portfolio will or is likely to achieve profits or losses similar to those shown. b. Merrill’s Capital Market Assumptions Framework Merrill’s capital market assumptions framework generates expectations of asset class returns, risk, and correlations for the upcoming 25 years. This time horizon, strategic in nature, is meant to capture multiple business cycles and can potentially contain periods of economic expansion, contraction, market peaks, and market troughs, all with varying degrees of volatility. By looking beyond these short-term fluctuations in the market, we focus instead on the more stable, long-term financial relationships that provide a strong foundation from which we aim to construct efficient and well diversified portfolios. History has demonstrated that inter-asset class relationships are dynamic and traditional relationships that have held in the past, may not in the future. As a result, we take secular shifts into account in our modeling and incorporate new trends as they develop. Generating forecasts for returns, standard deviations, and correlations is the first step in developing the particular strategic asset allocation that helps meet each of our clients’ unique needs and situations. c. Expected-Return Methodology There are many different methodologies for developing expected-return forecasts. Models can range in sophistication from the more basic, which rely exclusively on historical data (often producing misleading results) to the more complex, which seek to merge historical analysis with forward-looking views. Further, care must be taken when selecting suitable methodologies, as models built in the same manner for disparate asset classes can lead to unrealistic return expectations. As such, a wide array of techniques has been employed to more precisely estimate the return potential for each asset class. Merrill asset class expected return forecasts are guided by economic theories and based on the principle that asset returns provide compensation for exposure to systematic risk factors. To develop capital market assumptions, Merrill uses a proprietary approach that reflects the dynamic interrelationships between asset class returns and a set of risk factors. Those risk factors have been found in academic research to represent systematic sources of risk and exhibit risk premium that are expected to persist in the future. More specifically, Merrill first generates forward looking forecasts for those selected key risk factors guided by financial theories, academic and practitioner research, and using data that gauge current market conditions. We then estimate relationships between the asset classes and the risk factors by applying regression analysis to historical data. Asset class expected returns are then developed based on asset class exposure to those systematic risk factors and our forecasts for those risk factors. Institutional Investment Consulting Brochure | 16  Merrill Lynch Institutional Investment Consulting Brochure d. Standard Deviation and Correlation Coefficient Methodology As in the case with Merrill’s expected return modeling, Merrill applies a factor-based approach to generate forward-looking volatility and correlation assumptions. We first generate forward looking scenarios for a set of risk factors guided by financial theories and empirical evidences. We then use historical data to estimate the empirical relationship between each asset class and relevant risk factors. For example, for U.S. equity asset classes, we use well-known risk factors such as market size and value. Next, we simulate asset class future return scenarios based on their relationship with relevant risk factors. Finally, we derive asset class expected volatilities and correlations coefficients from simulated future return scenarios. e. Forecasted Annualized Returns Forecasts within the report we provide to you for the current portfolio or alternate portfolio mixes studied do not take into account capital gains taxes incurred by re-allocating from your current asset allocation. Annual rebalancing of portfolios consistent with the asset allocation used in the analysis is assumed. Dividends and income are reinvested to the extent not used to fund annual spending. Neither the historical performance of the indexes nor the adjusted performance data guarantee future results. The returns of the market indexes and the strategic asset allocation alternatives included in the report we provide to you do not reflect actual account performance or the deduction of transaction costs or advisory fees. The deduction of such costs and fees would reduce performance. Certain assumptions are made in the analyses included in the report we provide to you. For example, the allocations shown for each alternative remain consistent over all periods of time. This practice would seldom be followed in actual investing; and performance returns of the alternatives assume reinvestment of income. Assumptions concerning inflation and tax rates in the report we provide to you are for illustrative purposes only and are not intended to predict or guarantee economic performance. f. Market Risks Diversification does not guarantee a profit or protect against loss in declining markets. Since the goals-based asset allocation contained in the report we provide to you involves continual investment in securities regardless of fluctuating price levels, you must consider your willingness to continue purchasing during periods of high or low price levels. You should also carefully consider the results of your modeling study and make an independent judgment that this material accurately reflects your situation, investment philosophy and risk tolerance. Investments in foreign securities involve special risks, including foreign currency risk and the possibility of substantial volatility due to adverse political, economic or other developments. These risks are magnified for investments made in emerging markets. Foreign currency exchange rates may adversely affect the value, price or income of any security or related investment mentioned in the report we provide to you. In addition, investors in securities such as American Depositary Receipts (“ADRs”), whose values are influenced by the currency of the underlying security, effectively assume currency risk. There are special risks associated with an investment in commodities, including market price fluctuations, regulatory changes, interest rate changes, credit risk, economic changes, and the impact of adverse political or financial factors. g. Risks in Alternative Investments Most alternative investment products are sold on a private placement basis and eligible clients must typically be Qualified Purchasers ($5 million net investments). No assurance can be given that any alternative investment’s investment objectives will be achieved. In addition to certain general risks, each product will be subject to its own specific risks, including strategy and market risk. You should bear in mind the following risks of alternative investments: • Alternative Investments are speculative and involve a high degree of risk. Institutional Investment Consulting Brochure | 17  Merrill Lynch Institutional Investment Consulting Brochure • Alternative investments may trade on a leveraged basis which increases the risk of loss. • Performance can be volatile. • An investor could lose all or a substantial amount of their investment. • The use of one or a small number of fund managers applying one set of allocation procedures could mean lack of diversification and, consequently, higher risk. • There is no secondary market for investor’s interest in alternative investments and none is expected to develop. • There may be restrictions on transferring interests in the alternative investments. • High fees and expenses, including performance fees payable to the manager, may offset trading profits. • Fund managers have broad authority to suspend redemptions, defer payment of redemption proceeds and establish illiquid side pockets to segregate illiquid investments. • A substantial portion of the trades executed by the underlying managers may take place on non-US exchanges. • Alternative investments may require tax reports on Schedule K-1 to be prepared. As a result, investors may be required to obtain extensions for filing federal, state, and local income tax returns each year. • In addition to the foregoing risks, each alternative investment fund is subject to its own strategy-specific or other risks. You must carefully review the offering memorandum for any particular fund and consider your ability to bear these risks before any decision to invest. • Past performance is not indicative of future results. • Hedge Funds and Private Equity may be included in the recommended strategic asset allocation but Merrill will not provide any investment manager or strategy recommendations with respect to such assets. h. Risks in Private Equity In addition to the foregoing, private equity fund investments are subject to the following risks: • Private equity investments involve significant risks, are typically illiquid on a long-term basis and may require a holding period of at least 8 to 12 years. Underlying private investments may be difficult to value. Investors may lose their entire investment. • Private equity managers typically take several years to invest a fund’s capital. Investors will not realize the benefits of their investment in the near term and there will likely be little or no near-term cash flow distributed by the fund during the commitment period. Interests may not be transferred, assigned or otherwise disposed of without the prior written consent of the manager. • Private equity funds may make a limited number of investments, and such investments generally will involve a high degree of risk, such as start-up ventures with little or no operating histories. In addition, funds may make minority equity investments where the fund may not be able to protect its investment or control or influence the business of such entities. The performance of a fund may be materially impacted by a single investment. • A private equity fund may obtain rights to participate in, or to influence, the management of certain portfolio companies, including the ability to designate directors. This or other measures could expose the assets of the fund to claims by a portfolio company, its security holders, creditors and others. Institutional Investment Consulting Brochure | 18  Merrill Lynch Institutional Investment Consulting Brochure • Private equity fund investors are subject to periodic capital calls. Failure to make required capital contributions when due will cause severe consequences to the investor, including possible forfeiture of all investments in the fund made to date. i. Past Performance is No Guarantee of Future Results Once you have reviewed the report we provide to you, it is your responsibility to decide if, and how, the suggestions made in conjunction with this report should be implemented. You should carefully consider all relevant factors in making these decisions and are encouraged to consult with any of your outside professional advisors. In particular, neither Merrill nor its Designated Advisors provide legal or tax advice. We recommend that you consult with your lawyer, accountant or other advisor about questions affecting your individual circumstances. It is important to review your financial situation regularly. If your financial goals or circumstances change, you should carefully consider how these changes might affect any course of action you have previously selected. Your Designated Advisor will collect certain information from you, such as your portfolio’s investment objectives, risk tolerance, and projected cash flows, through a questionnaire in order to provide this service. However, you are responsible to provide all necessary information, particularly any limitations imposed by law or otherwise. We rely upon information provided by you to provide the report as well as the other Program services described below. You should provide prompt written notice to Merrill of any change in your portfolio’s investment goals, risk tolerance, guidelines, restrictions or similar information, which could materially change the information previously provided by you and used by us to create the report or provide other Program services described below. It is your responsibility to select the final strategic asset allocation and to determine whether to implement any asset allocation strategy. After you select a strategic asset allocation, it is important that you periodically review your portfolio’s actual asset allocation to verify that it remains in line with your investment guidelines. 2. Asset Liability Modeling Service If you are or are acting on behalf of a single employer sponsored defined benefit plan with an investment portfolio under the Program of at least $50 million, we will provide the Asset Liability Modeling Service to you upon your request. Merrill will assist you in identifying an appropriate strategic asset allocation for your portfolio’s specific investment goals and objectives in meeting future defined benefit plan payment obligations. Under the service, we provide a report that includes a comprehensive stochastic modeling of plan assets and liabilities using Monte Carlo simulations to forecast the following pension metrics: • Annual contributions (according to the plan sponsor’s funding policy) • Profit and loss expense Funded status on an ERISA basis • • Balance sheet funded status The modeling uses our forward-looking capital market assumptions of risk, return, and correlations for the different asset mixes and for liability calculations during the forecast period. For further information on our capital market assumptions and Monte Carlo simulation, see above Methods of Analysis, Investment Strategies and Risk of Loss–Strategic Allocation Modeling Service. Please note that the capital market assumptions used with this Asset Liability Modeling Service generate expectations of asset class returns, risk, and correlations for the upcoming 15 years instead of 25 years which is used with the Strategic Allocation Modeling Service. The report also includes a liability driven investment glide path, if applicable, Institutional Investment Consulting Brochure | 19  Merrill Lynch Institutional Investment Consulting Brochure with clearly defined trigger points that correspond with dynamic asset allocation changes that seek to limit swings in the plan’s funded status, changes in contribution requirements, and impact on the balance sheet. Merrill will utilize its Affiliate, BANA, under a servicing arrangement between Merrill and BANA to assist Merrill in providing the Asset Liability Modeling Service. The servicing agreement details the roles and responsibilities of each party in connection with the report. Your Designated Advisor will collect certain information from you, such as your portfolio’s investment objectives, risk tolerance, and projected cash flows, through a questionnaire in order to provide this service. Your Designated Advisor will also request that you provide certain actuarial reports in order to provide the service. However, it is your responsibility to provide all necessary information and actuarial reports, particularly any limitations imposed by law or otherwise. We rely upon information provided by you to provide the report as well as the other Program services described in this Brochure. You should provide prompt written notice to Merrill of any change in your portfolio’s investment goals, risk tolerance, guidelines, restrictions or similar information, which could materially change the information previously provided by you and used by us to create the report or provide other Program services described below. Note the guidance we provide in the creation of your asset allocation for the Program is a recommendation and it is your responsibility to approve the final portfolio strategic asset allocation. If you choose to invest your assets in a manner that differs from our recommendations, you may assume additional risks that result from your decisions. We also encourage you to consult with your tax and legal professionals, since we do not provide tax or legal advice that may affect asset classes or allocations used in the modeling. However, we will apply guidelines you supply as directed. Again, compliance with restrictions or guidelines, if any, is your responsibility. INVESTMENT POLICY STATEMENT SERVICE B. The Program questionnaire is designed to profile various characteristics of you that will assist in the creation of the IPS. The characteristics that are taken into consideration include tax status, investment goals, risk tolerance, time horizon, liquidity needs, and investment constraints. Your Designated Advisor will also discuss with you minimum and maximum ranges for each asset class for realigning your portfolio to your selected strategic asset allocation based on investment goals and objectives. Your Designated Advisor will provide a draft IPS for your investment portfolio to you for review that will include your selected strategic asset allocation, as well as a recommendation for the minimum and maximum ranges for realigning your portfolio to your selected strategic asset allocation. During the editing phase, we strongly recommend that you utilize your other professional advisers, such as attorneys and accountants to check relevant documentation, particularly in the case of trusts and retirement plans. Please note that it is your responsibility to provide all necessary information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. If you have an existing IPS and do not choose to create a new IPS through the Program, your Designated Advisor will review your existing IPS and provide guidance including minimum and maximum ranges for the selected strategic asset allocation. You will also receive written confirmation of your investment guidelines including but not limited to your risk tolerance, time horizon and selected strategic asset allocation and minimum and maximum ranges. The information set forth in the initial and each subsequent written confirmation of your investment guidelines is how we reflect our understanding of your investment guidelines for the Program. You should carefully review each written confirmation of investment guidelines we send to you to ensure that the information reflected therein is accurate and you should contact your Designated Advisor if you believe any of the information is, or becomes, inaccurate. The acceptance and adoption of the IPS created for you through this Program, as well as ensuring your portfolio’s adherence to your IPS, is your responsibility. You are also responsible for ensuring that investment Institutional Investment Consulting Brochure 2 | 0  Merrill Lynch Institutional Investment Consulting Brochure managers and strategies that you select are able to accommodate any investment restrictions reflected in your IPS and the investment restrictions are properly captured by any program you select for implementation. C. MANAGER SEARCHES AND RECOMMENDATIONS 1. Manager Identification Report We assist you with the identification of investment managers and strategies from the IIC Eligible Strategies universe that are appropriate based on either your IPS created through the Program or the written confirmation of your investment guidelines that was sent to you, as well as your responses to a questionnaire. Clients, with the assistance of their Designated Advisor, complete the questionnaire, which details the need for the service as well as specific investment manager criteria and constraints to be considered during the identification process. This information is then compared against data about investment managers available to us from a variety of sources, including both nonproprietary databases and subscription services. Information about investment managers is obtained from sources believed to be reliable, but reliability cannot be guaranteed. While Merrill only recommends investment managers and strategies that are IIC Eligible Strategies, clients may request investment managers and strategies that are not IIC Eligible Strategies. The client must provide a written request to the Designated Advisor to include in the MID an investment manager or strategy that is not an IIC Eligible Strategy for comparison purposes only. Merrill expresses no opinion about an investment manager or strategy that is not an IIC Eligible Strategy and inclusion of the investment manager or strategy in the MID is not an endorsement or recommendation of the investment manager or strategy. Although we generally review an investment manager’s past performance, we do not perform an audit of this data to verify either its accuracy or that each investment manager has calculated past performance in a manner that is consistent with industry standards or uniform with other managers. Moreover, the methodology used by an investment manager to select and aggregate accounts for performance reporting purposes (i.e., the development of the investment manager’s composite), as well as the calculation of performance results reported by each investment manager for its composite and its underlying accounts, may not have been created or calculated on a uniform or consistent basis from manager to manager. Further, performance information provided by the manager or obtained from third-party sources may include data pertaining to types of accounts that are different from the type of account you are interested in having managed. You are encouraged to evaluate this performance data carefully and to consider all relevant factors in selecting or retaining one or more managers. Using this analysis, we will present you with a list of typically three to five investment managers or strategies per asset class that appear appropriate for you based upon your investment guidelines and your selected strategic asset allocation. We will review the list of candidates with you and provide guidance to assist you in choosing an investment manager or strategy that you believe is appropriate based upon your portfolio’s goal and objectives. As discussed above, you are responsible for the implementation of any investment manager or strategy recommended under the Program and determining how the strategy will be implemented. Not all investment structures are available for each recommended investment manager or strategy. Investment managers or strategies recommended for your portfolio are limited to the IIC Eligible Strategies. Our recommendations therefore will not include every investment option available in the industry, including those offered through other Merrill investment advisory programs. Institutional Investment Consulting Brochure | 21  Merrill Lynch Institutional Investment Consulting Brochure 2. IIC Eligible Strategies IIC Eligible Strategies are investment managers and strategies that have been identified by us and may be used by Merrill and the Designated Advisor to make recommendations for your portfolio. As a general matter, we decide whether to include particular investment manager or strategies in the Program (or to remove them from the Program) based on a variety of factors, including client needs, investment styles available in the marketplace, platform capacity, client demand and the outcome of certain reviews that are conducted by or under the auspices of Merrill, including through the CIO. From time to time, Merrill makes additional investment strategies available in the IIC Eligible Strategies. Final selection of all investment strategies for your portfolio will be made solely by you. You should discuss with your Designated Advisor which investment strategies are appropriate for your portfolio. a. Review Process The initial and periodic reviews of IIC Eligible Strategies are performed by our product teams through an internal business review. In addition, we have in place an investment review, referred to as the "CIO Review Process", conducted by or under the auspices of personnel of the CIO, which covers IIC Eligible Strategies that the product teams and/or the CIO are considering for inclusion in the available investment managers and strategies. The CIO Due Diligence process consists of proprietary processes conducted by the CIO and those processes and reviews provided by third-party reviewers that we have engaged for this purpose. Both the third-party reviewer services and CIO apply multi-factor processes, but they are not identical. We, through the CIO, have reviewed such third-party reviewers’ processes and believe they are reasonable and appropriate in light of the objectives of the Program. Once we identify a need for a particular investment management style, we employ a multi-factor process to review appropriate investment managers and strategies to meet this need. These factors may include but are not limited to: organizational structure and stability of an investment manager or strategy, adherence to investment style, evaluation of risk and volatility, investment professional and strategy resources, investment philosophy and process, portfolio construction, and performance. Based on these factors and using the information collected, the CIO Review Process involves quantitative and qualitative analytical methods, some of which may be subjective. Generally, no single factor will be determinative. There is no assurance that the CIO Review Process or our internal business reviews will identify the best performing investment managers and strategies. Our reviews may involve in-person visits, telephone conference calls, reviews of performance, and updates of certain investment manager or strategy documents and information. We may also conduct periodic analysis of composite performance to determine whether that performance generally appears to be consistent with the investment style or objective of the manager or strategy. Merrill does not perform audits of the investment strategies to verify past performance information. For each investment manager or strategy, we will periodically evaluate factors related to the investment manager or strategy, that we deem appropriate. We will evaluate on an as needed basis, any material change related to such investment manager or strategy and the impact of any such changes including on the investment advisers managing the assets In addition, we may initiate reviews based on various factors determined by us and the CIO to be appropriate. These reviews occur as part of the CIO Review Process or otherwise. Institutional Investment Consulting Brochure | 2 2  Merrill Lynch Institutional Investment Consulting Brochure b. Information Available to Designated Advisors Regarding IIC Eligible Strategies We make information available to Designated Advisors through regular or ad hoc internal publications, including those from the CIO, that reflect our internal opinions and views with respect to investment managers and strategies. All such information is available to your Designated Advisor in considering whether a particular strategy is appropriate for your portfolio. You should discuss with your Designated Advisor any questions you have about our views with respect to a particular strategy. c. Status Change of IIC Eligible Strategies If your portfolio contains investment managers and strategies that no longer meet Merrill’s due diligence standards for inclusion as an IIC Eligible Strategy, your investment performance report will highlight those ineligible strategies. Your Designated Advisor will provide recommendations of IIC Eligible Strategies to replace those investment managers and strategies that no longer meet Merrill’s due diligence standards. IIC Eligible Strategies may change at any time. Merrill will generally not provide specific information regarding the basis for a change. Note that not all investment managers and strategies recommended for other Merrill clients outside of this Program will be included as IIC Eligible Strategies, and vice versa. Merrill’s review of your portfolio’s investment managers and strategies is not a substitute for your continued review of your portfolio and the performance of your investment strategies. d. Portfolio Evaluation, Review, and Reporting We provide periodic portfolio evaluation review and reporting of your investments and your selected strategic asset allocation as agreed upon in your Client Agreement. We will assist you in evaluating your portfolio including the review of your investment performance on an absolute and relative basis. We can also assist you in determining whether and how adjustments should be made. We will include your investment managers and strategies that are held in your portfolio in your IPR, including investment managers or strategies that are not in the IIC Eligible Strategy Universe upon written request. Our inclusion of these non-IIC Eligible Strategies is solely for the purpose of performance measurement and strategic asset allocation monitoring and does not constitute an endorsement or recommendation that you should continue to hold those investments or retain those managers. The principal source of information used for our performance reports is from Merrill unless your portfolio has a custodian other than Merrill. We also use outside information sources including computer and data analysis firms. This information is obtained from sources believed to be reliable, but reliability cannot be guaranteed. Merrill is not responsible for the accuracy of this data. The accuracy of the IPR and the information contained is limited by the accuracy and completeness of the information and data available to Merrill. Merrill relies solely on the information provided to us by your investment managers and custodians, and computational or other errors or limitations in that information will necessarily be reflected in the IPR. One particular area where information is limited is the calculation of net performance. Clients in the IIC Program may arrange to pay investment advisory fees to their investment managers and the Program Fee to Merrill directly rather than authorize deduction from the account managed by the investment manager. Similarly, clients may authorize the deduction of the Program Fee and investment advisory fees for an account or multiple accounts from a different or single account. Depending on whether your fees are paid directly out of your managed account, or fees for multiple investment managers are deducted from a single account, the performance information reported to Merrill by your investment manager(s) may or may not reflect accurately the deduction of those fees. In the event that Institutional Investment Consulting Brochure 2| 3  Merrill Lynch Institutional Investment Consulting Brochure clients have arrangements that provide such alternative payment mechanisms, the actual net performance of your accounts will differ from that shown in the IPR. In connection with the information in your performance review, such as the comparisons of the returns of your investment managers and strategies with those of the benchmarks recommended by us, it should be noted that: • If provided in the custodial statement, changes in portfolio valuations due to capital gains or losses, dividends, interest or other income are included in the calculation of returns; and • Typically, transaction costs, such as commissions, are included in the purchase cost or deducted from the proceeds of a sale of a security. If you also maintain an account(s) in one of our investment advisory programs, you will receive performance reporting for each advisory account through that program, unless otherwise agreed upon. D. PRICING OF SECURITIES Pricing of securities is provided for your information. Your Merrill account statement or the account statements provided by other custodians reflect your official record of holdings, balances, and security values. Unless otherwise indicated, values reflect current information as of the date shown at the top of each report. The valuation of alternative investments is prepared based upon information from third party sources. The information has not been verified and cannot be guaranteed. This data may include estimates and is subject to revision. If an account has been managed by more than one manager, the manager name in the IPR reflects the current manager. However, the return and standard deviation information may be calculated using the entire history of each account. Note that the IPR may also include information regarding account(s) that are not managed by a manager (i.e., where you make the investment decisions). Performance information set forth in an IPR is dependent upon valuations received from Merrill and custodians other than Merrill. For custodians other than Merrill, we rely upon their valuations and do not verify valuation data independently. E. RISKS ASSOCIATED WITH CERTAIN INVESTMENTS You should understand that investing in securities involves risk of loss that you should be prepared to bear. You should understand that all investments involve risk (the degree of risk varies significantly), that investment performance can never be predicted or guaranteed and that the values of the portfolio’s assets will fluctuate due to market conditions, and other factors. Investments made and the actions taken respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID- 19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Merrill makes no representations or warranties with respect to the present or future level of risk or volatility in your portfolios, strategies, mutual funds, or investments’ future performance or activities. There is no assurance that the performance results of any benchmark or index used in connection with the Program, including those shown on the performance report or other Merrill reports, can be attained. Nor is there any guarantee that our investment manager identification process will identify the best performing investment managers and strategies in their respective competitive universe. You are assuming the risks involved in | Institutional Investment Consulting Brochure 4 2  Merrill Lynch Institutional Investment Consulting Brochure selecting investment strategies for the portfolio and the portfolio could lose all or a portion of the amount held in those investment strategies. Typically, Merrill recommends that a client seek a diversified portfolio in an effort to meet the portfolio’s investment objectives and have investments diversified across multiple asset classes in order to reduce investment risk associated with concentrated investments. For specific risks associated with the investments in your portfolio, you should consult with the relevant investment manager you select to manage your portfolio. F. INFORMATION AND CYBERSECURITY RISKS With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly, BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, the funds and fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents suffered by BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. We, and our third-party providers, have experienced cybersecurity incidents and the adverse impacts from such incidents. We expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we, or our service providers,, will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and Institutional Investment Consulting Brochure 2| 5  Merrill Lynch Institutional Investment Consulting Brochure rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory, operational and ESG reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. G. ESG-THEMED STRATEGIES OR FUNDS There are an increasing number of products and services that purport to offer environmental, social, and governance (ESG) or sustainable investing strategies. The variability and imprecision of industry ESG definitions and terms can create confusion. Investment managers and product sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. Merrill generally does not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the manager) other than as part of the CIO Review Process. You should review the offering materials and Profiles to gain an understanding of how these managers and product sponsors describe their investment approach. ESG Strategies, including ESG-related Funds, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by a Style Manager or fund manager, will align with your ESG-related beliefs or values. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the Style Manager or Fund manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities and, as a result, investment performance could suffer. On the other hand, category restrictions that aim to screen companies that engage in certain Institutional Investment Consulting Brochure 2 6|  Merrill Lynch Institutional Investment Consulting Brochure behaviors or earn revenue derived from a restricted category may not exclude all companies with any tie or revenue derived from such restricted category and require assumptions, opinions and the subjective judgment of the data provider that might not reflect your ESG-related views or values. If you hold an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event. Category restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that client restrictions would not have any practical effect on an account comprised primarily of Fund investments. When evaluating investments for an ESG Strategy, a Style Manager or fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment of an investment’s ESG or sustainable attributes. Merrill does not guarantee or validate any third- party data, ratings, screenings or processes. Moreover, the screenings and processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in a Portfolio holding investments in companies that derive revenue from the restricted category. IMPORTANT CLIENT RESPONSIBILITIES For the various services described herein, you are asked to complete a questionnaire or other form that elicits various types of information. You are responsible for providing accurate and complete information, and failure to do so could significantly affect the services that we provide. In addition, external dependencies, including custodial obligations, are critical to the services provided in this agreement and may also impact the level of service provided. You are encouraged to work closely with your Designated Advisor to understand onboarding requirements and the dependencies that may impact the timing of service delivery, which may differ across the services provided under the Program (see Detailed description of services for further information). Further, you are obligated to notify your Designated Advisor promptly of any material change in financial circumstances or investment objectives or investment restrictions (if any) that may affect the strategic asset allocation, investment guidelines, or other Program services provided by Merrill. Your Designated Advisor will make recommendations for your IPS based upon the financial, and other information provided by you. You are responsible for reviewing the IPS or written confirmation of investment guidelines to ensure it is reflective of your goals and objectives, and the information you provided is captured correctly. The acceptance and adoption of an IPS for this Program, as well as ensuring your portfolio’s adherence to your IPS, is your responsibility. You are also responsible for ensuring that investment managers and strategies that you select can accommodate any investment restrictions reflected in your IPS and are properly captured for any other program you select for implementation. With respect to selecting a strategic asset allocation, you are responsible for providing us with the information necessary to create and update your strategic asset allocation. In addition, you maintain sole responsibility for selecting a strategic asset allocation that best aligns with your investment goals and objectives, as well as the minimum and maximum ranges for realigning your portfolio. Your Designated Advisor will provide recommendations to assist you in the initial selection of the strategic asset allocation and minimum and maximum ranges, as well as any subsequent updates to your strategic asset allocation, IPS created through the Program, or investment guidelines. On a periodic basis, we will monitor your strategic asset allocation and if appropriate make recommendations regarding updates. Merrill conducts due diligence on certain investment managers and strategies as part of the investment manager identification service offered within this Program. Your Designated Advisor will provide you with a MID to assist you in the selection of eligible investment managers and strategies. It is your responsibility to Institutional Investment Consulting Brochure | 72  Merrill Lynch Institutional Investment Consulting Brochure review the material presented to you prior to taking action. The selection of any investment manager and strategy is the responsibility of the client. By participating in the Program, you represent and confirm that you have sole and final responsibility for selecting asset allocations, accepting and adopting an IPS or reviewing the written confirmation of your investment guidelines if electing to not have an IPS created through the Program, and selecting investment managers and strategies for inclusion in your portfolio. You will use best efforts to notify Merrill if any of the foregoing representations become inaccurate or if the identity of any of the portfolio’s named fiduciaries or authorized persons with respect to this relationship changes. Such notification must be made in writing to your Designated Advisor. You should understand that our services described above should not substitute for or diminish the careful deliberation and determination made by those fiduciaries having responsibility for management and administration of the portfolio, following appropriate consultation with your other professional advisers and the review of relevant documentation. DISCIPLINARY INFORMATION The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill Lynch’s Form ADV at: https://www.adviserinfo.sec.gov/. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures Institutional Investment Consulting Brochure | 28  Merrill Lynch Institutional Investment Consulting Brochure relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’s remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Merrill, an indirect wholly-owned subsidiary of BofA Corp, is a leading global investment banking firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through our own arrangements and through its affiliate, BofAS, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As registered investment advisers, Merrill completes Form ADVs which they publicly file with the SEC (available at https://www.adviserinfo.sec.gov/). For purposes of Form ADV Part 2, certain Merrill management persons are registered as registered representatives or associated persons of Merrill. In the future, certain Merrill personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of Merrill to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on Institutional Investment Consulting Brochure 2 | 9  Merrill Lynch Institutional Investment Consulting Brochure a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning; asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales and (10) providing research including: global equity strategy and economics, global fixed income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp., is subject to the reporting requirements of the Exchange Act and additional information about BofA Corp. can be found in publicly available filings with the SEC. We, through our Advisors, may suggest or recommend that clients, including Program clients, use Merrill’s securities account, execution, and custody or other services, or such services of an Affiliate. Similarly, Advisors, who also handle clients’ securities accounts, may suggest or recommend that clients purchase Merrill’s products or products of an Affiliate. Where you use or purchase Merrill’s or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Advisors may, as permitted by applicable law, receive compensation (the amount of which may vary) in connection with these products and services. Merrill and its Affiliates may have business relationships with the officers, directors, or employees of a variety of clients, including corporations, pension and retirement plans, and other entities receiving IIC. These business arrangements may create a conflict of interest to the extent that these individuals have any role or influence in the hiring or retention of Merrill and its Advisors or with respect to their compensation. We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure. Moreover, our Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest—both those arising between and among client accounts as well as between client accounts and our business. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. CONFLICTS OF INTEREST AND INFORMATION WALLS Merrill and its parent company, BofA Corp. engages in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic Institutional Investment Consulting Brochure 30|  Merrill Lynch Institutional Investment Consulting Brochure information and allow public side sales, trading and research activities to continue while other businesses within the BofA Corp. organization possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts of interest that exist explicitly or implicitly. Each of BofA Corp., BofAS, and Merrill evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. B. CODE OF ETHICS We have adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services. Each Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that we follow in conducting our business with integrity and professionalism. The Code of Ethics covers requirements related to employees complying with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. All covered personnel must certify to the receipt of the Code of Ethics. The Investment Adviser Code of Ethics is available to you upon request. We have imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions, as well as those of all employees. Our requirements impose certain responsibilities on Advisors and their trading. Advisors are permitted to participate in block trades along with their clients and/or other Program clients. C. COMPENSATION, CONFLICTS OF INTEREST AND MATERIAL RELATIONSHIPS 1. Sales Compensation – Benefits to Merrill and Designated Advisors from Enrolling in IIC Merrill Benefits. Merrill earns revenue from the Program Fee you pay. We (including our Affiliates) and your Designated Advisor and other of our employees benefit from the fees and charges paid by you and other clients for the Services described in this Brochure. The compensation structure for Designated Advisors results in conflicts of interest between clients and Designated Advisors as described in this Brochure. Designated Advisors earn compensation and benefits based on the revenue that Merrill earns from the fees paid in the Program. In addition, we earn revenue, and the Designated Advisor earns compensation, from the referrals to Affiliates (including referrals to an Affiliate for banking products or services). Merrill may also receive revenue from third parties depending on the investment products in which you invest, which is not part of the Designated Advisor’s compensation. As Merrill revenue increases, the Designated Advisor’s compensation will increase or will be positively impacted. The amount of revenue we receive and compensation your Designated Advisor earns varies depending on the type of Designated Advisor and the program, service or product you select. These differences create a conflict of interest in that there is a financial incentive for your Designated Advisor to recommend or select a certain Institutional Investment Consulting Brochure | 1 3  Merrill Lynch Institutional Investment Consulting Brochure type of relationship or certain investment programs based on the nature of the compensation they will receive. The amount of revenue we receive from your enrollment in the Program may also be more or less than the revenue that would be received if you had instead participated in other of our investment advisory programs or if you had engaged in the investment activities in a brokerage account. If there is higher compensation to us your Designated Advisor has a financial incentive to recommend certain investment strategies to you or recommend this Program over other programs or other services offered by us or our Affiliates. Designated Advisor Benefits. Designated Advisors that provide services to you under the Program receive a portion of the Program Fee as compensation. If you have an asset-based fee rate, the more assets there are in your account, the more you will pay in fees, creating a financial incentive to recommend that you increase the assets in your account. In the Program, we make more revenue based on the level of assets in the account if you have an asset-based fee rate as well as the level of the Program Fee rate that you agree to or are charged. There is a conflict of interest when an Advisor recommends an account or program type, a security transaction or investment strategy where it is expected that Merrill will earn greater revenue over another account or program type, security transaction or investment strategy and therefore an Advisor will earn more compensation. We address conflicts described in this and throughout the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure, by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, our Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. 2. Compensation and Benefits to Merrill and Designated Advisors Designated Advisors are paid a salary and incentive compensation by us based on the revenues Merrill receives for the Program that we and your Designated Advisor provide to your account. In general, a Designated Advisor is credited with a portion of the Program Fee paid, in the form of “production credits.” The more overall production credits that a Designated Advisor generates, the higher the Designated Advisor’s incentive compensation. The Designated Advisor has a financial incentive to recommend an investment approach and/or investment products and services that result in the highest production credit. Advisors are eligible to receive a compensation award, payable over a defined period of time, from an incentive program that is currently based on meeting growth targets from the prior year in new households and in assets and liabilities. The growth in assets and liabilities component of the award is based on: the movement of client assets into accounts enrolled in this Program and our other investment advisory programs; investment activity in specified investment products (e.g., money market funds, alternative investments, 529 Plan accounts, annuities and/or life insurance); the opening of new BANA trust accounts; the establishment of 401(k) Plan accounts; and clients’ participation in banking services and lending services (i.e., brokerage sweep deposit accounts and brokerage sweep money market funds, checking and savings accounts, the Preferred Deposit product available in brokerage accounts, loans, mortgages and margin lending) offered by Merrill, BANA and our other Bank Affiliates. Advisors do not receive additional compensation as a result of advisory client assets held in the bank deposit Cash Sweep Program. An Advisor is subject to a reduction in their incentive compensation grid if they fail to achieve growth for two consecutive years in the assets and liabilities component of the award. Merrill considers and approves its compensation program from year to year and its compensation criteria can change which will impact compensation paid to Advisors. Institutional Investment Consulting Brochure | 2 3  Merrill Lynch Institutional Investment Consulting Brochure Having a compensation award based on meeting criteria based on client investment activity or engaging with Merrill or Affiliate services presents a conflict of interest between the Advisor and you because it could lead to such activity being promoted by your Advisor to qualify for the compensation award or to avoid the reduction in their incentive compensation. Merrill addresses this conflict in a variety of ways, including by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures, documentation provided to clients prior to or at time of sale and disclosures in this Brochure. Our Advisors are also eligible to receive referral fees under defined referral programs and guidelines in the form of production credits based on referrals of clients to our bank Affiliates and other Merrill Affiliates for banking and lending services, like mortgages, as well as for referrals related to other financial services to other of our Affiliates. Advisors who join Merrill from other firms generally receive payments in connection with that move. These payments may take various forms, including salary guarantees, upfront bonuses or loans, and various forms of compensation contingent on continued employment. The amount paid to an Advisor under these arrangements generally is based to a large extent on the size of the business serviced by the Advisor at their prior firm. In addition, as part of the recruiting arrangements, an Advisor is eligible for future bonus payments based on assets that transfer, including from the Advisor's prior firm, which creates a conflict of interest since the Advisor has an incentive to recommend that you transfer your account to us. The future bonus payments are conditioned on the total assets in accounts serviced by the Advisor at Merrill. These bonuses are in addition to the incentive compensation to which a Designated Advisor is otherwise entitled as an Advisor. Advisors who recommend rolling over assets from an employer-sponsored retirement plan (such as a 401(k) plan) or from a retirement account at another firm into an Individual Retirement Account (IRA) or other similar account (a “Rollover”) and enrolling that account into the Program may receive compensation or benefit based on the amount of funds transferred. If you have an asset-based fee rate, there is a financial incentive for an Advisor to recommend a Rollover because the enrollment into the program or to a Merrill brokerage retirement account will generate compensation to Merrill and benefit the Advisor. 3. Field Management and Merrill Management Compensation. Elements of our field management compensation are based on revenues to Merrill and based on the Advisors whom they manage meeting strategic goals set for the year, including the growth in assets and liabilities component of the award as described above. Part of this award component includes the participation in banking and lending services described above offered by Merrill, BANA and our other Bank Affiliates. Management personnel and other employees of Merrill and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Merrill’s and BofA Corp.’s profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is an incentive for our field management team to encourage Advisors to recommend products and services that result in more revenue to Merrill and to meet their strategic growth compensation targets under the Advisor compensation plan. This includes enrollments into the Program, transactions in certain types of investment products and clients’ participation in banking and Affiliate lending programs, and other compensation targets. There is a financial incentive for management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. We maintain policies and procedures and supervisory and review processes that are reasonably designed to ensure that Advisors meet the standard of conduct applicable to each client and that Institutional Investment Consulting Brochure 33|  Merrill Lynch Institutional Investment Consulting Brochure compensation plans and referral compensation and criteria have been designed and implemented to mitigate any incentive or conflict to favor any one security type or investment product or service. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. 4. Account and Program Choice The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance for your Portfolio. The Program Fee you pay covers the Program, including investment advice and guidance under the Program as described in this Brochure. You may be able to obtain the same or similar services through other investment advisory programs and services offered by Merrill. These may be available at lower or higher fees than the Program fee you pay. You may also be able to obtain some or all services from other firms and at fees that may be lower or higher than the Program Fee we charge. We address potential conflicts in the following ways. We provide clients this Brochure, Client Agreement, and upfront information about our available programs. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Moreover, our Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. 5. Mutual Fund Related Compensation; Other Compensation We only make available mutual funds, money market funds (each, a “fund”) and share classes of funds that retain and pay us to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchange, dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under agreements with each of these funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services to the holders of these funds maintaining shares in an account as well as in other Merrill securities accounts and receive the agreed-upon sub-accounting services fee. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by fund types, fund and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. For U.S. mutual funds, depending on the specific arrangements, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.26% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market mutual funds, the sub- accounting services asset-based fee is generally 0.005% per annum. Money market funds available to certain accounts as an automatic cash sweep option also include an asset-based administration fee up to 0.50% per annum. Due to applicable regulation, we do not retain compensation for sub-accounting services for funds held in Retirement Accounts or Trust Management Accounts (“TMA”) accounts. Institutional Investment Consulting Brochure | 4 3  Merrill Lynch Institutional Investment Consulting Brochure We have a conflict of interest in selecting certain fund products (or share classes) for inclusion as part of our product offering available to you. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of our product menu but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting services fees that we charge will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the sub- accounting services fees varies among funds and, in certain instances, between share classes of individual funds. This results in a conflict of interest because it creates an incentive for us to recommend that you invest in funds and share classes that pay higher fees. We receive higher sub-accounting payments from fund families that have higher fund assets held in our clients’ accounts as the service fee calculation is based off of the level of the asset holdings. Additionally, there is benefit to us because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. We address these conflicts of interest in the following ways. We disclose the nature of our sub-accounting service arrangements. We also determine the compensation paid to our Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Advisors do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we and our Affiliates select funds that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. You should be aware that the amount of fees paid by the different mutual funds and/or mutual We also receive distribution (12b-1) fees up to 1.00%, administrative and shareholder servicing fees up to 0.55% with respect to mutual funds offered to customers, including participants in Plans that access the Program. We receive but do not retain compensation for sub-accounting, distribution (12b-1) fees, and administrative and shareholder servicing fees with respect to mutual fund assets held in Merrill accounts for Plans that access the Program. For more information, please refer to Mutual Fund Investing at Merrill Lynch or refer to the ERISA 408(b)(2) Fee Disclosure available from your Advisor upon request. We also receive compensation from some mutual fund sponsors for our distribution, marketing, and other support with regard to their mutual funds in amounts that vary by fund; we do not collect (or if we receive, we do not retain) such fees with respect to mutual fund assets held in Merrill accounts for Plans that access the Program. fund sponsors varies and that mutual funds that would otherwise meet our criteria for inclusion in the Program but whose principal underwriters, agents or sponsors do not agree to pay such fees will not be selected, thereby limiting the available universe of mutual funds. D. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS We, our Affiliates, your Designated Advisor and other of our employees’ benefit from the fees and charges you and other clients pay for the services described in this Brochure. Designated Advisors receive compensation from us for providing the services to clients enrolled in the Program and share portions of this compensation with other Advisors with whom they have made certain arrangements. The amount of this compensation is based upon, and will vary depending on the Program Fee. The amount of compensation we and your Designated Advisor receive from your enrollment in the Program may be more or less than the compensation we and the Designated Advisor might receive if you had instead participated in other of our investment advisory programs. If there is higher compensation, the Designated Advisor has a financial incentive to recommend this Program over other programs or other services offered by us (or our Affiliates). We, through our Advisors, may suggest or recommend that clients use our investment advisory programs, securities account, execution, and custody or other services for your investment activity or use the services of an Affiliate. Similarly, Advisors, who also handle clients’ securities accounts, may suggest or Institutional Investment Consulting Brochure | 3 5  Merrill Lynch Institutional Investment Consulting Brochure recommend that clients purchase Merrill’s products or products of an Affiliate. Where you use or purchase Merrill’s or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Advisors will, as permitted by applicable law, receive compensation (the amount of which varies) in connection with these products and services. As noted above, if your investment portfolio is subject to ERISA, your plan assets, including your investment portfolio under the Client Agreement, must be held at a custodian other than Merrill and may not be held in a brokerage account or enrolled in any investment advisory program offered by Merrill or its Affiliates. If your investment portfolio is not subject to ERISA, you may implement Program recommendations through an investment advisory program offered by Merrill or its Affiliates, however, you may not implement through a brokerage account at Merrill and should you do so, you will be subject to termination. If you utilize other products and services that we offer, we and our Designated Advisors will benefit from the additional compensation paid or generated by the selection. In particular, if you select an investment advisory program offered by Merrill or its Affiliates to implement Program recommendations, the amount of compensation we and your Designated Advisor receive would increase if the fees for the investment advisory program were higher than the fees for the Program. In that case, we and your Designated Advisor would have a financial incentive to recommend investment managers and strategies under the Program that you can implement at Merrill or its Affiliates and will have a further financial incentive to make recommendations to use an affiliated investment advisory program. We attempt to address this conflict through the disclosure in this Brochure and by selecting investment products and strategies based on the investment merits of the particular investment products and not based on the compensation earned from the providing these services. Merrill has business relationships with the officers, directors, or employees of a variety of clients, including corporations, pension and retirement plans, and other entities receiving services through the Program. These business arrangements create a conflict of interest to the extent that these individuals have any role or influence in the hiring or retention of Merrill and its Designated Advisors or with respect to their compensation. We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure. Moreover, our Designated Advisors are required to recommend investment advisory programs, investment products and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost; and a variety of restrictions, procedures and disclosures designed to address actual or potential conflicts of interest – both those arising between and among Accounts as well as between Accounts and our business (e.g., personal trading preapprovals, self-reporting, restrictions on our personnel detailed in our policies and procedures and Code of Ethics). E. RELATED PERSONS Other BofA Corp Affiliates or divisions offer their own managed products or wrap fee programs that are similar to this non-wrap fee program or other Merrill programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including advice related to the recommendation of certain investment managers. This is due to, among other things, the differing nature of the Affiliate’s investment advisory services and differing processes and criteria upon which determinations are made. F. COVERED ENTITIES UNDER THE VOLCKER RULE We may provide certain entity clients that qualify as “family wealth management vehicles” or FWMV clients, with both the Program Services as well as lending services and to engage, where permitted, in principal transactions. In doing so, we rely on the exception under the Volcker Rule implementing regulations that is Institutional Investment Consulting Brochure 3| 6  Merrill Lynch Institutional Investment Consulting Brochure available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Agreement. For certain entity clients that are deemed “covered fund” clients under the Volcker Rule, we are not permitted to offer both Program Services and the availability of margin, lending or other extensions of credit from us or any of our Affiliates, including BANA, or engage in certain principal transactions. Certain other transactions between BANA or its Affiliates and the entity client will also be prohibited. G. SECURITIES TRADING BY MERRILL AND OUR PERSONNEL We and our Affiliates act in a variety of capacities to a wide range of clients. As part of a global financial services firm, Merrill will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by Merrill or any of its Affiliates, it or its Affiliates’ roles in connection with other clients and in the capital markets, its internal policies, and/or potential reputational risk. As a result, client accounts managed by Merrill may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by BofA Corp. From time to time in the course of those duties, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. See “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Conflicts of Interest and Information Walls.” Similarly, we may give advice or take action with regard to certain clients, including IIC clients, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken with respect to certain securities or investment managers. In some instances, the actions taken by Affiliates for similar services and programs will conflict with the actions taken by us. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. Many of the conflicts related to participation or interest in client transactions and personal trading are less pronounced in the context of IIC because our recommendations are limited to the IIC Eligible Strategy universe. We have established a variety of restrictions, procedures and disclosures designed to address potential conflicts of interest – both those arising between and among client accounts as well as between client accounts and our business. For example, our personnel also are subject to personal trading restrictions as detailed in our policies and procedures and Code of Ethics. These policies and procedures and the Code of Ethics require our Designated Advisors to obtain pre-approval for certain securities transactions, disclose their investment accounts, and provide or cause Merrill to receive annual holdings reports and quarterly transaction reports. BROKERAGE PRACTICES The Program does not make specific securities recommendations or analyze particular securities. REVIEW OF ACCOUNTS An important part of the Program relationship involves providing you with the opportunity to engage in periodic reviews with your Designated Advisor. These reviews provide updates on the progress of your Portfolio towards your goals and other important information about your portfolio. Because these reviews provide you with important and necessary information relating to your portfolio, you are strongly encouraged to take advantage of these opportunities to participate in these reviews. As part of IIC, we will provide you with periodic written reports containing returns and other reasonable statistical performance analyses. Your Institutional Investment Consulting Brochure | 73  Merrill Lynch Institutional Investment Consulting Brochure Designated Advisor shall be made reasonably available to assist you in reviewing and evaluating the reports on the portfolio provided through IIC. Any review we perform does not substitute for your continued review of your reports or accounts. Our Program guidelines provide that, at a minimum, a periodic review of your account should occur on an annual basis, with Merrill having the ability to extend or defer the annual meeting within certain time limits based on meeting certain criteria. If you do not participate in a review within the timeframes we have established in our Program Guidelines, we have the right to, in our discretion, terminate an account from the Program. CLIENT REFERRALS AND OTHER COMPENSATION A. COMPENSATION FOR CLIENT REFERRALS Merrill has not entered into any client referral arrangements with third parties in connection with referrals of clients to IIC. B. OTHER COMPENSATION 1. Relationships With Third-Party Firms Third-Party Firm Business Relationships and Support We and our Affiliates have business relationships with Third-Party investment managers, including Style Managers, PAS Managers, fund managers, distributors and sponsors, and insurance companies and other product providers (“Third-Party Firms”). We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for a Third-Party Firm and for any fund offered through the Program (and if applicable, a portfolio company in which an AI Fund may hold an interest). We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates is additional compensation to us for services we and our Affiliates provide to them. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our Advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, we select investment products that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and procedures reasonably designed to prevent the receipt of Institutional Investment Consulting Brochure | 8 3  Merrill Lynch Institutional Investment Consulting Brochure such compensation and other business arrangements from affecting the nature of the advice we and our Advisors provide. Participation and Sponsorship by third-party firms for Merrill conferences, manager meetings and charitable Events Certain third-party firms periodically participate in Merrill-hosted internal training and education conferences for invited Merrill financial professionals. These financial professionals include Advisors and members of their team, employees who work for a Merrill branch, market or division to support the Advisors and employees who cover product, Chief Investment Office and home office support functions. Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where third-party firms participate. Merrill organizes the conferences and client events and approves the attendees, speakers, agenda and meeting content and sponsors. Third party firms reimburse Merrill for eligible costs associated with the conferences and client events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending Advisors and select employees facilitating the conferences and/or client events. During 2024, Merrill was reimbursed by participating third-party firms for certain expenses incurred in connection with a number of conferences and client events in the amount of approximately $21 million. Certain third-party firms periodically host or participate in meetings where they provide certain Advisors, field management employees and non-field employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-party firms that hold any such manager meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending Advisors, field management employees and certain permitted non-field employees (not including any CIO employee). In 2024, the total expenditures made by participating third-party firms relating to manager meetings was $3.1 million. Third-party firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by third-party firms in support of charitable events and causes that we requested or initiated with the third-party manager in 2024 was approximately $260,000. The participation of, and payment of costs by, a third-party firm for conferences, client events, manager meetings and charitable events present conflicts of interest. They create incentives for Advisors to recommend products of participating third-party firms. They give those Advisors participating in conferences, client meetings, manager meetings and charitable events more opportunities to interact and build relationships with third-party firms and their personnel which could lead them to recommend the products and services of these third-party firms over others. There is also a conflict of interest for field management employees to approve those recommendations and for non-field employees to select products of the third- party firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that third-party firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our Advisors to recommend the products or services of a third-party firm that makes such contributions over those that do not. We do not incentivize field management employees to approve their Advisors’ recommendations of products and services of those participating third-party firms. Furthermore, we do not incentivize non-field employees to approve particular products of a third-party firm for the Merrill platform. Third-party firms that elect to act as sponsors of national conferences and client events reimburse Merrill on an equitable basis for the eligible costs of the Institutional Investment Consulting Brochure | 9 3  Merrill Lynch Institutional Investment Consulting Brochure particular conference they sponsor. Third-party firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-party firm reimbursements of costs for conference and client events and the payment of manager meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Third-party firm Office Access and Gifts and Entertainment Representatives of third-party firms will, from time to time, meet and work with our Advisors, field management employees and non-field employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit third-party firms from providing or paying for, and our Advisors, Field employees and non-field employees, from receiving, gifts and entertainment (including meals) other than as permitted by and subject to the limits established under Merrill internal policies. In general, our Advisors, field management employees and non-field employees may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting third-party firm representatives access to our financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to recommend investment products of those third-party firms. It can also create incentives for field management employees to approve recommendations of an Advisor, where required. Furthermore, providing gifts and entertainment to non-field employees creates incentives to approve the investment products of the third-party firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency of office visits and other business interactions and the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-party firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from third-party firms. 2. Provision of Diversified Financial Services by Us and our Affiliates BofA Corp. is a diversified financial services company that generally provides, through us and our Affiliates, a wide range of services to retail and institutional clients for which it receives compensation. As a result, we, BofA Corp. and our Affiliates can be expected to pursue additional business opportunities with the entities whose investments we and our Designated Advisors recommend or make available to you. Consistent with industry regulations, the services that we and our Affiliates provide include banking and lending services, sponsorship of deferred compensation and retirement plans, recordkeeping services, investment banking, securities research, institutional trading and prime brokerage services, custody services, investment advisory services, licensing arrangements involving indices, and effecting portfolio securities transactions for our/its clients. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes Institutional Investment Consulting Brochure | 04  Merrill Lynch Institutional Investment Consulting Brochure in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships are publicly available in Regulation NMS Rule 606 reports we file with the SEC. CUSTODY To the extent we or an Affiliate hold any of the assets of your investment portfolio under this Program, you receive account statements from us or an Affiliate. You also should receive account statements from other unaffiliated custodians for assets of your investment portfolio held with such other unaffiliated custodians. We urge you to review these account statements carefully. Clients who do not receive such account statements are encouraged to follow-up directly with their custodian and request such statements. To the extent you receive additional reports from us, you should compare these reports to account statements received from custodians. Such reports may vary from custodial account statements based on accounting procedures, reporting dates, valuation methodologies and other factors and are not intended to be a substitute for account statements provided by a custodian, and should not be used for official purposes. Your account statement from us or an Affiliate or the account statements provided by other custodians reflect your official record of holdings, balances, and security values. INVESTMENT DISCRETION We do not accept discretionary authority in connection with the Program. VOTING CLIENT SECURITIES The Program does not involve voting proxies on a client’s behalf. FINANCIAL INFORMATION None. Institutional Investment Consulting Brochure | 4 1  Merrill Lynch Institutional Investment Consulting Brochure GLOSSARY “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Advisor” means a Merrill Financial Advisor. “Affiliate” means a company that is controlled by, in control of, or under common control with another company. “ADR” means an American Depositary Receipts. “ARS” means auction rate securities. “BANA” means Bank of America, N.A. “Bank Affiliate” means Bank of America, National Association (BANA) or other banks that are affiliated with us. “BofA Corp” means Bank of America Corporation. “BofAS” means BofA Securities, Inc., an Affiliate of Merrill. “Brochure” means the Merrill program brochure relating to the Merrill Lynch Institutional Investment Consulting Program, as amended or updated from time to time. The Brochure is also referred to as the Disclosure Statement. “CIO” means the Chief Investment Office and is the business group that provides investment solutions, portfolio construction advice and wealth management guidance to our clients. It is a separate division from the business group that administers the Program. “CIO Review Process” means the initial and periodic review conducted by the CIO and those processes and reviews provided by third-party reviewers that we have engaged for this purpose. “Client,” “you,” or “your” means the IIC client. “Client Agreement” means the investment advisory agreement between the Client and Merrill that you sign for the Program, as amended from time to time. “Code of Ethics” means Merrill’s Investment Adviser Code of Ethics. “Designated Advisor” means a Merrill Financial Advisor that has met certain Merrill requirements and qualifications to deliver IIC services. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. “ESG” means environmental, sustainability and governance. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “Excluded Assets” means the investment portfolio assets that Merrill will not assist the Client in the evaluation, review and selection of investment managers and strategies under the Program. These assets are private equity funds, hedge funds, limited partnerships, or other illiquid assets held by the Client as a part of the investment portfolio under the Program. “FDIC” means the Federal Deposit Insurance Corporation. “FWMV” means family wealth management vehicles. “FINRA” means the Financial Services Regulatory Authority, Inc. “Gifts” means non-monetary gifts and gratuities. Institutional Investment Consulting Brochure 2 | 4  Merrill Lynch Institutional Investment Consulting Brochure “IIC” or “Program” means the Merrill Lynch Institutional Investment Consulting Program. “IIC Eligible Strategies” mean investment managers and strategies that meet Merrill’s due diligence standards that will be used by Merrill and your Designated Advisor to make recommendations for your portfolio. “IPR” means the Institutional Performance Report. “IPS” means Investment Policy Statement. “Merrill,” “MLPF&S,” “we,” “us,” or “our” means Merrill Lynch, Pierce, Fenner & Smith Incorporated. “MID” means Manager Identification Report. “Order” means an order issued by the SEC. “PAS Manager” means a third-party investment manager who provides discretionary managed strategies selected by MLPF&S for the Program and related investment advisory and trading services. This type of manager may also be referred to as a DC Manager in certain of our Program materials. “Program Fee” means the IIC fee. “Style Manager” means an investment adviser, which may be Merrill, its Affiliate, or a third-party that provides a client’s Account with advice regarding the securities or other property to be purchased or sold in an Account. “SEC” means the U.S. Securities and Exchange Commission. “Trust Management Accounts” or “TMA” means accounts over which BANA performs trust services, in addition to custodial duties for the plan. Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation © 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated Printed in the U.S.A. Institutional Investment Consulting Brochure | 43 

Merrill Lynch Strategic Portfolio Advisor® Service WRAP FEE PROGRAM BROCHURE Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 800.637.7455 www.ml.com This wrap fee program brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“Merrill”) relating to the Merrill Lynch Strategic Portfolio Advisor® Service. If you have any questions about the contents of this brochure, please contact us at 800–MERRILL (800-637-7455). The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority Investment adviser registration does not imply a certain level of skill or training. Additional information about Merrill also is available on the SEC’s website at adviserinfo.sec.gov. The investment advisory services described in this brochure are not insured or otherwise protected by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency; are not a deposit or other obligation of any bank or any affiliate of Merrill; are not endorsed or guaranteed by Bank of America, N.A., Merrill, any bank or any affiliate of Merrill; and involve investment risk, including possible loss of principal. March 21, 2025 Investment products: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value SPA2A 0325  MATERIAL CHANGES On March 22, 2024, MLPF&S filed its last annual update for the Merrill Lynch Strategic Portfolio Advisor Service brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. It also sets forth changes as well as enhancements made in this annual update as well as those made since the 2024 annual update, which were previously communicated. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated Item 9 “Additional Information” at the heading “Disciplinary Information” to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its Financial Advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We enhanced existing disclosure regarding the conflicts of interest that Financial Advisors have when determining the SPA Fee Rate they will agree to with a client. See “The SPA Fee” and “Compensation, Conflicts of Interest and Material Relationships.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our Financial Advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Compensation, Conflicts of Interest and Material Relationships.” MATERIAL CHANGES AND ENHANCED DISCLOSURES MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes and Enhancements • We updated “Additional Information” at the heading “Disciplinary Information” to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and- desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” • We have updated our disclosures throughout the Brochure to make other enhancements. 1 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure TABLE OF CONTENTS MATERIAL CHANGES .....................................................................................................................................................................................................1 TABLE OF CONTENTS ...................................................................................................................................................................................................2 SERVICES, FEES AND COMPENSATION .............................................................................................................................................................3 DESCRIPTION OF SPA ............................................................................................................................................................................................3 MANAGER IDENTIFICATION SERVICE .............................................................................................................................................................4 MERRILL PERFORMANCE REPORTING SERVICE ........................................................................................................................................4 IMPORTANT CLIENT RESPONSIBILITIES .......................................................................................................................................................6 OPTIONS AND MARGIN STRATEGIES .............................................................................................................................................................7 REASONABLE INVESTMENT RESTRICTIONS ..............................................................................................................................................7 FUNDING AND OPERATION OF SPA ACCOUNTS .......................................................................................................................................7 TAX MATTERS ........................................................................................................................................................................................................ 12 CUSTODIAL ARRANGEMENTS ......................................................................................................................................................................... 13 TRADING IN SPA ACCOUNTS ........................................................................................................................................................................... 14 PROXY VOTING AND OTHER LEGAL MATTERS ....................................................................................................................................... 16 THE SPA FEE ........................................................................................................................................................................................................... 17 ABILITY TO OBTAIN CERTAIN SERVICES SEPARATELY AND FOR DIFFERENT FEES ............................................................... 21 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................................................................................................ 22 CLIENT ELIGIBILITY ............................................................................................................................................................................................. 22 ACCOUNT MINIMUMS ........................................................................................................................................................................................ 22 RETIREMENT ACCOUNTS ................................................................................................................................................................................. 22 PORTFOLIO MANAGER SELECTION AND EVALUATION ........................................................................................................................ 22 REVIEW OF COVERED STRATEGIES AND MANAGER IDENTIFICATION SERVICES ................................................................... 22 SCOPE OF OBLIGATIONS RESPECTING UNCOVERED STRATEGIES ............................................................................................... 24 ADVISORY SERVICES PROVIDED BY MERRILL AND CERTAIN AFFILIATES .................................................................................. 24 INVESTMENT RISK ............................................................................................................................................................................................... 25 TAILORED INVESTMENT ADVICE ................................................................................................................................................................... 28 PERFORMANCE-BASED FEES ......................................................................................................................................................................... 28 METHOD OF ANALYSIS ...................................................................................................................................................................................... 28 VOTING CLIENT SECURITIES ........................................................................................................................................................................... 29 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ..................................................................................................... 29 CLIENT CONTACT WITH PORTFOLIO MANAGERS .................................................................................................................................... 29 ADDITIONAL INFORMATION .................................................................................................................................................................................. 29 DISCIPLINARY INFORMATION ......................................................................................................................................................................... 29 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....................................................................................................... 30 CONFLICTS OF INTEREST AND INFORMATION WALLS ...................................................................................................................... 31 CODE OF ETHICS .................................................................................................................................................................................................. 31 COMPENSATION, CONFLICTS OF INTEREST AND MATERIAL RELATIONSHIPS ....................................................................... 31 PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ............................................................................................................... 39 REVIEW OF ACCOUNTS; REPORTS ............................................................................................................................................................... 42 CLIENT REFERRALS AND OTHER COMPENSATION .............................................................................................................................. 43 FINANCIAL INFORMATION ...................................................................................................................................................................................... 43 GLOSSARY ........................................................................................................................................................................................................................... 44 2 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure SERVICES, FEES AND COMPENSATION This Brochure relates to the Merrill Lynch Strategic Portfolio Advisor® Service, an investment advisory service (“SPA” or the “Program”) offered by Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or “Merrill”). This Brochure also contains important information relating to clients’ responsibilities for their account when enrolled in the Program (an “Account”), certain conflicts of interest involved with the services offered, and other matters. You should read this Brochure carefully when deciding whether the services are appropriate for you and ask your Financial Advisor any questions you may have. MLPF&S is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser and as a broker dealer. Merrill is an indirect wholly-owned subsidiary of Bank of America Corporation (“BofA Corp.”). BofA Corp,. through Bank of America, N.A. (“BANA”), BofA Securities, Inc. (“BofAS”) and other Affiliates, provides integrated investment services and is a leading banking institution for consumers, corporations and institutions. Capitalized terms that are not defined in this Brochure have the meanings provided in the Glossary. As used in this Brochure, “you” and “your” refer to the client. “We,” “us,” “our” and “MLPF&S” refer to Merrill. DESCRIPTION OF SPA For an annual asset-based fee, SPA clients receive (except as otherwise indicated) manager identification services, performance reporting, execution and custodial services and other account-related services (“SPA Services”). The manager identification service offers clients the opportunity to select one or more investment styles or disciplines or combinations of investment styles and disciplines (“Strategies”) offered by investment managers participating in SPA (“Investment Managers”). The Merrill performance reporting service provides reports containing returns and other statistical performance analyses. We want you to know a few things upfront about SPA, including: • You enter into an investment advisory agreement with us (the “Client Agreement”) for the services you receive from us. • As described in greater detail below, you agree to pay Merrill an annual asset-based fee (“SPA Fee”) for the services you receive from us for your Account. • The SPA Fee is negotiable depending upon a number of factors. • You will need to enter into a separate agreement with your selected Investment Manager. • Your Investment Manager will charge you a separate management fee for its services. • Your Investment Manager is exclusively responsible for the management of your assets. The scope of any investment advisory relationship we have with you is defined in the Client Agreement. When you are enrolled in SPA, we act as your investment adviser only for your Account and not any other assets or accounts, unless otherwise separately agreed to by us in writing. Our SPA advisory relationship begins when we enter into the Client Agreement with you, which occurs on the later of the date of acceptance of the signed Client Agreement by us or the date you have contributed assets in the Account. Preliminary discussions or recommendations before we enter into the Client Agreement with you are not investment advice and should not be relied on as such. Merrill has certain fiduciary obligations in providing the SPA Services. As a fiduciary, we will act in your best interest and will endeavor to provide you material facts and information relating to the SPA Services. This Brochure is a key element in meeting this disclosure obligation. The fiduciary standards we aim to follow are established under the Advisers Act and, where applicable, state laws. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in our Client Relationship Summary on Form CRS (“Form CRS”) and in the Summary of Programs and Services, both of which are available at ml.com/relationships or upon request. In addition, these documents provide a summary of the other available investment 3 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure advisory programs we offer. Certain aspects of these investment advisory programs are similar to the Services available in the Program. Please refer to the section “Ability to Obtain Certain Services Separately and for Different Fees.” MANAGER IDENTIFICATION SERVICE Based on your responses to the Profiling Questionnaire, your Financial Advisor will assist you with your selection of an Investment Manager and Strategy. If you select a Strategy from the list of Strategies from which clients may select (“Coverage List”), or the Strategy is not available in SPA for new Accounts but is an investment strategy that is made available in the Merrill Lynch Investment Advisory Program (“MLIAP”), we, through the Chief Investment Office (CIO), will provide ongoing due diligence on such Strategy. If an Investment Manager or Strategy is removed from the Coverage List or is removed from MLIAP as an available strategy, we will no longer perform ongoing due diligence. We do not perform due diligence on any other strategy or Investment Manager other than those on the Coverage List or those that are available in MLIAP. Manager identification services are completed upon the presentation of the Investment Managers referred to above. It is your responsibility to select and/or retain any of the Investment Managers presented and to negotiate the terms of any Investment Manager agreement. Thereafter, new manager identification service recommendations will only be prepared upon your specific request. The Investment Manager’s fee is not included in the SPA Fee. Manager identification services do not present information on all of the Investment Managers that might be appropriate for you. In compiling a list of Investment Manager candidates, we are limited by the scope of databases used and other practical considerations and may exclude firms viewed as direct competitors. In addition, given our diversified financial services business, we and our Financial Advisors have relationships or dealings with, and receive direct or indirect compensation or other benefits from, Investment Managers presented to you with manager identification services. Certain Investment Managers participating in the SPA service are also available for your selection in other of our investment advisory programs. Please refer to the section “Ability to Obtain Certain Services Separately and for Different Fees.” For a description of the manager identification services offered as part of the Program, see the section “Portfolio Manager Selection and Evaluation—Review of Covered Strategies and Manager Identification Services.” MERRILL PERFORMANCE REPORTING SERVICE Merrill periodic performance reports. We assist you in monitoring and evaluating the performance of your Account by providing periodic performance reports containing returns and other statistical performance analyses. Account returns are compared with the returns of selected market indexes and other professionally managed investment accounts. Performance reports provide an attribution analysis of the effect on performance of the Investment Manager’s securities selections and asset allocation decisions. An assessment of the risk taken to achieve the returns is also presented. In consultation with your Financial Advisor, you can customize the performance report by choosing certain approved indexes and benchmarks for portfolio comparison purposes, and you can select the level of report detail that meets your needs. You should use the report to evaluate your Investment Manager and its progress towards selected goals. Your Financial Advisor will be available to assist you in understanding the format and content of the performance report, which includes graphic and tabular presentations of performance. The principal source of information for the performance report is data from Merrill; provided, however, if the custodian for an Account is a third party custodian that is not a Merrill Affiliate (an “Unrelated Custodian”) or a custodian that is a Merrill Affiliate (an “Affiliated Custodian”), the source of the information for the performance report is the custodian. We also use outside information sources including computer and data analysis firms. This information is obtained from sources believed to be reliable, but reliability cannot be guaranteed. The inclusion of any particular securities in the performance report does not constitute a recommendation or advice with regard to suitability or the appropriateness of continued investment. When special circumstances come to its attention, Merrill reserves the right to make adjustments which, in its judgment, would more accurately reflect the value of securities held in, and the performance of, a particular portfolio. In connection with the information contained in the Merrill performance report, you should note that: • Changes in Account valuations due to capital gains or losses, dividends, interest or other income are included in the calculation of returns. 4 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure • Account returns will be shown both before and after the deduction of the SPA Fee and the Investment Manager Fee (as defined below) depending on the report selected (when such advisory fees are provided to Merrill for inclusion in the performance report). • When your assets are maintained by an Unrelated Custodian or an Affiliated Custodian, we will rely upon the data supplied by the custodian in preparing the performance report. We are not responsible for the accuracy of this data. When special circumstances come to our attention, we reserve the right in our discretion to make adjustments which, in our judgment, would more accurately reflect the value of securities held in, and the performance of, a particular Account. • Differences in transaction costs among accounts used in the Investment Manager’s composite will affect account comparisons. • The market indexes shown in the performance report do not include transaction costs. If available, an actual investment in these indexes, or in the securities comprising the indexes, would require an investor to incur transaction costs and performance would be reduced by such costs and their compounded effect. • Performance information from third-party sources may differ from that shown in the performance report. These differences may be due to different methods of analysis, different pricing sources, treatment of accrued income or different accounting procedures. For example, infrequently traded fixed-income securities may be priced according to yields calculated on a matrix system, which varies among pricing sources. • The methodology used by an Investment Manager to select and aggregate accounts for performance reporting purposes (i.e., the development of the Investment Manager’s composite), as well as the calculation of performance results reported by each Investment Manager for its composite and its underlying accounts, may not have been created or calculated on a uniform or consistent basis from manager to manager. • Performance information provided by the Investment Manager or obtained from third-party sources may include data pertaining to types of accounts that are different from the type of account you are interested in having managed. We encourage you to evaluate this performance data carefully and to consider all relevant factors in selecting or retaining one or more Investment Managers. Institutional Performance Reporting. IPR is no longer available for new clients enrolling into SPA. SPA Accounts that had selected Institutional Reporting service prior to March 27, 2017 will continue to receive those services. With the IPR service, the eligible SPA client is provided with in-depth performance reporting through the Institutional Performance Report (“IPR”) that details the portfolio’s performance, how that performance was achieved and the factors primarily responsible for it. The report also presents monthly cash flows and portfolio valuations, current asset allocations, returns compared to the market indexes and other benchmarks, risk analysis, and analysis to help identify how much of the portfolio’s performance can be attributed to management decisions rather than to market conditions, asset allocations or other factors. The IPR is provided for performance measurement purposes only. The principal source of information for the IPR is data from the custodian for the eligible SPA Account. Merrill uses outside information sources including computer and data analysis firms. This information is obtained from sources believed to be reliable, but reliability cannot be guaranteed. The inclusion of any particular securities in the IPR does not constitute a recommendation or advice with regard to suitability or the appropriateness of continued investment. The IPR provides information about the eligible SPA Account, market indices, goals and risk level. In connection with the information in the IPR, such as the comparisons of the returns of an IPR client’s portfolio with those of the selected market indexes and other professionally managed portfolios, it should be noted that: • Changes in portfolio valuations due to capital gains or losses, dividends, interest or other income are included in the calculation of returns. • Transaction costs, such as commissions, are included in the purchase cost or deducted from the proceeds of a sale of a security. • Portfolio returns are shown before the deduction of investment advisory fees for the accounts. Investment advisory fees (when reported to Merrill) are treated as a portfolio withdrawal rather than as a reduction in income and therefore do not reduce returns (unless the client requests that these fees be treated as a reduction in income). 5 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure  • The return information for the accounts, market indices and return comparison charts reflect time-weighted rates of return unless the returns are labeled “Internal Rate of Return.” Both return calculations reflect transaction costs, market appreciation or depreciation and the reinvestment of capital gains, dividends, interest and other income. • If an Account has been managed by more than one Investment Manager, the manager name in the IPR reflects the current manager. However, the return and standard deviation information may be calculated using the entire history of each Account. Note that the IPR may also include information regarding account(s) that are not managed by an investment manager (i.e., where you make the investment decisions). When client assets are maintained by an Unrelated Custodian or Affiliated Custodian, Merrill will rely upon the data supplied by the custodian in preparing the IPR. Merrill is not responsible for the accuracy of this data. When special circumstances come to its attention, Merrill reserves the right to make adjustments which, in its judgment, would more accurately reflect the value of securities held in, and the performance of, a particular portfolio. IMPORTANT CLIENT RESPONSIBILITIES As with any investment advisory program, different parties have different responsibilities and it is important for you to understand what you and your Investment Manager are responsible for (as opposed to what we are responsible for). You are responsible for the following: • Providing accurate and complete information. You are responsible for providing accurate and complete information about your investment profile for the Account including in respect of the completion of a Profiling Questionnaire or other forms that elicits various types of information. • Notifying your Financial Advisor and Investment Manager of certain material changes. You must notify the Investment Manager promptly of any material change in financial circumstances, investment objectives, or investment restrictions (if any). Because the management of your Account is your Investment Manager’s responsibility and not ours, you must provide any such updated information directly to your Investment Manager. We and your Financial Advisor do not have any obligation to communicate such information to your Investment Manager. You must notify your Financial Advisor or any such circumstances that may affect the services your Financial Advisor provides to the SPA Account. We will periodically notify you to emphasize the need to report such information. • Selecting your Investment Manager and Strategy. You should review the data and materials we provide you carefully before taking appropriate action to select your Investment Manager and Strategy. Upon selection, the Investment Managers have exclusive discretionary authority over the Accounts that they manage. • Notifying your Investment Manager of additions, or withdrawals, of assets to/from your Account. You have the responsibility to notify your Investment Manager promptly with respect to any addition, or withdrawal, of assets to/from your Account maintained at Merrill, an Affiliated Custodian or an Unrelated Custodian. • Avoiding conflicting instructions. You have the responsibility to avoid providing conflicting instructions to us and your Investment Manager. Merrill does not assume responsibility for your choice of Investment Manager and Strategy, the Investment Manager’s and Strategy’s investment performance, the Investment Manager’s adherence to your objectives and restrictions, the Investment Manager’s compliance with applicable laws or regulations, and/or other matters within your Investment Manager’s control. Similarly, we do not monitor transactions directed by the Investment Managers for compliance with any applicable restrictions or requirements, even where we execute the transactions. You always retain the final authority, obligation and responsibility for making your own determinations regarding the selection and retention of an Investment Manager as well as the monitoring of your Accounts. We encourage you to speak with your Investment Manager to discuss any questions that you may have about existing or potential conflicts of interest relating to your Investment Manager. We note that certain Investment Managers may be an Affiliate of Merrill (“Related Manager”). Related Managers and your ability to use Related Managers as part of SPA presents conflicts of interest for the Related Manager and us. We discuss these conflicts in the section entitled “Use of Related Investment Managers.” 6 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure OPTIONS AND MARGIN STRATEGIES In certain circumstances, your Investment Manager may employ margin, write uncovered options and/or sell securities short (collectively, “Options and Margin Strategies”). As disclosed in the documentation relating to the use of margin in your Account you executed when opening your underlying securities account (“Margin Agreement”), if your Investment Manager uses margin to purchase securities, the collateral for the margin debt will be the assets in your Account and other accounts at Merrill. If the securities in a margin account decline in value, so does the value of the collateral supporting the margin loan, and, as a result we can take actions, such as issuing a margin call or selling securities or other assets maintained at Merrill in order to maintain the required equity in the account. Overall, margin increases the risk of losses you would sustain, as compared to an unleveraged Account, in declining markets that negatively affect the value of securities bought on margin. You assume full responsibility for your Investment Manager using margin to buy securities. If you determine that you no longer want your Investment Manager to use margin in your Account, you are responsible for notifying your Investment Manager of such determination. We are not responsible for any losses resulting from your Investment Manager’s failure or delay in implementing such instructions. You may also discontinue use of margin in your Account according to the terms of the Margin Agreement. If you terminate the Margin Agreement, you are responsible for notifying your Investment Manager of such termination. We are not responsible for notifying your Investment Manager of the termination of the Margin Agreement or for any losses resulting from your failure to so notify your Investment Manager. In certain circumstances, your Investment Manager may write uncovered options and sell stock short in your Account. If you permit your Investment Manager to write uncovered options, you will be exposed to potentially significant losses. For a call option, if the value of the underlying instrument increases above the exercise price, you can incur large and unlimited losses until the option expires or other contract remedies are pursued. For a put option, you bear the risk of loss if the value of the underlying instrument declines below the exercise price. If your Investment Manager writes combination or straddle options (where your Investment Manager writes both a put and a call option on the same underlying instrument), your potential risk of loss is unlimited. Further, if a secondary market in options were to become unavailable, your Investment Manager could not engage in a closing transaction and you would remain obligated until expiration or assignment. To engage in options transactions, you need to execute an option account agreement and, under the terms of that agreement, if you do not meet applicable margin payment requirements, we may liquidate stock, options or other account positions in your Account, with little or no prior notice to you. Selling stock short raises similar risks as writing uncovered call options and you will assume similar risks of loss. The costs, risks and other features and conditions of margin and short sales are more fully described in the Margin Agreement. REASONABLE INVESTMENT RESTRICTIONS You may impose reasonable investment restrictions on your Account, but you must communicate such restrictions directly to your Investment Manager. It is your responsibility to monitor such investment restrictions, review such investment restrictions with your Investment Manager, and advise the Investment Manager of any discrepancies or modifications to such restrictions. You should understand that your Investment Manager, not Merrill, will be responsible for complying with your restrictions, if any, and we and your Financial Advisor shall not be responsible for communicating, implementing or monitoring your restrictions. If you have selected to restrict investments in your Account, you accept any effect such restrictions may have on the investment performance and/or diversification of the Account. FUNDING AND OPERATION OF SPA ACCOUNTS Funding Accounts. We will initiate SPA Services for new Accounts after your execution of any required Account documentation, approvals and funding of the Account and expect such enrollment to occur promptly. Enrollment may be delayed or rejected if the account is underfunded or funded with ineligible assets. A Client request to enroll in the Program is not considered a market order due to the requirements for enrollment which includes funding as well as the administrative processing time needed to implement enrollment instructions. There is typically a short delay between Account inception and initial investment transactions. Until we initiate Program services with respect a new Account, your assets will be held in a brokerage account for which you will be solely 7 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure responsible for making any investment decisions with respect to the assets. During such time, we will not act as an investment adviser with respect to the assets. Not all account types are eligible to enroll in the Program. You may fund your Account by depositing cash and/or securities acceptable to us. We may determine in our sole discretion that certain assets are ineligible for the Program or otherwise unacceptable. Failure to comply with a request to transfer such assets out of an Account enrolled in the Program will result in that Account’s termination from the Program. Upon enrollment in the Program, you acknowledge and direct that any “good-til-cancelled,” “good-til-date” or “day limit” orders for equity securities that have not been executed be cancelled. You should consider all relevant factors before you fund (either initially or otherwise) your Account with mutual fund shares or other securities, including that: • Your Investment Manager generally cannot purchase additional shares of any mutual fund in your Account (as described below), though your Investment Manager may sell them from your Account. • If you fund your Account with mutual fund shares, we will (except in certain limited circumstances) request that such shares be liquidated or transferred from your Account. If they are not liquidated or transferred within a limited period of time after being requested to do so, your Account will be removed from the Program. During the period of time that such contributed mutual fund shares are in your Account, we will consider such assets to be ineligible for the Program and, accordingly, they will not ultimately be subject to the SPA Fee. See “The SPA Fee-Calculation of Account Fees” for more information. • In all cases, we will not exchange any mutual fund holdings in your Account to other share classes. Accordingly, you should not assume that these contributed mutual fund shares are the mutual fund share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. • You may have paid a front-end sales charge or may be subject to contingent deferred sales charges (“CDSC”) or redemption fees. Such sales charges and fees, if applicable, will remain your responsibility and will be in addition to your SPA Fee. Clients should understand that, upon their account enrollment in SPA, the following services will not be available for that Account: checks, Visa® debit cards, web bill pay, online client orders, and systematic withdrawal services such as Move Money®/funds transfer disbursements. Similarly, the enrollment of an account in the Merrill Automated Investment Program (“AIPS”) will be suspended during your participation in SPA, except to the extent that you have authorized the automatic transfer of cash into the Account. Additional assets contributed through AIPS will be invested at your Investment Manager’s discretion. Withdrawals and Addition of Assets in SPA Accounts. You are responsible for notifying your Investment Manager of any deposits made into your Account and instructing your Investment Manager to liquidate positions in the event you wish to withdraw assets from your Account. We have no responsibility to invest cash deposits (other than cash sweeps described below) or liquidate positions for withdrawal, tax purposes or for other situations, nor do we have responsibility for any losses that may result from your failure to notify your Investment Manager. Unless otherwise agreed, your Account will be credited with any dividends, interest and principal paid on assets held in your Account. Cash Balances and the Cash Sweep Program. At times, your Account will have an allocation to cash based on the Strategy selected, the asset allocation and investment determinations your Investment Manager has made. The cash allocation is held as a cash balance and/or invested in cash alternatives such as money market mutual funds (“money market funds”) as determined by the Investment Manager for the Strategy, which could be a Related Manager. The allocation can result from your Investment Manager’s decision to keep a cash balance for operational and/or investment purposes as part of the investment strategy and is based on a number of factors, including the nature of the investment approach for the Strategy, the asset allocation, the investment determinations, rebalancings, market conditions, the Investment Manager’s cash management approach and market view and concerns. In certain circumstances, including periods of volatile or uncertain market conditions, any such cash allocation will be higher based on, for example, concerns about the market or a decision to pursue a defensive investment strategy. Some types of Strategies include investments that take an extended period of time to purchase due to the type of security, market availability and selection criteria. Until invested, the cash for these investments is typically automatically swept under the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the Investment Manager as a temporary investment pending purchase of the individual security. 8 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Unless your Investment Manager directs that your Account’s cash allocation be invested in a cash alternative investment like a money market fund, your Account’s cash allocation will be treated as a cash balance in your Account. Any cash balances will automatically be “swept” with your consent in accordance with the terms of your underlying Merrill brokerage account agreement (the “Cash Sweep Program”). The available automatic cash sweep options under the Cash Sweep Program vary based on the Merrill account type and other criteria such as citizenship, residency status and jurisdictional restrictions. Not all Merrill account types have the same cash sweep option. Except as described below, the only automatic cash sweep options currently available for Merrill account types eligible for enrollment in the Program are the Merrill Lynch Bank Deposit Program (“MLBD Program”), the International Bank Variable Rate Deposit Facility (“IBVRD Facility”) for accounts of non-U.S. citizens who are not residents of the U.S., and the Retirement Asset Savings Program (“RASP”) for retirement accounts. The MLBD Program, IBVRD Facility and RASP provide for an automatic sweep of cash balances to bank deposits with BANA and other banks affiliated with us (“Bank Affiliates”). For certain qualified retirement plan account types, the accountholder selects either: (1) the MLBD Program; (2) the Insured Savings Account Program (“ISA”), a bank deposit program where cash is swept to our Bank Affiliates and unaffiliated participating banks (the “ISA Participating Banks”); and (3) certain money market mutual funds. To view a list of the depository institutions currently participating in the ISA Program, visit www.ml.com/ISA. Certain other Merrill account types for qualified retirement plans have the automatic cash sweep option of a money market fund only. The trust management account type (“TMA”) over which BANA provides various investment and trust-related services has its own automatic sweep options which include bank deposits at Bank Affiliates, the ISA Program and certain money market funds. Please refer to your trust agreement and/or TMA Brochure for additional information regarding the automatic sweep options for a TMA Account. You can obtain a paper copy of these disclosures from your Financial Advisor. Please refer to your account agreement and related disclosures for additional information regarding the automatic sweep options for your type of account. The Sweep Program Guide for Merrill Clients, which can be found on mymerrill.com or is available from your Financial Advisor, provides an overview of the automatic cash sweep options and how they work and a chart of automatic cash sweep options by Merrill account type. The current rates and yields for the cash sweep options are available at mymerrill.com and from your Financial Advisor. “Bank Deposit” Sweep Option. Under the MLBD Program, RASP and the IBVRD Facility, an Account’s cash balance is swept to accounts held at our Bank Affiliates. Under the ISA Program, an Account’s cash balance is swept to accounts that are held at ISA Participating Banks. To view a list of the depository institutions currently participating in the ISA Program, visit www.ml.com/ISA. Under each of the MLBD Program, the IBVRD Facility, RASP and the ISA Program, Merrill as your agent establishes the bank deposit accounts on your behalf at the Bank Affiliate or the ISA Participating Bank as provided for in your underlying brokerage account agreements. Bank deposits in the MLBD Program, RASP and the ISA Program are insured by the Federal Deposit Insurance Corporation (“FDIC”). Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection programs. Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Certain conditions must be satisfied for deposit insurance coverage to apply when bank deposits are opened on your behalf in the name of Merrill as your agent. Merrill has in place business requirements and practices that are reasonably designed to satisfy those conditions, which include, but are not limited to, proper account titling and recordkeeping. The sweep deposit accounts at banks in the MLBD Program, RASP and the ISA Program are protected by FDIC insurance, up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership category, per bank. FDIC insurance covers both principal and credited interest, up to applicable limits. Any such deposits in the same account ownership category, whether directly, through other Merrill accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If your total cash balances in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) of, and/or in any type of bank product (i.e., a brokered CD) of a Bank Affiliate in the MLBD Program or RASP or any ISA Participating Bank exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Neither Merrill nor the Bank Affiliates manage or monitor the deposits swept under the MLBD Program, the RASP or the ISA Program for FDIC insurance limit purposes. Deposits are not aggregated or limited under the MLBD Program, RASP and the ISA Program based on the FDIC limits for the same depositor in the same bank across Merrill accounts. Merrill 9 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure does not undertake through the SPA Program or the Client Agreement or under the underlying brokerage agreement to provide you notice that cash balances in your SPA Account or in any of your other brokerage accounts or investment advisory accounts exceeds the FDIC coverage limit for any of our Bank Affiliates or any other Participating Bank. Monitoring FDIC insurance coverage limits is expressly not a SPA Service. You are responsible for monitoring the total amount of deposits held at the Bank Affiliates and at any ISA Participating Bank in order to determine the extent of FDIC insurance. The agreements and disclosures that you received in connection with establishing your underlying Merrill brokerage account and the Sweep Program Guide for Merrill Clients include additional information about FDIC insurance. A paper copy can be obtained from your Financial Advisor. For additional information on FDIC insurance, visit fdic.gov. Cash balances swept under the MLBD Program and RASP to a bank deposit account of our Bank Affiliates will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts will be periodically set and reset by the Bank Affiliates in their discretion. The rate is variable and may change at any time after the account is opened without notice or limit. Under MLBD Program and RASP, interest rates are tiered based upon a client’s relationship with Merrill. Accounts with the MLBD Program and RASP as their Cash Sweep Program that are enrolled in SPA and in other specified Merrill investment advisory programs receive the highest tier rate available under the MLBD Program or RASP. A brokerage account with one of these sweep options that enrolls in the SPA Program will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. There is no interest rate tiering offered under the IBVRD Facility. Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection and receive a lower rate than the highest rate available under the MLBD Program or RASP. The interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. “Money Market Fund” Sweep Option for Certain Account Types. Under account agreements covering certain retirement accounts where the account holder has selected the money market fund option for the cash sweep, please note that these money market funds have certain internal expenses and costs and also include a 0.40% asset-based administration fee per annum that is paid to Merrill. Merrill rebates the amount of the asset-based administration fee it receives to the clients of these Retirement Accounts with this sweep option. The amount of such rebate may be less than this 0.40% fee in certain rate environments where the fund manager waives or reduces the amount of such fee in order to avoid a negative return on the money market fund. You will bear your proportionate share of such money market fund’s fees and expenses including, but not limited to, management fees paid to the fund’s investment manager or its Affiliates, fees payable to the fund’s professional and other service providers, transaction costs and other operating costs. The SPA Fee does not cover or offset any fees and expenses that the money market fund incurs for transactions occurring within the fund itself. Please consult the prospectuses and offering material for the sweep money market funds for more detailed information on the amounts charged. “No Sweep” Option. Certain account types have the option to select the “No Sweep” option under their underlying brokerage agreement which results in cash being held as a cash balance and not ‘swept’ to any available sweep option under the Cash Sweep Program. The cash balance will not earn interest or dividends. The cash will be covered by the Securities Investor Protection Corporation (SIPC) up to $500,000 per client, inclusive of $250,000 for cash. As a registered broker-dealer, Merrill benefits from the possession or use of cash balances, also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. Conflicts of Interest related to the Cash Sweep Program. We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See “Compensation, Conflicts of Interest and Material Relationships” at the section “Cash Sweep Program Compensation Received by Us and Our Affiliates.” See also “Participation or Interest in Client Transactions—Cash Balances and Cash Sweep Program.” 10 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Cash Held with Custodian other than MLPF&S. Cash held with a custodian other than MLPF&S is not covered by the Cash Sweep Program and will not be subject to its cash sweep arrangements. You are responsible for separately establishing appropriate sweep arrangements with any such custodian. We will include the cash positions in your Account are included in the value of your Program assets for the calculation of the SPA Fee. Assets held in Accounts with a custodian other than MLPF&S are not subject to Merrill’s SIPC coverage. Closing an Account and/or Terminating the Client Agreement. The Client Agreement may be terminated at the direction of you or us as described in the agreement. The termination of the Agreement will terminate the Account enrollment in the Program. Termination of the Agreement will not generally affect or preclude the consummation of any transaction previously initiated for the Account and the completion of other processes that may be required to terminate the Account. Termination of your Account will be effective following the completion of processes that may be required to terminate the Account, including any required liquidations. We will not be responsible for market fluctuations in your Account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient liquidation of an Account include, but are not limited to, size and types of securities, liquidity of the markets and market-makers’ abilities. Due to the administrative processing time needed to terminate an Account, termination requests cannot be considered market orders. It could take up to several business days under normal market conditions to process your request. Termination of the Client Agreement is separate from, and will have no automatic effect on, any agreement entered into between you and your selected Investment Manager. You have the responsibility to notify your Investment Manager of your decision to terminate the SPA Account or terminate your agreement with your Investment Manager. You further understand that neither Merrill nor your Financial Advisor is responsible for notifying your Investment Manager of your decision to terminate the Client Agreement or your agreement with your Investment Manager. Except as otherwise provided in the Client Agreement, neither Merrill nor your Financial Advisor are responsible for any losses incurred by you as a result of your failure to notify the Financial Advisor of the termination of your agreement with the Investment Manager. Upon termination, we will refund any prepaid SPA Fee on a pro rata basis as specified in the Client Agreement or as required by law. The termination of your Financial Advisor’s employment with Merrill will not automatically terminate the Client Agreement. In the event that your Financial Advisor is no longer able to service your Account, Merrill may reassign that Account to a different Financial Advisor and you will be notified of any such change. Rules for Cash Accounts and Margin Transactions. As a broker-dealer, Merrill is responsible for compliance with federal margin rules. When an Account enrolls in the Program, the Account will be designated as a cash Account irrespective of whether or not the accountholder had selected that margin apply to the underlying securities account. This account notation means that margin is not permitted and purchase of securities must be fully paid for on the date of the trade. With a cash Account, if securities are sold before the payment for their purchase has settled, an event known as a “free-riding violation” has occurred. Free-riding is prohibited under margin rules and our Program guidelines. Having a “free-riding” violation may result in your Account being restricted for 90 days or “frozen.” The imposition of such a freeze could have a negative effect on your Account and performance. The risk of engaging in an inadvertent “free-riding” violation and therefore freezing of your Account is enhanced (1) when you change Investment Managers and reconstitute your investments; (2) when you engage in periodic rebalancing (which results in purchases and sales of securities over a short period of time); or (3) when you withdraw cash from your Account when there is a pending order to purchase a security. If an Options and Margin Strategy is selected for the Account, margin will be specifically permitted and the account designation will change to that of a margin account. Loans and Collateral. Certain of your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through loan programs (“Lending Programs”), including those of Affiliates of Merrill, such as the securities-based lending Loan Management Account® (“LMA”) and Mortgage 100®/Parent Power® mortgage programs). The terms and conditions applicable to the Lending Program are governed by the applicable loan documents and other service agreements and are not included or described further in this Brochure. You should review carefully the terms, conditions and any related risk disclosures for such Lending Program. 11 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure The risks of pledging the assets in an Account in a Lending Program will be heightened in the event you pledge your account or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. The lender has the right to protect its own commercial interests and to take actions that adversely affect the management of your Account and related performance. Regardless of whether the lender is Merrill, an Affiliate or a third-party lender, the lender’s lien is senior to any rights we may have on the assets in the Account. As such, the lender has the right to sell securities in the Account that serve as collateral, if needed. A collateral call could disrupt your selected Investment Manager’s investment strategy for the Account and, furthermore, neither you, we or the Investment Manager will be provided with prior notice of a liquidation of securities or transfer of interests in your pledged Account. Furthermore, neither you nor we are entitled to choose the securities which are to be liquidated or transferred by the lender. The costs associated with such a lending arrangement under a Lending Program are not included in the SPA Fee and, if the Lending Program is with an Affiliate, result in additional compensation to us, our Affiliate(s) and our Financial Advisors. The interest charges on any such margin loan or loan combined with the fees charged for SPA Services may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. You should consult with your own independent tax advisor in order to fully understand the tax implications associated with pledging your Account as loan collateral and the potential liquidation of pledged assets. TAX MATTERS You acknowledge that your Investment Manager may sell all or a portion of the securities in your Account, either initially or during the course of your participation in SPA. You are responsible for all tax liabilities arising from these transactions. We and your Financial Advisor will not offer tax advice to you on these or any other issues. You also are responsible for all tax liabilities and tax-return filing obligations arising from all transactions in your Account enrolled in the Program. We are not responsible for attempting to obtain any tax credit or similar item or preparing and filing any legal document on your behalf. You should review all disclosures you receive associated with the investments held in and transactions occurring within your Account with a qualified tax professional. We do not, and will not, offer tax advice to you and you need to rely on such qualified tax professional in all instances for tax advice. If you are an investor with special circumstances such as a non-U.S. resident or an entity sensitive to unrelated business taxable income, you should also discuss with your qualified tax professional the tax consequences of each investment held in your Account as there may be additional tax withholding, reporting and payment obligations which may result from such investments. Special tax rules may apply to the investments themselves which may result in unique tax consequences to you. In some circumstances, certain tax elections may be able to be made that will affect the tax consequences arising from such an investment. Certain investments (such as master limited partnerships) may result in tax consequences to investors that are subject to tax on unrelated business taxable income and you will be responsible for the reporting and filing of tax returns and the payment of the associated income tax resulting from such investments. You should be aware that tax consequences may arise when portfolio changes occur in your Account, such as rebalancing, liquidations and redemptions and as a result of any action undertaken as part of a Direct Indexing Strategy (as defined below). We specifically disclaim any undertaking of tax management of your Account or investments and assume no responsibility for any resulting tax consequences. Any requests to realize gains or losses with the Account must be made to the Investment Manager as it has full investment and trading authority respecting activity in the Account. Special Risks and Limitations Associated with Direct Indexing Strategies. You may elect a Strategy for your Account where an objective of the portfolio management investment approach undertaken by the Investment Manager is to opportunistically sell securities that have a loss and invest proceeds in strategy-aligned replacement securities or other tax loss harvesting approaches (a “Direct Indexing Strategy”). The Investment Manager’s investment decisions and related transaction orders for the Direct Indexing Strategy may include selling depreciated positions and seeking to recognize tax losses to offset your capital gains (and, possibly, ordinary income to a limited extent), recognizing capital gains to seek to offset any recognized losses, selling the highest cost securities first, seeking to avoid the wash sale rules and/or other tax harvesting actions. There are risks and limitations associated with Direct Indexing Strategies and these limitations may result in tax- inefficient trades and wash sales. You should consult your tax and/or legal advisor prior to enrolling in any Direct Indexing Strategy, as well as on an ongoing basis to determine whether the wash sale rules, the straddle rules, or other special tax rules could apply to your trading activity. Generally, under the wash sale rules, if you sell a security for a loss and you repurchase the same (or a substantially identical) security either 30 days before or 30 days after the date of sale, the loss 12 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure is disallowed. In addition, other tax treatment rules, such as the straddle rules, may disallow losses. There is little authority governing whether an ETF replacement security is “substantially identical” to another ETF security for purposes of the wash sale rules. As such, no assurances can be provided that if an Investment Manager chooses an ETF as a replacement security to the sold security, the replacement security will not be deemed “substantially identical” for purposes of the wash sale rules. It is important to note that Direct Indexing Strategies apply on a per-Account basis only and only to the Account that has selected the particular Direct Indexing Strategy. Please note, however, that the wash sale rules apply to securities transactions in not only that Account but also to securities transactions in all other accounts held by you, your spouse and certain entities controlled by you and your spouse. The accounts covered under the wash sale rules include all taxable accounts and retirement accounts held at Merrill or an Affiliate that are brokerage accounts and/or accounts enrolled in investment advisory programs, and all securities accounts of any type held with third parties in each case, held by you, your spouse and certain entities controlled by you and your spouse (collectively, “securities accounts”). The Direct Indexing Strategy will not take into account trading activity in any of these other securities accounts. The sale of a security for a loss in an Account enrolled in a Direct Indexing Strategy will not generate a loss for tax purposes if the security was part of a wash sale or straddle as a result of trading activity or securities in any other of your securities accounts. In addition, the purchase of a replacement security in an Account enrolled in a Direct Indexing Strategy may give rise to a wash sale with respect to a security or position in any of your securities accounts (including those of your spouse and certain of your spouse’s controlled entities). Similarly, other trades executed in any securities account may also result in a wash sale in the Account enrolled in a Direct Indexing Strategy. In applying a Direct Indexing Strategy to an Account that includes selling securities and investing in Strategy-aligned replacements, the performance of any replacement security selected will not be the same as that of the security sold and, in fact, the replacement security may perform worse than the security sold. Any tax-related benefits that result from a Direct Indexing Strategy may be negated or outweighed by investment losses and/or missed gains (realized and unrealized) that also may result. An Account that enrolls in a Direct Indexing Strategy will generally trade more frequently than an account which has not selected a Direct Indexing Strategy. There are implicit trading opportunity costs associated with the additional turnover which may affect the returns on your Account. Direct Indexing Strategies may not be appropriate for your financial situation. If you are taxed at lower aggregate marginal income tax rates, you may be less likely to benefit from the Direct Indexing Strategies than would an investor taxed at higher aggregate marginal income tax rates. Because you may use capital losses only to offset certain amounts of capital gains that you might have, and possibly, to a limited extent, ordinary income, if you have net capital losses in excess of the applicable threshold, you may not realize as many immediate tax benefits through the application of a Direct Indexing Strategy to your Account. It is your obligation to monitor transactions across all of your accounts to identify any wash sales or straddles and for all tax liabilities attributable to the disallowance of any losses pursuant to the wash sale rules or of any deferral under the straddle rules. Merrill cannot provide any assurances that losses will not be disallowed pursuant to the wash sale rules or deferred under the straddle rules. If you elect to enroll in a Direct Indexing Strategy, you should consider receiving trade-by-trade confirmations (rather than receiving trade confirmations on a periodic basis), monitoring those confirmations, and, to the extent any security is sold for a loss, refraining from acquiring the same (or a substantially identical) security in your Account or any of your securities accounts. Despite this, it is possible that you may still be subject to the wash sale or straddle rules in any given tax year. CUSTODIAL ARRANGEMENTS Generally, Merrill will act as the custodian for the assets held in your Account. Assets will be maintained in one or more central asset accounts established at Merrill through the applicable securities account. Pursuant to the Client Agreement, you have agreed to execute the applicable documentation for such accounts. In limited circumstances, upon your request and direction and with our consent, you may enter into arrangements for your assets in the Program to be maintained with (1) an Affiliated Custodian or (2) an Unrelated Custodian. Unless otherwise agreed with such custodian, you will pay a separate fee for these arrangements on terms agreed upon by you with such custodian. 13 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Our rights and authority respecting your assets enrolled in the Program, including as to transfers of assets held with the Affiliated Custodian or the Unrelated Custodian, are limited to those set forth in the Client Agreement, regardless of any separate agreements or arrangements you may have or may enter into with any such Custodian. We disclaim any broader rights that may be contained in your separate agreement with the Affiliated Custodian or Unrelated Custodian. You will be responsible for all fees and expenses charged by an Affiliated Custodian or an Unrelated Custodian subject to applicable law and the custodial arrangements you agree to. These fees and expenses are not covered by the SPA Fee. Cash held with an Affiliated Custodian or an Unrelated Custodian will not be subject to the same sweep arrangements you have with Merrill acting as the custodian, but we will include such cash positions in the value of your Account for the calculation of the SPA Fee. You are responsible for separately establishing appropriate sweep arrangements with the Affiliated Custodian or Unrelated Custodian. Assets held in Accounts with an Affiliated Custodian and the Unrelated Custodian are not subject to Merrill’s SIPC coverage. It is the responsibility of the Affiliated Custodian or an Unrelated Custodian to implement your proxy delivery instructions. Accounts that are custodied with an Affiliated Custodian or an Unrelated Custodian are not eligible to elect periodic trade confirmation delivery. You will be responsible for ensuring that we (and all vendors used by us) are provided with daily access to the Affiliated Custodian or Unrelated Custodian’s systems, transaction and account data and other information necessary to provide adequate account supervision, transaction, billing and other client reports and other necessary services to your Account. You understand that as a result of your use of a custodian other than Merrill, you may receive more limited information and reporting when we cannot obtain certain required information from the Affiliated Custodian or Unrelated Custodian. Furthermore, any performance and other reports we provide for your Account will be based upon information provided by the Affiliated Custodian or Unrelated Custodian, which we will use for purposes of calculating the SPA Fee. We are not responsible for verifying the accuracy of such information or any losses or errors by an Affiliated Custodian or Unrelated Custodian with respect to your Account. You have agreed to promptly notify your Investment Manager with respect to any additions or withdrawals of assets to your Account maintained at the Affiliated Custodian or Unrelated Custodian and have agreed that we will not be responsible or liable for any losses due to your failure to provide such prompt notification. Any assets held in your Account must be free from any lien, charge or other encumbrance (other than a lien, charge or other encumbrance in favor of us or our Affiliates). Such assets must remain so unless you notify us and we agree. You must notify us in writing prior to effecting loans secured by securities in your Account (including loans by our Affiliates) as described below (commonly referred to as “collateralizing”). You understand that we will not provide advice on or oversee any of your collateral arrangements. In the event of any conflict between the terms of the Client Agreement and your collateral arrangements, the terms of the Client Agreement will prevail. You must also disclose to any lender the terms of the Client Agreement. No specific securities in your Account must be held as collateral to secure your loan. You should be aware of the adverse effects of collateralizing Accounts, including, but not limited to, the fact that the lending institution may require additional collateral or liquidation of securities held in your Account to meet a call, as well as the related tax consequences. You must promptly notify us of any default or similar event under your collateral arrangements as defined in the respective collateral arrangements. TRADING IN SPA ACCOUNTS Your trades are generally placed by, and are the responsibility of, the Investment Manager, including any Related Manager. By executing an agreement with the Investment Manager and by executing the Client Agreement, you have granted the discretionary authority to the Investment Manager to determine (subject to your investment objectives and constraints) the securities to be bought or sold on your behalf, the amount of such securities, and the brokers or dealers to be used in such transactions. The Investment Manager you select is obligated, absent your direction to the contrary, to effect transactions with or through those brokers or dealers that, in the Investment Manager’s view, are capable of providing best price and execution of orders for your benefit. The Investment Manager has the authority to place orders for transactions with broker-dealers that it selects, including with Merrill or any of our Affiliates that act as a trade counterparty (an “Affiliated Trade Counterparty”) and with broker dealers that are not Merrill or one of its Affiliates (“Unaffiliated Trade Counterparty”). The Investment Manager is able to transact with Merrill or an Affiliated Trade Counterparty on a principal basis when permitted by law. They may place trades for purchases of securities in underwritten offerings with Merrill or any of our Affiliates or with an Unaffiliated 14 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Trade Counterparty under which certain underwriting compensation is earned by Merrill, BofAS or any of our other Affiliates or by the Unaffiliated Trade Counterparty. When these transactions are effected on a principal basis, we will receive additional compensation. When an Investment Manager places a trade order with Merrill or an Affiliated Trade Counterparty for the purchase or sale of fixed income or other securities where dealer spread charges are imposed, the dealer spread charges (that are part of the net price of the security) will be in addition to your SPA Fee. These dealer spread charges will not be listed in your trade confirmation or account statement; however, upon written request, we will undertake to obtain the amount of these charges for a given transaction in your Account. If the Investment Manager determines to execute a purchase or sale of any security for your Account through an Unaffiliated Trade Counterparty, any resulting execution charges (i.e., commissions, markups, markdowns, dealer spread charges) will be separately charged to that Account. A transaction that the Investment Manager has placed through an Unaffiliated Trade Counterparty for a particular Investment Manager Strategy is commonly referred to as a “step out” or “step out trade.” In selecting a firm to execute transactions and the markets in which the transactions will be executed, the Investment Manager is not obligated to solicit competitive bids for each transaction or seek the lowest available commission cost to you so long as it reasonably believes that the firm it selects can be expected to obtain a “best execution” market price on the particular “step out trade.” Each Investment Manager is responsible for ensuring that it complies with its own best execution obligations. Certain Investment Managers have historically executed all or a portion of their trades as “step outs.” Frequently, these trades have been for fixed income or other securities for which trading-related charges and costs (e.g., mark-up/downs, dealer spreads) are charged by the executing broker-dealer. These trading-related charges and costs are included in the net price of the security and are charges and costs that are in addition to your SPA Fee. You, rather than Merrill or the Investment Manager, will bear the cost of these trading-related charges and costs. See information in the section “Other Fees and Expenses.” In addition, these trading-related charges and costs will not be reflected as separate charges on your trade confirmations or account statements. We will undertake, at your written request, to obtain the amount of this remuneration for a given transaction in your Account. The Covered Strategies that we have identified as trading through an Unaffiliated Trade Counterparty, either on a regular or a limited basis, are designated in the “SPA Strategy Step Out Information Document.” Similarly, the “SPA Uncovered Investment Manager Strategy Step Out Information Document” contains step-out information on Strategies of investment managers retained by you outside of the SPA manager identification services and/or Strategies that are no longer on the Coverage List or are not available in MLIAP (collectively, “Uncovered Strategies”), These documents are accessible at ml.com/SMA and are available from your Financial Advisor. Information in these documents is based solely on the historical information that has been provided by the Investment Managers at their discretion, and we have not independently verified such information. We do not make any representation regarding the future trading practices of any Investment Manager for any Strategy. We recommend that before making a selection of a Strategy, you review the Investment Manager’s Form ADV, Part 2A brochure, which contains more detailed information about its brokerage practices. You should consider the costs of “step out trades. You will pay a SPA Manager Fee for the investment management and related services that the Investment Manager for the Strategy provides. The rates charged by Investment Managers vary among each other and among other Strategies. For trades in fixed income securities, whether executed as a “step out trade” or a trade with an Affiliated Trade Counterparty, you will pay the dealer spread charges associated with such trade. It is possible that the SPA Manager Fee rates for Strategies may be higher than other available Strategies. You could be deemed to be indirectly bearing the cost of the “step out trades” by virtue of any such higher charges. In addition, you will pay the same fee rate for a particular Strategy regardless of whether or not the Investment Manager executes “step out trades.” You should consider the use by the Investment Manager in executing “step out trades” when selecting a Strategy. The potential cost advantage associated with using Merrill to execute trades for your Account is expected to alter the way in which each Investment Manager satisfies its duty to seek best execution. That said, Investment Managers may utilize execution services of broker-dealers other than Merrill. In particular, BANA, a Related Manager, will select broker-dealers other than Merrill and the resulting transaction costs will be in addition to the SPA Fee. As of the date of the Brochure, BANA is not on the Coverage List for selection as an Investment Manager. We and our Affiliates will ordinarily act as agent in executing transactions on behalf of SPA Accounts. Principal transactions may also be effected for SPA Accounts under the appropriate circumstances as permitted by law. Principal 15 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure transactions may be subject to a dealer spread (i.e., the difference between the bid and the offer price), which would result in additional compensation or other benefit to us. Transactions in securities customarily traded in dealer markets (such as fixed-income or over-the-counter securities) that are purchased from or sold to broker-dealers other than us may include markups or markdowns by these firms. In accordance with the instructions of your Investment Manager and your authorization, our execution services (or those of an Affiliated Trade Counterparty) will generally be used for the purchase and sale of securities for a SPA Account, unless you designate another broker-dealer, or applicable law is to the contrary. However, in buying or selling certain securities (particularly those that customarily trade in “dealer markets”), we may, for legal or other reasons, cause such transactions to be effected through an Unaffiliated Trade Counterparty. When we select an Unaffiliated Trade Counterparty to execute transactions, we will consider various factors, such as the nature and quantity of the securities involved; the markets involved; the importance of speed, efficiency and confidentiality; the firm’s apparent knowledge of such markets and sources from or to whom particular securities might be purchased or sold; the reputation and perceived soundness of the broker-dealer; the ability and willingness of the broker-dealer to facilitate both purchases and sales of securities for client accounts by participating in such transactions for its own account; the firm’s clearance and settlement capabilities; and other factors relevant to the selection of a broker-dealer for the execution of your securities transactions. The SPA Fee does not cover transaction charges or other charges, including markups and markdowns, resulting from trades effected through us or with an Unaffiliated Trade Counterparty. In addition, the SPA Fee does not cover transaction and other charges incurred by registered and unregistered investment companies, including mutual funds, money market mutual funds, closed-end funds, ETFs and hedge funds, real estate investment trusts and other pooled investment vehicles (“Funds”) that might be held by you in SPA Accounts or that the Investment Manager may invest in. Purchases of securities from an underwriter or dealer in a distribution will be effected at the public offering price. Your transactions are effected by us on the instruction of your selected Investment Manager. Accordingly, it should be understood that, for any and all transactions effected by or through us in a SPA Account at the direction of your Investment Manager, we are acting exclusively as a broker-dealer in relation to such transactions. We and the Investment Managers may, but are not required to, aggregate orders for the sale or purchase of securities for your Account with orders for the same security for our other clients, proprietary accounts or the accounts of our employees and/or related persons, without your prior authorization. In such cases, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro rata share of any fees. For foreign ordinary security transactions executed outside the U.S., we may use the services of a foreign Unaffiliated Trade Counterparty (or its Affiliate). The foreign Unaffiliated Trade Counterparty (or its Affiliate). will handle the order and will assess trading-related charges and costs (i.e., commissions, mark-ups/downs, dealer spreads and other fees and charges) and, to the extent a foreign currency conversion transaction is required, it will be remunerated in the form of a dealer spread or a mark-up/down. These trading-related and currency conversion-related charges and costs are included in the net price of the security and are charges and costs that are in addition to your SPA Fee. In addition, these charges and costs will not be reflected as separate charges on your trade confirmations or account statements. We will undertake, at your written request, to obtain the amount of this remuneration for a given transaction in your Account. We and our Affiliates may effect agency-cross transactions in which we or one of our Affiliates acts as agent for the parties on both sides of the transactions involving SPA or other clients in accordance with applicable law. When effecting such crossing transactions, we or our Affiliates generally receive compensation (the amount of which varies) from each party to such transactions, which is in addition to the fees described herein. While such compensation, in theory, creates a conflicting division of loyalties and responsibilities, transactions involving SPA are directed by your Investment Manager, (which could be a Related Manager) and we will be acting solely as a broker-dealer in connection with such trades. PROXY VOTING AND OTHER LEGAL MATTERS Unless otherwise designated in the Client Agreement or other writing addressed to us (or another custodian you select), you direct your Investment Manager for each SPA Account to vote the proxies and receive other issuer-related material relating to the securities held in the SPA Account, and you represent in the Client Agreement that, under any applicable instruments or governing law, you are authorized to make such direction. To the extent that we are the custodian and 16 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure voting instructions are not received and as permitted by applicable law, we will comply with the rules and policies of the SEC and applicable self-regulatory organizations, consistent with our role as a non-discretionary custodian. As a broker- dealer, Merrill uses a third-party service provider for certain proxy-related functions, including processing and forwarding proxy and other issuer-related materials and receives amounts collected by the vendor for the costs of these services as permitted by applicable securities regulation. In addition, we do not advise or act for you regarding any legal matters, including bankruptcies and class actions, pertaining to the securities held in the SPA Account, nor will we be responsible for making any tax credit or similar claim or any legal filing (including, but not limited to proofs of claim) on your behalf. Unless otherwise agreed, we will send you any documents we receive for client distribution with regard to such matters. The Investment Manager is responsible for responding to corporate actions. THE SPA FEE We have set the maximum SPA Fee rate schedule (inclusive of any Legacy Elective Service as applicable) for the Program as set forth below. The SPA Fee rate schedule is subject to change. The SPA Fee rate is negotiable meaning you and your Financial Advisor may agree to a SPA Fee rate for an Account that is lower than the maximum rates listed in the schedule below. The extent to which you and your Financial Advisor agree to a lower rate is solely within your and your Financial Advisor’s discretion and is subject to our policies regarding the Program. You may accept or decline any proposed rate by your Financial Advisor as part of the negotiation process. Dollar Value of Assets in Each SPA Account Annual Equity/ Balanced/ Convertible/ REIT Maximum Fee Schedule Annual Fixed Income Maximum Fee Schedule Up to $4,999,999 1.50% 0.70% $5,000,000 – 9,999,999 1.00% 0.60% $10,000,000 – 14,999,999 0.85% 0.50% $15,000,000 – 19,999,999 0.75% 0.45% $20,000,000 – 24,999,999 0.70% 0.40% $25,000,000 – 49,999,999 0.60% 0.40% $50 million or greater Determined by Mutual Agreement Determined by Mutual Agreement For purposes of determining which maximum SPA Fee Rate applies to your Account, we will consider the aggregate value and composition of assets in your Account and in certain other of your Merrill accounts and those of your household. The SPA Fee rate that is applicable to your Account is the rate agreed upon between you and your Financial Advisor (the “SPA Fee Rate”). The SPA Fee is based on the dollar value of assets in each SPA Account and the agreed upon SPA Fee Rate. The SPA Fee Rate applicable to an Account will not change during a calendar quarter, and any decrease in the SPA Fee Rate will take effect at the beginning of the next calendar quarter. If you receive any of the separate services described here but determine not to proceed with the SPA Service, you are still responsible for paying us for such services on a separate basis under the then-current fee schedule for such service. Note that the SPA Fee does not cover the services of the Investment Manager for the Strategy in the Account. Merrill compensates your Financial Advisor on an ongoing basis derived from the SPA Fee Rate that applies to your Account. When considering whether to offer or agree to charge a lower SPA Fee Rate, a Financial Advisor typically will consider a number of factors, including the type and size of your Account, the breadth of our relationship with you, your engagement with the Financial Advisor, competitive considerations and how Merrill compensates the Financial Advisor. Because the amount of compensation paid to your Financial Advisor is based on the SPA Fee Rate for your Account, your Financial Advisor has a financial interest in that Rate. In general, Financial Advisors receive “production credits” toward their compensation formula based on the amount of the SPA Fee that you pay for your Account. Merrill’s policies result in Financial Advisors receiving fewer production credits (by 5% or more) if the assets in the Account are less than $5 million and/or if the weighted average of the SPA Fee Rates for your and your designated household members’ Accounts is lower than the rate levels for specific wealth asset tiers that Merrill establishes. Merrill and Financial Advisors have a conflict 17 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure of interest based on this structure because the Financial Advisor is incentivized not to offer a SPA Fee Rate below such rate levels and to maintain a certain level of assets in the Account since that would reduce their compensation earned. For more information on Financial Advisor compensation and conflicts of interest, see “Compensation, Conflicts of Interest and Material Relationships—Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel.” Merrill typically pays a portion of the SPA Fee it receives from each client to the Financial Advisor for that client. The exact portion paid by Merrill to the Financial Advisor varies among the Financial Advisors and depends on factors such as each Financial Advisor’s overall annual revenue production. The amount received by a Financial Advisor as a result of a client’s participation in this Program may be more than the Financial Advisor would receive if the client participated in certain other of our investment advisory programs, or paid separately for investment advice, brokerage and other services covered by the SPA Fee. In those circumstances, the Financial Advisor has an incentive to recommend an investment advisory program that would pay higher compensation. We offer similar programs and/or investment strategies in different sales channels and at different fee levels. The SPA Fee paid by a client may be higher or lower than the fees other clients pay in the Program or another investment advisory program and/or the cost of similar services offered through other financial firms. See “Ability to Obtain Certain Services Separately and for Different Fees.” The full amount of the SPA Fee payable under the Client Agreement will be charged in accordance with the terms of the Client Agreement, regardless of the amount of transactions your Investment Manager chooses to effect in your Account. The SPA Fee will not be adjusted for your use of, or failure to use, the SPA Services, including (1) the level of trade activity; (2) your choice of a Strategy where the Investment Manager engages in trading activity away from us for certain security types; (3) your decision to custody your assets at a financial institution other than Merrill. You should note that any security purchased prior to enrolling in SPA and subsequently transferred into a SPA Account will be subject to the SPA Fee. This means that you may pay both an up-front commission (when the security was purchased prior to enrolling in SPA) as well as the SPA Fee (once enrolled in SPA) in connection with the purchase of the same security on the transferred security. Upon request, and at no charge, we will provide additional detailed information regarding your SPA Fee. Please contact your Financial Advisor if you would like to receive this more detailed SPA Fee information. Investment Manager Fee. You will be charged the advisory fee that you have agreed to pay the Investment Manager (“Investment Manager Fee”) for the Strategy you select. The maximum Investment Manager Fee will vary even for comparable strategies, depending on the Strategy. Certain Strategies have a lower rate than others. The Profile for the Strategy indicates the maximum Investment Manager Fee rate. Recommending Strategies that have lower Investment Manager Rates than others present the Financial Advisor with an opportunity to negotiate a higher SPA Fee Rate than might otherwise be the case. The opportunity to negotiate a higher SPA Fee Rate provides the Financial Advisor with a financial incentive to recommend Strategies with lower Investment Manager Fees over other Strategies. The ability to negotiate a higher SPA Fee Rate benefits Merrill as well as the Financial Advisor since Merrill retains a certain percentage of the SPA Fee. For more information, see “Compensation, Conflicts of Interest and Material Relationships—Benefits to Us and Your Financial Advisor from Your Enrollment in the Program.” Calculation of Account Fees; Ineligible Assets. The SPA Fee is payable quarterly in advance based on the estimated value of your Account’s assets as of the last business day of the previous calendar quarter, as determined by us or another custodian holding such assets. Merrill will use a variety of pricing sources in calculating the value of such assets in your Account, including Affiliates. All assets (including cash balances swept under the Cash Sweep Program to a deposit account or a sweep money market fund, depending on your account type and any cash alternatives including money market funds selected by your Investment Manager) are included in the value of your Account for the calculation of the SPA Fee, unless we have deemed that any assets are ineligible for the Program, in which case, such assets would not ultimately be subject to the SPA Fee. Depending on when such ineligible assets are contributed to, or liquidated or transferred from, the Account, such assets will be either: (i) excluded from the value of your Account for the calculation of the SPA Fee or (ii) included in the Account’s value for that calculation but you will receive a subsequent adjustment for any SPA Fee charged for holding those ineligible assets. In addition, any money market funds that are not held through any relevant cash sweep vehicle 18 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure applicable to your Account or invested in by the Investment Manager as part of its strategy are considered ineligible assets, and, therefore, are not ultimately subject to the SPA Fee and could subject your Account to termination if not timely liquidated or transferred out of your Account. For the avoidance of doubt, any money market funds that are held through any cash sweep vehicle applicable to your Account, are eligible assets and, therefore, are subject to the SPA Fee. In certain limited circumstances, where an Investment Manager purchases or holds contributed mutual fund shares (whether money market funds or otherwise) in your Account as part of its Strategy, such shares would be subject to the SPA Fee. The SPA Fee for your Account does not cover the services of Investment Managers, and while Merrill may not consider all Account assets for purposes of your SPA Fee, your Investment Manager may do so for its fee. For the initial quarter, the SPA Fee is calculated proportionally based upon the number of days left in such quarter from the date our advisory relationship begins, which occurs on the later of the date of acceptance of the signed Client Agreement by us or the date you have contributed assets in the Account. The initial SPA Fee is based on the estimated value of the Account as of the close of business on the day preceding notification to the Investment Manager to begin managing the SPA Account. You may elect to have SPA Fee paid by debit from the SPA Account, debit from an alternate Merrill account, or through the payment of an invoice. The account value used for the calculation of fees may differ from that shown on your monthly securities account statement and performance report due to a variety of factors, including trade date or settlement date accounting, the treatment of accrued income, round lot valuation and other considerations. Further, it should be noted that the valuation of client securities reported in the performance report may also be subject to occasional re-pricing in reasonable and appropriate circumstances, but such re-pricing will not affect, or result in the adjustment of, previously calculated SPA Fee. Deduction of Account Fees. As set forth in the Client Agreement, you may authorize us to deduct the SPA Fee from the Account. We also may, for your convenience and if so agreed between you and your Investment Manager, deduct from the Account the Investment Manager Fee. We will remit the Investment Manager Fee to the Investment Manager. The Investment Manager Fee will be deducted in addition to, but after, the SPA Fee payable to Merrill. To the extent permitted by law, all assets in the Account or other assets held by Merrill or any Affiliate for you will be subject to a lien for the discharge of your obligation to make timely payment to us, and we may sell assets in the Account to satisfy this lien. Other Fees and Expenses. We want you to know that the SPA Fee does not cover: • Investment Management fees you pay to your selected Investment Manager (and set by such manager). • Transaction charges (i.e., commissions, sales charges, markups, markdowns) on trades effected through or with an Unaffiliated Trade Counterparty (including on fixed-income or over-the- counter transactions in which we act as agent). • Dealer spread charges, markups or markdowns charged by an Unaffiliated Trade Counterparty (including on fixed- income or over-the-counter transactions in which we act as agent). • Dealer spread charges, markups and markdowns imposed by Affiliated Trade Counterparty for purchase and sale of fixed income securities and other securities where a dealer spread charge is imposed. • Underwriting discounts, selling concessions or other transaction charges with respect to any new issue securities offering that we or our Affiliate may receive in connection with the offering, a portion of which may be used to pay your financial advisor. • Margin interest and fees and charges, charged by us or third parties, imposed for any margin strategy or for any securities that are shorted as part of an options strategy and that are in limited supply (i.e., the shorted securities are “in demand”), a portion of which may be used to pay your Financial Advisor. • Transfer taxes. • Fees charged by us, our affiliates or unaffiliated third parties in connection with short-sale transactions. • Fees, expenses and charges charged by Funds or by the managers or sponsors of Funds. Exchange, alternative trading system fees, required SEC fees or similar fees charged by third parties, including issuers. 19 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure • Electronic fund, wire and other account transfer fees, including any fees or markups charged for foreign currency exchange or conversions relating to transfers or wires to or from your Account, a portion of which may be used to compensate your Financial Advisor. • Custodial fees and expenses associated with your use of an Affiliated Custodian or an Unrelated Custodian. • Commissions and charges for transactions in foreign ordinary securities and dealer spread charges, mark-ups or mark-downs in connection with foreign currency conversions, including transactions in foreign ordinary shares or ADRs or foreign currency wire transfers either in or out of your Account. • Any other charges imposed by law or otherwise agreed to with regard to your Account including those charges payable to Merrill and/or third parties as described in this Brochure. The SPA Fee does not include certain fees and charges relating to transfer and termination fees, cash management services, money transfers, wire transfers and foreign exchange conversion fees and costs and certain corporate action fees. Certain of these costs are detailed on the Merrill Schedule of Miscellaneous Account and Service Fees and the Explanation of Fees document (as to foreign conversion costs), available at ml.com/relationships. Please see the securities account agreement and account enrollment documents relating to brokerage services and related transactions and account fees for your Merrill account. If you have any questions about any charges or fees applicable to your Account, please consult with your Financial Advisor. If your SPA Account holds a Fund security or the Strategy invests in a money market fund, as with any Fund investment, you will bear your proportionate share of such Fund’s fees and expenses including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. In addition, any Fund contingent deferred sales charge, redemption or other fees imposed by a Fund manager as a result of your redeeming the Fund (e.g., to invest in a particular Program Strategy) will be separate from, and in addition to, the SPA Fee. The SPA Fee does not cover or offset any fees and expenses that any Fund incurs for transactions occurring within the Fund itself, including commissions and other transaction-related charges incurred by the Fund, even if we or any Affiliate effect these transactions for the Fund or provide services to the Fund. All of these fees and costs may be material. If your Investment Manager determines to execute a purchase or sale of any security for your Account through a broker or dealer other than us, any resulting execution charges will be separately charged to your Account and are in addition to the SPA Fee. As noted above, on trades effected through or with us by the Investment Manager, we will not charge a commission on agency transactions. Principal transactions effected with us, as permitted by law, will be subject to a dealer spread (i.e., the difference between the bid and the offer price), which results in additional compensation or other benefit to us. The SPA Fee does not cover charges (generally the dealer spread) imposed by an Unaffiliated Trade Counterparty on step out trades as dealers, including where MLPF&S or its Affiliates act as agent in executing fixed income or over-the-counter transactions. Clients for which an Investment Manager places any fixed income, foreign or securities trades on an over- the-counter basis through an Unaffiliated Trade Counterparty will not receive a discount from, or credit against, the SPA Fee for any markup or mark-down imposed by the executing Unaffiliated Trade Counterparty. Neither the SPA Fee nor the Investment Manager Fee covers these transaction execution costs. See “Trading in SPA Accounts” for more information on step out trades. Options and Margin Strategies. SPA Accounts are generally not permitted to effect margin transactions. However, when so permitted, the margin interest you pay on debit balances is not included in the SPA Fee. Financial Advisors will receive additional compensation in such circumstances, unless waived, as well as, in limited cases, from rights or tender offers. If your Investment Manager utilizes Options and Margin Strategies, you will incur costs in addition to the SPA Fee. Although you will be paid interest on the short market value of any securities sold short in your Account, we will also benefit from these short sale positions. The rate of interest paid to you will be determined by Merrill in its sole discretion and will reflect the retention of compensation by us. In addition, you will be charged fees, as reflected on your Account statements, for any securities that we deem to be “in demand” either at the time your Investment Manager sells such securities short or at any time before the short position is “closed out” by your Investment Manager. Investment Managers that sell securities short will use cash generated from short sales to purchase additional securities, (i.e., leverage). If margin is used by your Investment Manager or if adverse market conditions trigger a margin call, you will pay interest pursuant to the Margin Agreement. 20 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Loans and Collateral. If your Account assets are “pledged” or used as collateral, with our consent, in connection with loans obtained through a Lending Program, the costs associated with such a lending arrangement under a Lending Program are not included in the SPA Fees and results in additional compensation to us, our Affiliate(s) and our Financial Advisors. Cash Assets. The SPA Fee will be applied to any cash and eligible cash alternatives held within your Account. You will experience negative performance on the cash asset holdings in your Account if the fee charged on your cash and any cash alternatives is higher than the return you receive on any cash asset holdings. The SPA Fee is in addition to other compensation that we and our Affiliates earn on cash that is held for investment purposes and on cash held as part of a cash asset allocation and swept to a cash sweep vehicle in accordance with the Cash Sweep Program. For more information about the Cash Sweep Program, including compensation and benefits we and our Affiliates receive, see “Funding and Operation of SPA Accounts—Cash Balances and the Cash Sweep Program” and “Participation or Interest in Client Transactions—Cash Balances and the Cash Sweep Program” for more information. ABILITY TO OBTAIN CERTAIN SERVICES SEPARATELY AND FOR DIFFERENT FEES As noted above, you are not obligated to implement any of the recommendations provided through SPA or to trade through SPA. You may be able to obtain some or all of the types of services available through SPA from Merrill and its Affiliates, on a separate or combined basis, subject to certain restrictions, including the type of account for which you are seeking these types of services. Depending upon the factors below, SPA may cost you more or less than purchasing the SPA Services separately. You may also be able to obtain some or all of the types of SPA Services available through SPA from other firms, and account fees may be higher or lower than the fees charged by other firms for comparable services. It is your responsibility to review the other services or investments available through us and our Affiliates with your Financial Advisor to determine which may be most appropriate for you. In comparing the account types and programs and their relative costs, you should consider various factors, including, but not limited to: • Your preference for an advisory or brokerage relationship. • Your preference for a discretionary or a non-discretionary relationship. • Your preference for a fee-based or commission-based relationship. • Your preference for access to a dedicated Financial Advisor. • The types of investment vehicles and solutions that are available in each program or service and their costs. • How much trading activity you expect to take place in your Account. • How much of your assets you expect to be allocated to cash. • The frequency and type of client-profiling reports, performance reporting and account reviews that are available in each program or service. • The scope of ancillary services that may be available to you in a brokerage account, but that are not available in an advisory program. We have provided you with materials that help to explain the various platforms and programs we offer, including the Form CRS and the Summary of Programs and Services, both of which are available at ml.com/relationships or from your Financial Advisor upon request. Merrill makes available other investment advisory programs that provide a client with the ability to receive certain investment advisory services directly from an investment manager under a separate agreement as well as certain limited investment advisory services from Merrill as described in the applicable program brochures. By enrolling into MLIAP and selecting the Premium Access Strategy (“PAS”) option, clients will receive access to discretionary management services and investment strategies of a third-party or affiliated investment manager (a “PAS manager”) pursuant to a separate contract with the PAS manager. Additionally, if a SPA Strategy becomes available in PAS, the SPA Strategy will be closed to new investors. In PAS, the client will pay Merrill an asset-based fee based on the value of the assets enrolled in the account and the Merrill fee rate, a rate negotiated by the client and the Financial Advisor, subject to a maximum rate of 1.75%. The client and the PAS manager also negotiate the PAS manager fee rate as part of the client’s separate contract with the PAS manager. Certain Investment Managers that participate in the SPA program also provide managed investment strategies in MLIAP. 21 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure BANA, our Affiliate, makes available certain of its managed strategies through MLIAP as PAS strategies to Accounts and to TMA Accounts enrolled in MLIAP. These strategies may also be available directly through BANA outside of MLIAP, including though the Select Portfolio Solutions program offered by BANA to its clients for which a Merrill Affiliate acts as an investment adviser. The fee schedules applicable to MLIAP TMA clients and clients with accounts directly through BANA are different from that offered in SPA and can be lower than the SPA Fee Rate negotiated with your Financial Advisor. In certain circumstances, Merrill makes available the Merrill Lynch Managed Account Service program (“MAS”), a dual contract program which is designed to accommodate a client’s selection of a third-party investment manager that is not currently available in other Merrill investment advisory programs. Under this program, Merrill makes the investment strategy available on an exception basis where the client or the Financial Advisor has a pre-existing relationship with the MAS manager prior to establishing an account relationship with Merrill. There are important differences among this Program, MLIAP, MAS and a BANA account relationship in terms of the involvement of your Financial Advisor in providing ongoing advice, the services, structure and administration, the depth of research conducted on the Investment Managers available in the programs and the applicable fees. You may request a copy of the ADV program brochures or BANA account materials for these programs by contacting your Financial Advisor. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Client Eligibility. Merrill requires that all clients who wish to enroll in the Program enter into the Client Agreement. The Client Agreement sets forth the terms and conditions that govern the handling of the client’s Account and the investment advisory relationship between the client and Merrill. A separate account is required for each SPA Account. In addition, clients enter into separate agreements with the selected Investment Manager, which sets forth the terms and conditions that govern the management of the client’s Account by the Investment Manager. Merrill and/or the Investment Manager may each decline to accept a particular client or account in the Program at any time and for any reason at their sole discretion. Investors eligible to participate in SPA include, but are not limited to, individuals, trust and estates (to the extent allowed by state law), charitable organizations, banks, corporations, or such other participants as we determine in our discretion and in accordance with applicable law. Account Minimums. The minimum account size for a SPA Account generally is $2 million, but we, in our discretion, may accept accounts with less than $2 million. Certain Strategies require minimum investment amounts as reflected in the applicable Profile or other disclosure document. You may fund your Account with cash and/or securities acceptable to us. When funding an Account with securities (or otherwise transferring securities into an Account), however, you should bear in mind that your Investment Manager may decide to sell all or a substantial portion of such securities and that you will be responsible for any tax or other liabilities (such as CDSC on certain classes of mutual fund shares) resulting from such transactions. Retirement Accounts. SPA has been generally closed to new enrollments by Retirement Accounts. If you are an existing Retirement Account client, you should understand that the SPA Services, particularly, the services and related materials of the manager identification services and the performance report (including IPR, where applicable), are provided in order to assist plan fiduciaries as they carry out their investment-related responsibilities and are not intended to be a primary basis for decisions related to your Account. Moreover, these services should not substitute for, or diminish the careful deliberation and determination of, those plan fiduciaries, after appropriate consultation with other professional advisers and the review of relevant plan documentation. PORTFOLIO MANAGER SELECTION AND EVALUATION REVIEW OF COVERED STRATEGIES AND MANAGER IDENTIFICATION SERVICES The SPA service assists you with the identification and selection of Investment Managers that may be appropriate based on the criteria you provide (including financial goals and needs) and based on the information obtained from the Investment Managers and/or from Investment Manager databases. We seek to provide clients with access to professional investment advice and to make available a choice of various investment styles and corresponding risk levels. As a general matter, we decide whether to include particular Strategies in SPA (or to remove them from SPA) based on a variety of 22 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure factors, including client needs, investment styles available in the marketplace, platform capacity, client demand and the outcome of certain reviews conducted by or under the auspices of Merrill, including through our Chief Investment Office (“CIO”). Review and Selection of Investment Managers. Initial and periodic reviews of Strategies available for investment in SPA on the Coverage List are performed by product teams through an internal business review. In addition, for those Strategies, we have in place an investment review conducted by or under the auspices of personnel of the CIO, referred to as the “CIO Review Process.” The CIO Review Process consists of proprietary processes conducted by the CIO and those processes and reviews provided by third-party reviewers that we have engaged for this purpose. The third-party reviewer services are generally consistent with the multi-factor processes that the CIO deploys but they are not identical. We, through the CIO, have reviewed such third-party reviewers’ processes and believe they are reasonable and appropriate in light of the objectives of the Program. Once we identify a need for a particular investment management strategy, we employ a multi-factor process to review appropriate Strategies to meet this need. These factors include but are not limited to organizational structure and stability of a Strategy; adherence to investment style; evaluation of risk and volatility; investment professional and strategy resources; investment philosophy and process; portfolio construction; performance; and operating and administrative capability. Based on these factors and using the information collected, the CIO Review Process involves quantitative and qualitative analysis, some of which may be subjective. Generally no single factor will be determinative. There is no assurance that the CIO Review Process or our internal reviews will identify the best performing Strategies. Please note that there may be particular Strategies that are not reviewed under the CIO Review Process. Our reviews may involve in-person visits, telephone conference calls, reviews of performance, and updates of certain Investment Manager documents and information. We may also conduct periodic analysis of composite performance to determine whether that performance generally appears to be consistent with that of the Investment Manager. We do not perform audits of Investment Managers to verify past performance information that the Investment Managers provide to us. For each Investment Manager, we will periodically evaluate factors related to the Investment Manager and the Strategy investments, that we deem appropriate. In addition, we may initiate reviews based on various factors determined by us and the CIO to be appropriate, including the level of assets of the Investment Manager Strategy in client accounts at Merrill or an Affiliate, the number or percentage of Merrill or an Affiliate, clients in the Strategy and the asset class involved. If we identify concerns regarding a Strategy that we find significant or important, we may choose not to accept any new investments in that Strategy. A drift or variation of the style of management of a particular Strategy from the stated style does not require a removal from our Program offering. Merrill retains the decision-making authority to add or remove a Strategy from the Program, regardless of, or in light of the results of, any review conducted, including through the CIO Review Process. Our review, including through the CIO Review Process, of Investment Managers and their Strategies does not substitute for your ongoing monitoring of your Account and the performance of your investments. Please see the section “Client Information Provided to Portfolio Managers” for additional information. Strategy Construction. Strategies are generally organized according to a shared characteristic such as asset class or investment style. The Investment Manager will construct the particular investment strategy and select the securities. They also set the allocations or allocation ranges. Please refer to the Strategy Profile for additional information about the Strategy or the Investment Manager, including further details with respect to the strategy description, portfolio construction and due diligence. Profiles for Strategies and other Information. We will generally provide you with important information about each Strategy available in the Program through a document known as a “Profile.” The Profile will describe the relevant objectives, styles and risks of the particular strategy. It will also describe the roles of the Investment Manager in implementing the Strategy. We prepare the Profiles from information provided by the Investment Managers. Each such Manager may use different methodologies to select and aggregate accounts for performance reporting purposes as well as different calculation approaches for composite performance results. We make no claim that the Profile performance information has been calculated according to any industry standards. The investment Manager has the obligation to establish and maintain each Strategy in the manner generally described in the then-current Profile and to provide us 23 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure notice on a timely basis of any changes made. We cannot guarantee the accuracy or consistency of the information contained in the Profiles but we obtain periodic confirmations from the relevant Investment Managers to help us confirm they continue to be materially accurate and complete. We make available guidance to our Financial Advisors through regular or ad hoc internal publications, including those from the CIO, that reflect our internal opinions and views with respect to a Strategy. The Financial Advisors are not obligated in all circumstances to take action with respect to any such determination and have the ability to decide not to use or follow this additional guidance and to make independent recommendations. Scope Of Obligations Respecting Manager Identification Services. We will provide ongoing due diligence on an Investment Manager or Strategy from the Coverage List, or if the Strategy is available in the MLIAP at the time of your enrollment in SPA. If an Investment Manager or Strategy is removed from the Coverage List, we will no longer perform ongoing due diligence. We do not perform due diligence on any other strategy or Investment Manager other than those on the Coverage List or those that are available in the MLIAP. SCOPE OF OBLIGATIONS RESPECTING UNCOVERED STRATEGIES We make no representation concerning Uncovered Strategies. To the extent a Related Manager is on the Coverage List but is not included in the SPA manager identification services, such Related Manager would not be considered an Uncovered Investment Manager. We do not provide due diligence with respect to Strategies of Uncovered Investment Managers. Similarly, we make no independent determination that any such Investment Manager and its management philosophy are compatible with your investment objectives. As a result, we are not responsible for services rendered, for information provided, or for any recommendations made by an Investment Manager you select outside of the Manager Identification Service. We will generally not reduce the SPA Fee even if you do not want Manager Identification Services. You assume responsibility for monitoring the Uncovered Investment Manager’s performance. We will not: • Perform any ongoing due diligence review with respect to the Uncovered Investment Manager. • Make any representation concerning the Uncovered Investment Manager’s abilities or qualifications as an investment adviser. • Bear responsibility for the services rendered, for information provided, or for any recommendations made by the Uncovered Investment Manager with respect to the Account. • Endorse, recommend or otherwise suggest that the Uncovered Investment Manager will make suitable investment decisions for you. • Undertake to investigate or monitor the suitability of the Uncovered Investment Manager’s investment decisions. We strongly encourage you to contact your Uncovered Investment Manager on a periodic basis to: • Discuss your Account and its investment performance. • Review the Uncovered Investment Manager’s philosophy and style of management so that you may determine the ongoing compatibility of your Investment Manager to your level of risk tolerance. • Discuss any restrictions you wish to impose or modify on your Account. • Request information regarding conflicts of interest between you and the Uncovered Investment Manager which we, our affiliates and your Financial Advisor may not be aware of and are under no obligation to investigate. • Receive a current copy of the Uncovered Investment Manager’s Form ADV filing and/or brochure for review. We also suggest that you periodically check the registration status and other information regarding your Uncovered Investment Manager, including disciplinary events, at the SEC’s website: www.adviserinfo.sec.gov. ADVISORY SERVICES PROVIDED BY MERRILL AND CERTAIN AFFILIATES Investment Managers, which include Related Managers, are exclusively responsible for the management of client assets as described in the section “Services, Fees and Compensation.” Merrill acts as the wrap fee program sponsor, as described in this Brochure. Merrill receives the entire SPA Fee as described in this Brochure. The Investment Manager Fee is a separate charge from (and in addition to) the SPA Fee. We do not retain any portion of the Investment Manager Fee. 24 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure INVESTMENT RISK Set forth below is a summary description of material risks related to the SPA Services and investment strategies and products that have significant or unusual risks. The information provided below is meant to summarize certain risks and is not inclusive of each and every potential risk associated with each investment type or applicable to a particular Account. Therefore, you should not rely solely on the descriptions provided below and are urged to speak with your Financial Advisor and the Investment Manager and ask questions regarding risk factors applicable to a particular Strategy, read all Strategy-specific risk disclosures and determine whether a particular Strategy is suitable for your account in light of your specific circumstances, investment objectives and financial situation. General. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed, and the value of your assets will fluctuate due to market conditions and other factors. Investments made and the actions taken respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics, terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. You should review the offering materials and other disclosure available for each relevant investment security or transaction to get an appreciation of its associated risks and fees. Strategies that consist of equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain Strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. You should review the offering materials and other disclosure available for each relevant investment security or transaction to get an appreciation of its associated risks and fees. You are assuming the risks involved with investing in securities and other investment products, and you could lose all or a portion of the amount you hold in the Program. You should understand: • Investment performance can never be predicted or guaranteed. • The values of your Accounts will fluctuate due to market conditions, manager performance and other factors. • There is no assurance that the performance results of any benchmark or index used in connection with SPA, including those shown on performance reports or our other reports, can be attained. • All or a portion of your securities may be sold either at the initiation of or during the course of the management of your Accounts. You are responsible for all the tax liabilities arising from these transactions and are encouraged to seek the advice of qualified tax professionals. 25 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure • The purchase and sale of United States (U.S.) securities may have additional adverse tax consequences and risks if you are not a resident of the U.S. Risks of the Strategy. By deciding to allow your Investment Manager to manage your assets in the Account in accordance with the selected Strategy, you assume the risks associated with the Investment Manager’s investment decisions. Accordingly, if your Investment Manager assembles a concentrated position in the Account, you assume the risk of a substantial loss in value to the entire Account if there is a decline in the concentrated position or industry sector. Similarly, if your Investment Manager effects trades in securities that we do not follow or for which we have a contrary recommendation, you assume the risk associated with this activity. Market movements, the investment decisions of your Investment Manager, and other factors may result in significant differences between the performance of Account assets and any investment objectives made known to us. You acknowledge that the investments made and the actions taken for your Account will be subject to various market, liquidity, currency, economic and political risks, and may decline in value. You further acknowledge that we do not assume responsibility for or endorse the investment decisions made by your Investment Manager, which may involve additional and significant risks. If your Investment Manager chooses to make use of margin to effect transactions in an Account, you assume the risk associated with margin transactions, including that losses in the value of an asset purchased on margin are magnified as a result of the use of borrowed money. Generally, we believe that these investment styles add risk to a portfolio that you should not assume unless you are prepared to experience significant losses in the value of your Account. Ultimately, as between you and us, you bear the risk of all of these decisions, including: • You can lose more funds than amounts deposited in margin accounts. • We can force the sale of securities or other assets in your Merrill account(s). • We can sell your securities and other assets without contacting you. • You are not entitled to choose which securities or other assets in the Account are to be liquidated or sold to meet margin calls. • We can increase our “house” maintenance margin requirements at any time without advance written notice. • You are not entitled to an extension of time on a margin call. • If a margin call cannot be fully satisfied from assets in your Account or other assets at Merrill, you will remain liable for the outstanding debt. If your Investment Manager writes uncovered options in your selected Strategy, you assume additional risk, including: • You will be exposed to potentially significant losses. • If your Investment Manager writes an uncovered call option, if the value of the underlying instrument increases above the exercise price, you can incur large and unlimited losses until the option expires or other option contract remedies. • If your Investment Manager writes an uncovered put option, you bear the risk of loss if the value of the underlying instrument declines below the exercise price. • If your Investment Manager writes combination or straddle options (where a put and a call option are written on the same underlying instrument), the potential risk of loss is unlimited. • If a secondary market in options were to become unavailable, your Investment Manager could not engage in a closing transaction and you would remain obligated until expiration or assignment. • In accordance with the option account agreement, if you do not meet applicable margin payment requirements, we may liquidate stock, options or other positions in the Account, with little or no prior notice to you. Please note that short selling stock has similar risks as those described above regarding writing uncovered call options and you will assume similar risks of loss. The Investment Manager for the strategy in our Account can sell all or a portion of the securities in your Account, either initially or during the course of your enrollment in the Strategy. You are responsible for all tax liabilities arising from these transactions. We and your Financial Advisor will not offer tax advice to you on these or other issues. 26 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Information and Cybersecurity Risks. With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly. BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, Investment Managers, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents suffered by BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents and well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we or our service providers, will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (“AI”) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory, and operational reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. ESG-themed Strategies. There are an increasing number of products and services that purport to offer environmental, social, and governance (“ESG”) or sustainable strategies (“ESG Strategies”). The variability and imprecision of industry 27 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure ESG definitions and terms can create confusion. Investment Managers and product sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. Merrill and its Affiliates generally do not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the Investment Manager) other than as part of the CIO Review Process. You should review the offering materials and Profiles to gain an understanding of how these managers and product sponsors describe their investment approach. ESG Strategies can limit the types and number of investment opportunities and, as a result, could underperform other Strategies that do not have an ESG or sustainable focus. Certain Strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by an Investment Manager will align with your ESG-related beliefs or values. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the Investment Manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities that may be available to clients that do not choose similar restrictions and, as a result, investment performance could suffer. On the other hand, category restrictions that aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category may not exclude all companies with any tie or revenue derived from such restricted category and require assumptions, opinions and the subjective judgment of the data provider that might not reflect your ESG-related views or values. If you hold an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event. When evaluating investments for an ESG Strategy, an Investment Manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment an investment’s ESG or sustainable attributes. Merrill does not guarantee or validate any third-party data, ratings, screenings or processes. Moreover, the screenings and processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in a SPA Account holding investments in companies that derive revenue from the restricted category. TAILORED INVESTMENT ADVICE You will enter into a separate agreement with your selected Investment Manager for the management of your assets. You may impose reasonable investment restrictions on your Account but you must communicate such restrictions to your Investment Manager. Merrill acts as the wrap fee program sponsor and also acts as the portfolio manager in other wrap fee programs sponsored by us. We receive the SPA Fee as described in this Brochure. Your Investment Manager charges a separate management fee for services. We also act as a portfolio manager in certain investment advisory programs which are not wrap fee programs but are otherwise similar to the program described in this Brochure. PERFORMANCE-BASED FEES Merrill does not charge performance-based fees. METHODS OF ANALYSIS We make available to Financial Advisors various resources, including securities research and guidance prepared by BofA Global Research, investment guidance and management research and publications from the CIO covering macroeconomic and market events and specific Strategies, information and assistance from other Merrill internal specialists and support teams and information from selected third-party research providers and other resources. We and the Financial Advisor, as 28 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure the case may be, can use various securities analysis methods, including fundamental, technical, quantitative and economic analyses, and can reference primary source materials, including company management contacts, company releases, financial and trade publications, corporate rating services, annual reports and filings with governmental agencies and research reports and market commentary issued by investment firms that are not affiliated with us. VOTING CLIENT SECURITIES As described in the section “Proxy Voting and Other Legal Matters”, unless otherwise designated in the Client Agreement or other writing addressed to us or another custodian you select, you direct your Investment Manager for each SPA Account to vote the proxies relating to the securities held in the SPA Account. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS As part of the enrollment process into SPA, you are asked to complete a Profiling Questionnaire that elicits information about your financial circumstances, investment objectives, risk tolerance and other relevant information relating to your Account. The information in the Profiling Questionnaire is used by us to make manager recommendations and may be provided to your Investment Manager. You are obligated to notify your Financial Advisor promptly of any material change in financial circumstances, investment objectives or investment restrictions (if any) that may affect the services your Financial Advisor provides to the Account in SPA. You are notified periodically to emphasize the need for you to report such information. The management of your Account is the responsibility of your selected Investment Manager. Accordingly, you must also provide any such updated information directly to your Investment Managers, and neither Merrill nor our Financial Advisors have any obligation to communicate such information to your Investment Manager. CLIENT CONTACT WITH PORTFOLIO MANAGERS We do not place any restrictions on your ability to contact and consult with your Investment Manager. Under SPA, you enter into a separate agreement with your Investment Manager and that agreement will discuss your ability to contact your Investment Manager. ADDITIONAL INFORMATION DISCIPLINARY INFORMATION The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill Lynch’s Form ADV at adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the MLBD Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over- exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and- desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. 29 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’s remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and- desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the U.S., Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and, through BofAS, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As a registered investment adviser, Merrill completes a Form ADV, which is publicly filed with the SEC and accessible at adviserinfo.sec.gov. For purposes of Form ADV Part 2, certain MLPF&S management persons are registered as registered representatives or associated persons of MLPF&S. In the future, certain MLPF&S personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of MLPF&S to the extent necessary or appropriate to perform their job responsibilities. We, through our Financial Advisors, may suggest or recommend that clients, including SPA clients, use our securities account, execution and custody or other services for your investment activity or use the services of an Affiliate. Similarly, Financial Advisors may suggest or recommend that clients purchase our products or our Affiliates’ products. Where you use or purchase Merrill’s or our Affiliate’s services or products, we and our Affiliates will receive fees and compensation. Financial Advisors, as permitted by applicable law, receive compensation (the amount of which varies) in connection with these products and services. 30 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure CONFLICTS OF INTEREST AND INFORMATION WALLS Merrill and its parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within BofA Corp. possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp. and Merrill evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. CODE OF ETHICS Merrill has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services. The Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that we follow in conducting our business with integrity and professionalism. The Code of Ethics covers requirements relating to employees complying with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. Covered personnel must certify to the receipt of the Code of Ethics. The Merrill Investment Adviser Code of Ethics is available at mymerrill.com/ADV/materials or we will provide a copy of each Code of Ethics to you upon request. We also have imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions as well as those of all employees. Our requirements impose certain responsibilities on Financial Advisors and their trading. Financial Advisors are permitted to participate in block trades along with their clients and/or other Program clients. COMPENSATION, CONFLICTS OF INTEREST AND MATERIAL RELATIONSHIPS Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel Merrill Benefits. Merrill earns revenue from the SPA Fee paid to us under the Program, as well as from commissions, markups/markdowns, up-front sales charges and other sales charges or fees (collectively, “Sales Charges”) paid in connection with brokerage transactions. Merrill also earns revenue from other fees and payments you may make and from what it receives from Affiliates and third-party investment managers, fund managers, product distributors and sponsors and other product providers (“Third-Party Firms”) related to transactions in your Account. Merrill may also receive revenue from Third-Party Firms depending on the investment products in which you invest, which is not part of the Financial Advisor’s compensation. The amount of revenue we receive and compensation your Financial Advisor earns varies depending on the type of account relationship you have with us and whether your account is enrolled in the Program or is a brokerage account. These differences create a conflict of interest in that there is a financial incentive for your Financial Advisor to recommend or select a certain type of relationship or certain investment programs based on the nature of the compensation they will receive. The revenue we receive from your enrollment in the Program may also be more or less than the revenue that would be received if you had instead participated in other of our investment advisory programs or if you had engaged in the investment activities in a brokerage account. There is a conflict of interest when your Financial Advisor recommends an account or program type, a security transaction or investment strategy where it is expected that 31 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Merrill will earn greater revenue over another account or program type, security transaction or investment strategy and therefore will earn more compensation. The more assets there are in your Account, the more you will pay in fees, creating a financial incentive to recommend that you increase the assets in your Account. In the Program, we make more revenue based on the level of assets in the Account as well as the level of the SPA Fee rate that you agree to or are charged. Financial Advisor Compensation and Awards. The Financial Advisor compensation structure results in conflicts of interest between clients and Financial Advisors. Financial Advisors earn compensation based on the revenue that Merrill earns from the SPA Fee paid by you in the Program and other revenue derived from certain, but not all, of the other fees and costs you incur that are not covered by the SPA fee. They also earn compensation and benefits based on the revenue that Merrill earns from Sales Charges related to securities transactions in any brokerage account you may have as well as from the revenue derived from the referrals to Affiliates (including referrals to an Affiliate for banking products or services). You could pay higher fees in a brokerage account than from an account that you enroll in the Program depending on the level of trade activity, products invested in and other factors, which incentivizes your Financial Advisor to recommend a brokerage account. By contrast, if the trading activity in your brokerage account is limited, your Financial Advisor has a financial incentive to recommend that you enroll your account in the Program because we and your Financial Advisor could earn greater compensation from the Program’s annual asset-based fee. For more information about these conflicts, please review the section “Account and Program Choice.” As Merrill revenue increases, the Financial Advisors’ compensation will increase or will be positively impacted. This means that a Financial Advisor will have a financial interest in recommending transactions that generate higher amounts of revenue for Merrill and compensation for them, rather than those transactions that generate lower amounts of revenue. They also have the incentive to charge the maximum SPA Rate rather than agreeing to a lesser fee rate or offering a discount or waiver of Sales Charges for brokerage transactions. We pay Financial Advisors a salary and incentive compensation that is based on the revenues Merrill receives for making available and/or providing the SPA Services, as well as for the brokerage services provided to clients with brokerage accounts. In general, a Financial Advisor is credited in the form of “production credits” with a portion of the SPA Fee paid and, for brokerage accounts, the Sales Charges received from securities transactions. In addition, Financial Advisors also receive production credits based on a clients’ use of margin lending, in respect of brokerage cash swept to Bank Affiliates and for referrals of clients to BANA and other Merrill Affiliates for banking, lending and for other financial services, including trade execution. The calculation of production credits generated takes into account the SPA Fee you pay for SPA Services, Sales Charges received for the investment products purchased or sold in any brokerage account and other factors which may change from time to time. Because different investment products and services have varying Sales Charges, there are different associated production credits related to brokerage transactions in those products. Merrill compensates your Financial Advisor on an ongoing basis derived from the SPA Fee rate that applies to your Account. The SPA Fee Rate is negotiable and when considering whether to offer or agree to charge a lower SPA Fee Rate, a Financial Advisor typically will consider a number of factors, including the type and size of your Account, the breadth of our relationship with you, your engagement with the Financial Advisor, competitive considerations and how Merrill compensates the Financial Advisor. You may accept or decline any proposed rate by your Financial Advisor as part of the negotiation process. Because the amount of compensation paid to your Financial Advisor is based on the SPA Fee Rate for your Account, your Financial Advisor has a financial interest in that Rate. In general, Financial Advisors receive “production credits” toward their compensation formula based on the amount of the SPA Fee that you pay for your Account. Merrill’s policies result in Financial Advisors receiving fewer production credits (by 5% or more) if the assets in the Account are less than $5 million and/or if the weighted average of the SPA Fee Rates for your and your designated household members’ Accounts is lower than the rate levels for specific wealth asset tiers that Merrill establishes. Merrill and Financial Advisors have a conflict of interest based on this structure because the Financial Advisor is incentivized not to offer a SPA Fee Rate below such rate levels or is incentivized to maintain a certain level of assets in the Account since that would reduce their compensation earned. In the Program, a Financial Advisor has a financial incentive to obtain the highest SPA Fee Rate in the fee discussions with you and this incentive can influence the recommendations related to the Strategy for an Account (which has its own separate Investment Manager fee rate that would apply to your Account). The higher the SPA Fee rate you agree to, 32 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure the more your Financial Advisor earns in production credits. The more overall production credits that a Financial Advisor generates, the higher the Financial Advisor’s incentive compensation. This creates a conflict of interest for the Financial Advisor to recommend a Strategy that results in more earned production credits. Recommending a Strategy that has a low Investment Manager Fee rate than others in the Program presents the Financial Advisor with an opportunity to negotiate a higher SPA Fee Rate than might otherwise be the case. This opportunity provides the Financial Advisor with an incentive to recommend Strategies with a lower Investment Manager Fee over Strategies that have a higher Investment Manager Fee. The ability to negotiate a higher SPA Fee Rate benefits Merrill as well as the Financial Advisor since Merrill retains a certain percentage of the SPA Fee. Financial Advisors are eligible to receive a compensation award, payable over a defined period of time, from an incentive program that is currently based on meeting growth targets from the prior year in new households and in assets and liabilities. The growth in assets and liabilities component of the award is based on the movement of client assets into accounts enrolled in certain of our investment advisory programs; investment activity in specified investment products (e.g., money market funds, alternative investments, 529 Plan accounts, annuities and/or life insurance); the opening of new BANA trust accounts; the establishment of 401(k) Plan accounts; and clients’ participation in banking services and lending services (i.e., brokerage sweep deposit accounts and brokerage sweep money market funds, checking and savings accounts, preferred deposit products available in brokerage accounts, loans, mortgages and margin lending) offered by Merrill, BANA and our other Bank Affiliates. Financial Advisors do not receive additional compensation as a result of advisory client assets held in the Cash Sweep Program. A Financial Advisor is subject to a reduction in their incentive compensation if they fail to achieve growth in the assets and liabilities component of the award. Merrill considers and approves its compensation program from year to year and its compensation criteria can change that will impact compensation paid to Financial Advisors. Having a compensation award based on meeting criteria based on client investment activity and engaging with Merrill or Affiliate financial and banking-related services presents a conflict of interest between the Financial Advisor and you because it could lead to such activity being promoted by your Financial Advisor to qualify for the compensation award or to avoid the reduction in their incentive compensation. Financial Advisor Recruitment Payments. Financial Advisors who join Merrill from other firms generally receive payments in connection with that move. These payments may take various forms, including salary guarantees, upfront bonuses or loans and various forms of compensation contingent on continued employment. The amount paid to Financial Advisors under these arrangements generally is based to a large extent on the size of the business at their prior firm. In addition, as part of the recruiting arrangements, they are eligible for future bonus payments based on assets that transfer, including from their prior firm, which creates a conflict of interest since they have an incentive to recommend a transfer of the assets to us. The future bonus payments are conditioned on the total assets in accounts that they service at Merrill. These bonuses are in addition to the incentive compensation to which they are otherwise entitled as Financial Advisors. Rollover Recommendations and Compensation. Financial Advisors have a financial incentive to recommend rolling over assets (“a rollover”) from an employer-sponsored retirement plan (such as a 401(k) plan) or a retirement account at another firm into an Individual Retirement Account (“IRA”). We and our Financial Advisors also have a financial incentive to recommend a rollover to Merrill because transactions in the rollover IRA will generate either investment advisory fees if that account is enrolled in the Program, Sales Charges if a brokerage account, and other compensation that benefits Merrill and the Financial Advisor. Note, effective June 9, 2017, SPA was generally closed to new enrollments by Retirement Accounts. For more information, please review the section “Account Requirements and Types of Clients.” Referral Program and Compensation. Our Financial Advisors may recommend that you utilize the banking products and lending services of BANA or purchase products or services of our Affiliates. In addition, they may refer clients to BANA, BofAS and other Affiliates for financial services that they provide, including transaction execution and investment banking services and products (including banking products). They may introduce fund and other investment product distributors, sponsors, service providers or their affiliates to other services that we, BofA Corp. and our Affiliates provide. Similarly, employees of BANA, BofAS and other Affiliates may refer clients to us for brokerage and investment advisory services. These referrals can involve the payment of referral fees between us and BANA or our Affiliates. If a Financial Advisor refers a client to BANA or other Bank Affiliates to establish a bank account directly with the bank, Merrill receives a payment directly from each Bank Affiliate based on the daily deposit balance held by the Bank Affiliate. The amount of the payment made to Merrill varies from time to time and varies based on the Bank Affiliate. We may waive all or part of this payment. Our referral payment program results in a conflict of interest because Merrill and our Financial Advisors are 33 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure incentivized to introduce products or financial, banking and lending services that provide us or our Affiliates additional compensation or the Financial Advisor with associated production credits. Field Management and Merrill Management Compensation. Elements of our field management compensation are based on revenues to Merrill and based on the Financial Advisors whom they manage meeting strategic goals set for the year, including the growth in assets and liabilities component of the award as described in the subsection “Financial Advisor Compensation and Awards.” Management personnel of Merrill and other employees of Merrill and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is an incentive for our field management team to encourage Financial Advisors to recommend products and services that result in more revenue to Merrill, BANA and other Bank Affiliates and to meet their strategic growth compensation targets under the Financial Advisor compensation plan. There is a financial incentive for Merrill management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. We address the compensation conflicts described in this “Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel” section and in other sections of the Brochure, in a variety of ways, including the disclosure of the conflicts in this Brochure, by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. We engage in oversight and supervision of particular account type relationships and specific investment product choices and we provide account and product disclosures. We maintain policies and procedures and supervisory and review processes that are reasonably designed to ensure that Financial Advisors meet the standard of conduct applicable to each client and that compensation plans and referral compensation and criteria have been designed and implemented to mitigate any incentive or conflict to favor any one security type or investment product or service. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. Account and Program Choice Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. You have the ability to enroll accounts in the Program holding some or all of your investment assets and to have brokerage accounts for some or all of your assets. The various programs we offer and ways to interact with Merrill are outlined in the Form CRS, this Brochure and in the Summary of Programs and Services. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. There are differences among the programs and account relationships. You may be able to obtain the same or similar Services or types of investments you obtain in the Program through a brokerage account or other investment advisory programs and services offered by Merrill. These may be available at lower or higher fees than the SPA Fee you pay. You may also be able to obtain some or all Services from other firms and at fees that may be lower or higher than the SPA Fee we charge. A recommendation of the type of account relationship creates a conflict of interest for us and your Financial Advisor. The amount of compensation we and our Financial Advisors receive depends on the type of account and relationship you choose. In the Program, you will pay the SPA Fee at the rate you agree with your Financial Advisor for the SPA Services. In the Program, the amount of compensation paid to us and to your Financial Advisor depends on the level of assets in your Account and the SPA Fee rate applicable to your Account, as well as certain indirect compensation outlined in this Brochure. In a brokerage account, you will pay per trade Sales Charges to purchase and sell securities and a portion of those charges and fees will be paid to your Financial Advisor. In a brokerage account, the amount of revenues we receive and the compensation that our Financial Advisors receive depends on the level of trading activity in the brokerage account, the applicable Sales Charges and the associated production credits as well as other indirect compensation. You could pay higher fees in a brokerage account than from an account enrolled in the Program depending on the Sales 34 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Charges, frequency of trading and the investment products for investment and other factors. By contrast, if the trading activity in your brokerage account is limited, your Financial Advisor has a financial incentive or conflict of interest to recommend that you enroll in the Program because we and your Financial Advisor could earn greater compensation from the annual asset-based fee. Certain investment strategies are available to you outside of the Program for more or less than you would pay in the Program. We offer other investment advisory programs that offer certain of the Strategies that are the same as or similar to those available in the Program. There are important differences between this Program and our other available investment advisory programs in terms of the services, structure and the applicable fees. You may obtain these Strategies for a lower cost than you pay in the Program but you will receive different services from the Services you receive through the Program. When you compare the account types and investment advisory programs and their relative costs with what is available in the Program, you should consider the various factors outlined in the section “Ability to Obtain Certain Services Separately and for Different Fees.” Certain of these factors relate to your preferences regarding the relationship, whether you are seeking the types of SPA Services available in the Program, how you want to pay for investment services, the SPA Fee rate you agree to with your Financial Advisor and the types of Strategies you are interested in investing in. We address these conflicts through the disclosure in this Brochure and the Client Agreement, by providing clients with upfront information about our available programs and through Program enrollment confirmations in light of your investment objectives, preferences and financial circumstances. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. Use of Related Investment Managers The SPA program offers the ability to choose an Investment Manager that is a Related Manager. We will indicate in the Profile or another disclosure document whether an Investment Manager is a Related Manager. Merrill may include certain Related Managers on the Coverage List but will not include them in the SPA manager identification services. We provide due diligence on the Related Managers included on the Coverage List, but do not provide due diligence on Related Managers that are not on the Coverage List. Related Managers included on the Coverage List will currently not be made available to Retirement Accounts. As of the date of this Brochure, there are no Related Managers on the Coverage List. The selection of a Related Manager would result in increased compensation to us or our Affiliate because we and/or the Merrill Affiliate will retain both the SPA Fee and the Investment Manager Fee (other than with respect to Retirement Accounts). For this reason, a conflict of interest exists when your Financial Advisor assists you in the selection of a Strategy of a Related Manager. In addition, we have a conflict of interest when recommending, selecting, monitoring and considering the removal or status change of a Related Manager because we and our Affiliates have an incentive to favor Related Managers over those whose selection would be expected to result in less total compensation to us and our Affiliates. If the Strategy of a Related Manager is selected, we and/or the Merrill Affiliate retain both the SPA Fee and the Investment Manager Fee (other than with respect to Retirement Accounts). For this reason, a conflict of interest exists when your Financial Advisor assists you in the selection of a Strategy of a Related Manager. Our Affiliates such as BANA, offer their own managed products or wrap programs that are similar to this or other Merrill programs. Advice and/or recommendations provided to accounts in those programs, including advice related to the recommendation of certain Investment Managers, will be different from, or even conflict with, the advice and recommendations provided in connection with the Program or to other Affiliates. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. For example, we may recommend a specific Investment Manager for inclusion in a BANA program, but not a Merrill program. Conflicts of interest related to the inclusion of Related Managers in SPA are further discussed under the section “Trading in SPA Accounts.” We address these conflicts through disclosure in this Brochure and the Strategy Profile and by selecting Strategies based on the investment merits of the particular investment products. We also determine the compensation paid to our 35 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure Financial Advisors on the same basis for all Strategies selected for use in the Program without regard to the amount of compensation we or our Affiliates receive. Our Financial Advisors do not have an incentive to recommend certain Strategies over others because they do not receive additional compensation from the Investment Manager Fee for a Strategy. Cash Sweep Program Compensation Received by Us and Our Affiliates Merrill benefits financially when there are cash balances in the bank deposit accounts affiliated with the Cash Sweep Program. Merrill receives payments from our Bank Affiliates on a per account basis for each account that sweeps to one of our Bank Affiliates relating to offering and supporting the Cash Sweep Program. The fees we receive from the Bank Affiliates is one of many factors that affect the interest rate paid by the Bank Affiliates on your swept cash balances under the Cash Sweep Program. For Accounts that are eligible for and that elect a money market fund as its cash sweep option, we receive compensation for providing infrastructure, marketing support, sub-accounting or other services. If you choose the “No Sweep” option, we also benefit from the custody or use of uninvested cash balances also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. For the ISA cash sweep option available to certain account types, we receive a fee directly from each Participating Bank based on the daily deposit balance held by the Participating Banks. The amount of the fee varies from time to time and by the Participating Banks. For referrals made by a Financial Advisor resulting in a bank deposit account with a Bank Affiliate, we are entitled to receive a fee directly from each Bank Affiliate based on the daily deposit balance, which fee can be waived in whole or in part. For Program Accounts, Financial Advisors are compensated based on the SPA Fee charged on the Account which is based on the agreed-upon SPA Fee rate and the value of the assets in the Account, including cash balances and cash alternatives swept under the Cash Sweep Program. This creates a conflict of interest and an incentive for your Financial Advisor to recommend that you hold your securities investments and cash assets in your Account so that it would be included in the fee calculation. In addition, Financial Advisors receive increased compensation based on achieving a number of strategic objectives, including, among other activities, the growth in their clients’ participation in banking services and Lending Programs offered by Merrill, BANA and our other Bank Affiliates, like the brokerage account bank sweep deposits and brokerage account sweep money market funds, checking and savings accounts, the Preferred Deposit product available in brokerage accounts, loans, mortgages and margin lending. Financial Advisors do not receive additional compensation as a result of advisory client assets held in the Cash Sweep Program. The Bank Affiliates benefit financially from the Cash Sweep Program. Through the Cash Sweep Program, they receive a stable, cost-effective source of funding. They use the cash funds that are deposited in the bank deposits to fund their current and future lending, investment and other business activities. The participation of the Bank Affiliates in the Cash Sweep Program increases their respective deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” they earn on the deposits—the difference between the interest paid on the bank deposits and other amounts paid to Merrill related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in your Account that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more our Bank Affiliates benefit. Cash balances swept to a bank deposit account of our Bank Affiliates under the Cash Sweep Program will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts is periodically set and reset by the Bank Affiliates in their discretion. Under MLBD Program and RASP, interest rates for the MLBD Program and RASP are tiered based upon your relationship with Merrill. Accounts with the MLBD Program and RASP as their Cash Sweep Program that are enrolled in SPA and in other specified Merrill investment advisory programs receive the highest tier rate available under these programs. A brokerage account with one of these sweep options that enrolls in the SPA Program will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. There is no interest rate tiering offered under the IBVRD Facility. Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection and receive a lower rate than the highest rate available under the MLBD Program or RASP. 36 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure In any event, the interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. Merrill receives compensation for administrative and other services from the money market funds available as an automatic sweep option for certain Retirement Accounts which we do not retain under applicable regulation. We rebate the compensation received from the fund managers of the sweep money market funds to clients of these Retirement Accounts. We address the conflicts of interests associated with the Cash Sweep Program and the deposit accounts in a variety of ways, including through disclosure in this Brochure, by requiring clients to affirm their interest for the Cash Sweep Program options in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to your participation in the Cash Sweep Program. Financial Advisors do not receive any additional compensation for assets held in the Cash Sweep Program as opposed to another cash alternative product. We have adopted various policies and procedures reasonably designed to prevent the cash sweep arrangement and other business arrangements from affecting the nature of the advice we and our Financial Advisors provide. Third-Party Firm Business Relationships and Support We and our Affiliates have business relationships with Investment Managers, including Investment Managers participating in SPA, and other Third-Party Firms. We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for product vehicles managed or sponsored by them. We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates by a Third-Party Firm is additional compensation to us for services we and our Affiliates provide. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Financial Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our Financial Advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, we select Strategies that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our Financial Advisors provide. Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (“Conferences”) for invited Merrill financial professionals. These financial professionals include Financial Advisors and members of their team, employees who work for a Merrill branch, market or division to support the Financial Advisors (“Field Employees”) and employees who cover product, Chief Investment Office and home office support functions (“Non- Field Employees”). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third- Party Firms participate (“Client Events”). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending Financial Advisors and 37 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with a number of such Conferences and Client Events in the amount of approximately $21 million. Certain Third-Party Firms periodically host or participate in meetings (“Manager Meetings”) where they provide certain Financial Advisors, Field Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. . Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending Financial Advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of charitable events and causes that we requested or initiated with Third-Party Firms in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives for Financial Advisors to recommend products of participating Third-Party Firms. They give those Financial Advisors participating in Conferences, Client Meetings and Manager Meetings with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for Field Employees to approve those recommendations and for non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our Financial Advisors to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Employees to approve their Financial Advisors’ recommendations of products and services of those participating third-Party Firms. Furthermore, we do not incentivize Non-Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. We limit the participation of Financial Advisors, Field Employees and Non-Field Employees in these events. Third-Party Firms are not permitted to condition their payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs of Conferences and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Representatives of Third-Party Firms will, from time to time, meet and work with our Financial Advisors, Field Employees and Non-Field Employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third-Party Firms from providing and paying for, and our Financial Advisors, Field Employees and Non-Field Employees from receiving, gifts and entertainment, other than as permitted and subject to the limits established under Merrill internal policies. In general, Financial Advisors, Field Employees and Non-Field Employees may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting Third-Party Firm representatives access to our financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. It can also create incentives for Field Management Employees to approve recommendations of a Financial Advisor, where required. Furthermore, providing gifts and entertainment to Non-Field Employees creates incentives to approve the investment products of the Third-Party Firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product 38 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS There are various ways that we can be viewed as participating or having an interest in client transactions. These situations and any conflicts of interest arising from such activities, execution approach or other capabilities we offer in the Program are discussed in this section and throughout the Brochure. Cash Balances and Cash Sweep Program. As further described in “Funding and Operation of Accounts—Cash Balances and the Cash Sweep Program,” cash balances may be held in your Account for a number of different reasons, including as part of a Strategy’s asset allocation to cash. To the extent the Investment Manager does not select a cash alternative vehicle for your Account’s cash allocation, the allocation will be maintained in your Account as a cash balance. Unless your Account is a certain type of Retirement Account or a TMA Account, the only sweep vehicle currently available to you for the cash balance is a bank deposit account affiliated with the Cash Sweep Program with our Bank Affiliates. Please see the section “Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates” for a discussion of the conflicts of interest related to the Cash Sweep Program. The Sweep Program Guide for Merrill Clients provides information on the fees that Merrill receives from the Bank Affiliates for each account, including Program Accounts that sweeps to the MLBD Program, the RASP and the ISA Program. These fees are up to $100 per year for each account received from the Bank Affiliates and a fee of up to 2% per annum of the daily balances from the ISA banks. This compensation is subject to change from time to time, and Merrill may waive all or part of it. For TMA and certain eligible retirement accounts that have selected the money market fund automatic sweep option, the available sweep money market funds include a 0.40% asset-based administration fee per annum that is paid to Merrill. Merrill rebates the amount of the asset-based administration fee it receives to these clients. The amount of such rebate may be less than this 0.40% fee in certain rate environments where the fund manager waives or reduces the amount of such fee in order to avoid a negative return on the money market fund. Merrill may benefit from the possession or use of cash balances, also known as free credit balances, in your accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934. Other Compensation Received by Us and Our Affiliates. Separate and apart from the Program, Merrill, through its Financial Advisors, may suggest or recommend that you use the Merrill brokerage account and our execution and custody or other services for other of your investment activity or use the services of our Affiliates. Similarly, our Financial Advisors may suggest or recommend that you purchase our products or those of our Affiliates. Where you use or purchase our or our Affiliate’s products and services, we and our Affiliates will receive fees and compensation. We address the conflicts of interest presented by these Affiliated transactions described below by calculating the compensation paid to our Financial Advisors without regard to the amount of the compensation that we or our Affiliates receive from those transactions. In addition, we have adopted various policies and procedures reasonably designed to prevent the receipt of compensation by Merrill and its Affiliates and other business arrangements from affecting the nature of the advice we provide. Principal, Agency-Cross and Cross Trades. There may be instances in which we or an Affiliate of ours act as principal in effecting an investment transaction for your Account, in accordance with applicable law. If we or an Affiliate of ours effect a principal transaction for your Account, Merrill will not charge a markup or markdown. However, principal transactions may be subject to a mark-up, mark-down, dealer spread, underwriting discount, selling concession or other compensation and our Affiliates can profit from transacting as your counterparty or having proprietary positions in the subject securities. We or one of our Affiliates may, at times, act as agent for both buyer and seller in effecting investment transactions involving SPA clients or other advisory clients (“agency-cross transactions”), in accordance with applicable law. Since we generally will receive compensation from each party to an agency-cross transaction, there is a conflict between our responsibilities and loyalties to you and to the other party to the transaction. Any compensation we receive will be in addition to the SPA Fee. By signing the Client Agreement, you consent to us acting as your agent in effecting agency- cross transactions for the Account when we consider them advisable and consistent with applicable law. You may revoke the consent at any time by notifying us in writing. 39 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure From time to time, we may cause your Account to engage in a transaction for the purchase or sale of a security with another client, subject to applicable law. We would do so only when we determine that the transaction is in the best interest of each party, and we would not receive any compensation in connection with the transaction. Investments in Fund Products. We generally restrict Investment Managers from purchasing mutual fund shares in your Account, including purchasing additional shares of any mutual fund that you used to fund your Account (either initially or otherwise). To the extent that you fund your Account with mutual fund shares, and you or your Investment Manager do not liquidate or transfer such shares from your Account within a limited period of time after being requested to do so, we will terminate your Account from SPA. Mutual funds and money market funds that are not held through a cash sweep vehicle applicable to your Account are not eligible assets and therefore are not subject to the SPA Fee. In the event your Investment Manager is permitted to use these mutual funds as a part of the Strategy used in your Account, you understand that these funds may be related to the Investment Manager. Any fees and compensation, including the sub-accounting services fees discussed below, that we or our Affiliates receive from or on behalf of a mutual fund or either of their product sponsors in connection with your investments enrolled in the Program are in addition to the SPA Fee and, except to the extent required by applicable law, the SPA Fee is not offset or reduced by any such fees and compensation we receive. These mutual funds may pay us to provide the required sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under agreements with mutual funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services (either directly or through a subsidiary) to the holders of these types of mutual funds maintaining shares in an Account as well as in other Merrill securities accounts and receive the agreed upon sub-accounting services fee. This cost is either borne by the mutual fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by type of mutual funds, the mutual fund itself and by share class. For U.S. mutual funds, depending on the specific arrangements, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market funds, the sub-accounting services asset-based fee is generally 0.005% per annum. These fees and fee rates are subject to change from time to time and may be received individually, or as part of a “bundled” arrangement includes other types of fees, such as administration and distribution payments. Due to applicable regulation, we do not retain compensation for sub-accounting or administrative services for money market fund assets that are held through a cash sweep vehicle for Retirement Accounts or TMAs. The amount of the sub-accounting services fees varies among mutual funds and, in certain instances, between share classes of individual mutual funds. There is a benefit to us from the sub-accounting fee because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. We disclose the nature of our sub-accounting service arrangements. Mutual funds and money market funds, that are not held through a cash sweep vehicle applicable to your Account are not eligible assets and therefore are not subject to the SPA Fee. Provision of Diversified Financial Services. BofA Corp., through its subsidiaries and Affiliates, including us, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning, asset management and investment advisory and related recordkeeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, ETFs, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research including: global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. As a result, we, BofA Corp. and our Affiliates can be expected to pursue additional business opportunities with the entities whose investments we and our Financial Advisors recommend or make available to clients. Consistent with industry regulations, the services that we and our Affiliates provide include banking and lending services; sponsorship of deferred compensation 40 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure and retirement plans; recordkeeping services; investment banking; securities research; institutional trading and prime brokerage services; custody services; investment advisory services; and effecting portfolio securities transactions for Funds and other clients. BofA Corp. is subject to the reporting requirements of the Exchange Act and additional information about it can be found in publicly available filings with the SEC. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships are publicly available in Regulation NMS Rule 606 reports we file with the SEC. From time to time, a shareholder of BofA Corp. may acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Account, such as buying or selling securities issued by the shareholder or its affiliates, may be limited. Participation in Affiliate Lending Programs and Margin. There are of conflicts of interest when we recommend that you use a loan secured by your Account assets as collateral. These conflicts exist with any of our Affiliate lending programs that may be available to you from an Affiliate lender. In the case of a loan from an Affiliate, including but not limited to the Loan Management Account® product (“LMA® account”), the Affiliate lender intends to derive a profit as lender based on interest and/or fees, if any, charged on the loan, and your Financial Advisor receives compensation based on a percentage of the loan revenue of the Affiliate lender for such loan. Financial Advisors may receive greater benefit if you borrow more under a margin or Affiliate lending program and if you are charged a higher interest rate. The lender, whether it be Merrill, an Affiliate or a third-party lender, has a lien on your Account assets that are used as collateral for the loan. The lender will act to protect itself as lender in connection with the loan, and this may be contrary to your interests and/or investment objectives. Having a lien on your Account in connection with an Affiliate loan also creates a conflict of interest with respect to the recommendations we make to you. For example, your Financial Advisor may recommend that you allocate your investments to your Account that has an Affiliate lender’s lien rather than to another Account without such lien. Another example is that your Financial Advisor may recommend a less risky investment in order to minimize the risk of loss with respect to the Affiliate lender’s collateral. Furthermore, your Financial Advisor is compensated based on a percentage of the revenue on the loan and this means your Financial Advisor can benefit from your borrowing under the lending program, rather than liquidating assets held in the Account, and will receive a reduction in compensation earned by recommending you to reduce your outstanding loan balance. Certain investment strategies can involve the use of margin. Merrill will receive compensation in connection with any assets purchased in an Account on margin or other extensions of credit by us, which is in addition to, and does not reduce, the SPA Fee. Financial Advisors will receive additional compensation in such circumstances, unless waived, as well as, in limited cases, from rights or tender offers. The additional economic benefit to us from the use of margin creates a conflict of interest. Activity by Merrill, its Affiliates and Personnel. We and our affiliates act in a variety of capacities to a wide range of clients. From time to time in the course of those duties, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. Similarly, we may give advice or take action with regard to certain clients, including SPA clients, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken with respect to certain securities, Funds or Investment Managers. In some instances, the actions taken by affiliates with respect to similar services and programs will conflict with the actions taken by us. This is due to, among other things, the differing nature of the affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. Certain of our affiliates may have investment banking or other relationships with certain publicly traded companies; from time to time, these relationships compel us to forego trading in the securities of these companies. In the course of investment banking and other activities, our affiliates acquire confidential or material nonpublic information that prevents us or our affiliates, for a period of time, from purchasing, selling or recommending particular securities for your Account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. 41 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure We do not receive payment for order flow from liquidity providers to which we route our customer orders in equity securities. We directly or indirectly (through our Affiliate) receive rebates from, and pay fees to, certain registered securities exchanges for providing or taking liquidity on those exchanges according to those exchanges’ published fee schedules filed with the SEC. In some cases, the rebates received by us from an exchange over a period of time will exceed the fees paid to the exchange. We directly or indirectly (through our Affiliate) also participate in the options order flow programs sponsored by options exchanges such as the NYSE American Options, NYSE Arca Options, and the Cboe options and Nasdaq options exchanges. These exchange-sponsored programs offer payments for listed option orders that are directed to such options markets. The rebates and payments from these third parties vary depending on the order and the exchange to which orders are directed and create a conflict of interest because we are incentivized to recommend transactions that provide us with greater rebates or payments from these exchanges. We may offer Strategies of Related Managers. If a Strategy provided by a Related Manager is selected, we will retain the entire SPA Fee and the Investment Management Fee. For this reason, a conflict of interest exists when our Financial Advisor selects or assists you in the selection of, as applicable, a Related Manager Strategy. We and our Affiliates provide some or all of the same services offered in the Program through other financial firms, either with Affiliates or with firms that are unaffiliated. Certain of these services have fee rates that differ from the SPA Fee. We or our Affiliates may have a position in or enter into “proprietary” transactions in securities purchased or sold for clients, including SPA clients. We or our Affiliates benefit from such securities positions or transactions. Covered Entities Under the Volcker Rule. We may provide certain entity clients that qualify as “family wealth management vehicles” (“FWMV”), or FWMV clients, with both the services under the Program as well as lending services and to engage, where permitted, in principal transactions. In doing so, we rely on the exception under the Volcker Rule implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Client Agreement. For certain entity clients that are deemed “covered fund clients” under the Volcker Rule we are not permitted to offer both services under the Program and the availability of margin, lending or other extensions of credit from us or any of our Affiliates, including BANA, or engage in certain principal transactions. Certain other transactions between BANA or its Affiliates and the entity client will also be prohibited. REVIEW OF ACCOUNTS; REPORTS We do not review your Account on a periodic or other basis to monitor the trading of the Investment Manager or to confirm that Account transactions of the Investment Manager conform to your investment goals, risk tolerances or other instructions. We provide you with the opportunity to engage in periodic Account reviews in which your Financial Advisor reviews your Account’s progress toward goals. Because these reviews provide you with important and necessary information relating to your Account, you are strongly encouraged to take advantage of these opportunities to participate in these Account reviews. If you do not participate in your Account review, we may, in our discretion, terminate your Account from the Program. In addition, on a periodic basis, you are instructed, in writing, to provide us with current information regarding your Account. This would include changes in your financial situation or investment objectives, or if you would like to impose any reasonable restrictions or reasonably modify any existing restrictions. If the changes provided are material in nature, a review of your Account may be in order. As described in the section “Reasonable Investment Restrictions,” you may impose reasonable investment restrictions on your Account or modify any existing restrictions, but you must communicate such restrictions directly to your Investment Manager. You should understand that your Investment Manager, not Merrill, will be responsible for complying with your restrictions, if any, and we and your Financial Advisor shall not be responsible for implementing or monitoring your restrictions. Certain of our materials, including this Brochure, are compatible with various types of assistive devices, such as screen readers. Other program materials have varying degrees of compatibility with different assistive devices. If you experience difficulty in accessing a program document with an assistive device, please inform a Financial Advisor and request that the document be made accessible. As discussed above, we assist you in monitoring and evaluating the performance of 42 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure your investment accounts by providing periodic performance reports containing returns and other statistical performance analyses. When we act as custodian, you will receive an account statement in any month in which there is trading or other activity (or in any event quarterly). If you use a custodian other than us, your custodian or trust company must provide periodic custodial or trust reports and settlement instructions to us (or our designee). We are not responsible for the accuracy of these statements and will rely upon the data and other information presented therein or in other reports provided to us by your custodian to prepare performance reports for you. You may also receive reports directly from your selected Investment Manager. As you direct in the Client Agreement or other writing, you may elect not to receive confirmation of transactions for your Account(s) on a trade-by-trade basis, except as required by rule or regulation, and, in lieu thereof, receive a periodic statement that will be furnished to you not less frequently than quarterly and that will contain the same information that would be included in the trade-by-trade confirmation for each transaction. Your election to receive periodic statements in lieu of trade-by-trade confirmations is entirely optional, will not affect the calculation of or amount of your SPA Fees and is not a condition to entering into or continuing participation in SPA. You may rescind your election at any time by written notice to us with respect to your Account. We will send confirmations for transactions effected in your Account (or information contained therein) to you and your Investment Manager, as applicable. You may request, and we will provide to you at no additional cost, an interim update and further details concerning any transaction effected between periodic statements either by calling your Financial Advisor or, where you are enrolled in MyMerrill, by checking your account on MyMerrill. If you elect to receive periodic statements in lieu of trade-by-trade confirmations, you may later choose to receive, and we will provide to you at no additional cost, any confirmations for transactions effected for up to a one-year period preceding your last periodic statement and trade-by-trade confirmations for all subsequent transactions. CLIENT REFERRALS AND OTHER COMPENSATION Our Financial Advisors are not permitted to give to you or accept from you any fee, kickback, or other thing of value, including a SPA Fee Rate reduction, gifts, meals, or entertainment pursuant to any agreement or understanding, oral or otherwise, for receiving or referring business. We have entered or may enter into marketing arrangements with third parties who, for compensation, will provide certain services to us in connection with the marketing of our various advisory services, including SPA, for referring prospective clients to us. Each such marketing arrangement is or will be governed by a written agreement between us and the applicable third-party, and will be disclosed to you, as required by law. We have entered into solicitation arrangements with certain third-party entities to refer prospective clients to us (“Solicitors”). Generally, the fees paid to Solicitors will be paid from investment advisory fees received and retained by us relating to your Account. This fee will generally be a percentage of the investment advisory fee ordinarily credited to your Financial Advisor for the applicable account. We will pay this fee to the Solicitor from the date you establish an account in the applicable program for as long as your account remains enrolled in SPA and the agreement between us and the Solicitor is effective. If we terminate the agreement with the Solicitor for certain reasons, we may continue to pay the Solicitor for a period of time after termination. We will not increase the fees you pay as a result of our payments to the Solicitor. The fees we charge will not be higher than our usual fees because of the payments to the Solicitor. Our employees may refer advisory clients to BANA and other affiliates for products and services. Similarly, employees of BANA and its affiliates may refer clients to us for brokerage or advisory services. These referrals may involve the payment of referral fees between Merrill and BANA or its affiliates. FINANCIAL INFORMATION Not applicable because (1) Merrill is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act (2) Merrill does not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (3) there is no financial condition of which we are aware that is reasonably likely to impair Merrill’s ability to meet contractual commitments to its clients; and (4) Merrill has not been the subject of a bankruptcy petition at any time during the past 10 years. 43 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure GLOSSARY Account or SPA Account means each of the securities accounts to which the Client Agreement applies. ADR means American Depositary Receipt, which is a receipt for shares of a foreign company held by a U.S. financial institution that entitles you to rights and obligations of the underlying shares, including dividends and capital gains and losses. Advisers Act means the Investment Advisers Act of 1940, as amended. Affiliate means a company that is controlled by, in control of, or under common control with, another company. Affiliated Custodian means an Affiliate of Merrill that provides custodial services. AIPS means the Merrill Automated Investment Program. BANA means Bank of America, N.A. Bank Affiliate means one or more bank depository institutions affiliated with Merrill. Bank of America or BofA Corp. means Bank of America Corporation, the parent company of MLPF&S, MAA and other Affiliates. BofAS means Bank of America Securities, Inc. Brochure means the Merrill wrap fee program brochure relating to SPA, as amended or updated from time to time. Cash Sweep Program means the program associated with your securities account whereby cash balances in your Account are automatically swept into a cash sweep vehicle in accordance with the terms of the program for your Account. CIO means the Chief Investment Office of MLPF&S. For certain strategies, CIO refers to the Chief Investment Office of BANA, as described in the Profiles of those Strategies. Client Agreement means the agreement relating to SPA between the client and Merrill, as it may be amended from time to time. Code of Ethics means the Merrill Investment Adviser Code of Ethics. Coverage List means the SPA Current Coverage List of Strategies from which clients may select. ERISA means the Employee Retirement Income Security Act of 1974, as amended. “ERISA Plan” means a plan subject to the fiduciary responsibility provisions of ERISA or any other entity deemed to hold assets of such a plan, including SIMPLE, SEP and other IRAs subject to ERISA’s fiduciary responsibility provisions. ETF means an exchange-traded fund. Exchange Act means the Securities Exchange Act of 1934, as amended. FDIC means the Federal Deposit Insurance Corporation. Financial Advisor means the Merrill Financial Advisor who provides non-discretionary investment advice to the client in SPA. Funds means registered and unregistered investment companies, including mutual funds, money market mutual funds, closed-end funds, ETFs and hedge funds, real estate investment trusts and other pooled investment vehicles. Investment Manager means an investment adviser that is registered with the SEC or one or more state regulatory authorities, or which is exempt from the registration requirement. “Investment Manager” includes a Related Manager. Investment Manager Fee means the advisory fee that you pay the Investment Manager. IPR means the Institutional Performance Report, which is only provided to clients who elected the Institutional Performance Reporting Service prior to March 27, 2017. Margin Agreement means account documentation executed at account opening relating to the use of margin in your Account. MLIAP means Merrill Lynch Investment Advisory Program. Options and Margin Strategies means those Strategies where the Investment Manager may employ margin, write uncovered options and/or sell securities short. Profile: a document with important information about each Strategy on the Coverage List Profiling Questionnaire means a questionnaire that SPA clients complete as part of the enrollment process into SPA that elicits information about their financial circumstances, investment objectives, risk tolerance and other relevant information relating to their Account. Program means the Merrill Lynch Strategic Portfolio Advisor® Service. REIT means a real estate investment trust. Related Company means a company that is an Affiliate of Merrill or in which Merrill or an Affiliate of Merrill has a material ownership interest. Related Fund means a Fund sponsored, managed, or advised by Merrill or a Related Company. Related Manager means an Investment Manager that is a Related Company. Retirement Account means an plan subject to the fiduciary responsibility provisions of Employee Retirement Income Security Act of 1974, as amended, or any other entity deemed to hold assets of such a plan, including SIMPLE, SEP and other IRAs subject to ERISA’s fiduciary responsibility provisions, a U.S. tax-qualified plan of self-employed persons, a U.S. individual retirement account, or any other plan, arrangement or entity subject to Section 4975 of the U.S. Internal Revenue Code of 1986, as amended. Rule 12b-1 fees means fees paid pursuant to a plan adopted under Rule 12b-1 under the Investment Company Act. Sales Charges means commissions, markups/markdowns, up-front sales charges and other sales charges or fees paid in connection with brokerage transactions. SEC means the U.S. Securities and Exchange Commission. Securities Act means the Securities Act of 1933, as amended. Selling Broker Compensation means commissions, markups, markdowns, asset-based or subscription fees, mutual fund sales loads, Rule 12b-1 fees or other remuneration as described in the applicable confirmations, prospectuses, subscription agreements, or other offering documents. SPA means the Merrill Lynch Strategic Portfolio Advisor® Service. Strategy means one or more investment styles or disciplines or combinations of investment styles and disciplines offered by Investment Managers participating in SPA. Unaffiliated Trade Counterparty means a broker or dealer other than Merrill or an Affiliate of Merrill. Uncovered Investment Manager means Investment Managers retained by you outside of SPA manager identification services or Investment Manager(s) that are not on the Coverage List or available in the MLIAP. To the extent a Related Manager is on the Coverage List but is not included in the SPA manager identification services, such Related Manager would not be considered an Uncovered Investment Manager. Uncovered Strategies means Investment Managers retained by you outside of SPA Manager Identification Services or Strategies) that are not on the Coverage List or are not available in MLIAP. To the extent a Related Manager is on the Coverage List but is not included in the SPA Manager Identification Services, such Related Manager would not be considered an Uncovered Investment Manager. Unrelated Custodian means a custodian that is neither Merrill nor its Affiliate. Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. © 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated Printed in the U.S.A 44 SPA2A 0325Merrill Lynch Strategic Portfolio Advisor Service Brochure

Merrill Lynch INVESTMENT ADVISORY PROGRAM WRAP FEE PROGRAM BROCHURE Please retain for your records Managed Account Advisors LLC 101 Hudson Street Jersey City, NJ 07302 201.557.0504 Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 800.637.7455 ml.com This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) and Managed Account Advisors LLC (MAA) relating to the Merrill Lynch Investment Advisory Program. If you have any questions about the contents of this Brochure, please contact us at 800.MERRILL (800.637.7455). Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about MLPF&S and MAA also is available on the SEC’s website at adviserinfo.sec.gov. The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (FDIC) or any other government agency, are not a deposit or other obligation of or guaranteed by MLPF&S, MAA or Bank of America Corporation (BofA Corp.) or any of its affiliates and are subject to investment risks, including possible loss of principal. March 21, 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as “MLPF&S” or “Merrill”) makes available certain investment products sponsored, managed, distributed, or provided by companies that are affiliates of Bank of America Corporation (“BofA Corp.”). MLPF&S is a registered broker-dealer, Member SIPC and a wholly owned subsidiary of BofA Corp. Merrill Lynch Life Agency Inc. (MLLA) is a licensed insurance agency and a wholly owned subsidiary of BofA Corp. Investment products offered through MLPF&S and insurance and annuity products offered through MLLA: Are Not FDIC Insured May Lose Value Are Not Bank Guaranteed Are Not Insured by Any Federal Government Agency Are Not Deposits Are Not a Condition to Any Banking Service or Activity IAPB-032025  ITEM 2. MATERIAL CHANGES On March 22, 2024, MLPF&S and MAA together filed their last annual update for the Merrill Lynch Investment Advisory Program brochure (Brochure). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. It also sets forth changes as well as enhancements made in this annual update as well as those made since the 2024 annual update, which were previously communicated. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated “Item 9 Additional Information” at the heading “Disciplinary Information” to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We enhanced existing disclosure regarding the conflicts of interest that Advisors have when determining the Merrill Lynch Fee Rate they will agree to with a client. See “Item 4 The Program Fee and Other Charges” and “Item 9 Compensation, Conflicts of Interest and Material Relationships— Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel Advisor Compensation and Awards.” • We augmented our disclosure relating to the departure of a financial advisor where the Program Strategy type for an Account is Defined Strategy or Personalized Strategy with Advisor Discretion to highlight that, consistent with clients’ authorization through the Program agreement, Merrill may determine to select a replacement Program Strategy type for an Account and/or a Style Manager Strategy that we believe to be in your best interest. See “Item 4 Funding and Operation of Your Account—Terminating Enrollment in the Program.” • We included additional information in “Item 6 Advisory Services Provided by Merrill, its Advisors and Certain Affiliates” to describe certain eligibility requirements related to an Advisor’s offering of the Program Strategy types of Defined Strategy or Personalized Strategy with Advisor Discretion. • We updated the information relating in Third-Party Firms’ providing gifts and entertainment to our financial advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non-cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. See “Item 9 Compensation, Conflicts of Interest and Material Relationships—Third-Party Firm Business Relationships and Support-Third-Party Firm Office Access and Gifts and Entertainment.” MATERIAL CHANGES AND ENHANCED DISCLOSURES MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes and Enhancements • We updated “Item 9 Additional Information” at the heading “Disciplinary Information” to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” • We have updated our disclosures throughout the Brochure to remove references to the Preferred Deposit product as it is no longer available in the Program and to make other enhancements. Investment Advisory Program Brochure | 2 IAPB-032025 ITEM 3. TABLE OF CONTENTS About Us and the Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ITEM 4 SERVICES, FEES AND COMPENSATION . . . . . . . . . . . 6 Advice and Guidance Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Profiling and Setting a Target Asset Allocation . . . . . . . . . . . . . . . . . . . . 6 Target Asset Allocation Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Monitoring Adherence to Target Asset Allocation . . . . . . . . . . . . . . . . . . 6 Ability to Establish Multi-Client Portfolios Groups. . . . . . . . . . . . . . . . . . 6 Program Guidelines. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Treatment of Cash Balances in Your Account . . . . . . . . . . . . . . . . . . . . . . 6 Investment Strategy Services Available . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Overview and Program Strategy Types . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Ability to Request Reasonable Investment Restrictions . . . . . . . . . . . . . 8 Managed Strategy as a Program Strategy Type. . . . . . . . . . . . . . . . . . . . 9 Custom Managed Strategy as a Program Strategy Type . . . . . . . . . . . 12 Premium Access Strategy as a Program Strategy Type . . . . . . . . . . . . 13 Defined Strategy as a Program Strategy Type . . . . . . . . . . . . . . . . . . . . 15 Personalized Strategy with Advisor Discretion as a Program Strategy Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Personalized Strategy with Client Discretion as a Program Strategy Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Retirement Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Selection and Review of Investment Strategies and Funds Available in the Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Available Information Regarding Style Manager Strategies, PAS Style Manager Strategies and Funds . . . . . . . . . . . . . . . . . . . . . . . . 39 Strategy Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 Advisory Services Provided by Merrill, its Advisors and Certain Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 Performance-Based Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 Methods of Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 Investment Strategies and Risk of Loss . . . . . . . . . . . . . . . . . . . . . . . . . . 40 Tailored Investment Advice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Voting Client Securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 ITEM 9 ADDITIONAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . 45 Disciplinary Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 Other Financial Industry Activities and Affiliations . . . . . . . . . . . . . . . . 45 Conflicts of Interest and Information Walls. . . . . . . . . . . . . . . . . . . . . . . 46 Code of Ethics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 Compensation, Conflicts of Interest and Material Relationships . . . . 46 Portfolio Reviews, Program Reports and Information. . . . . . . . . . . . . . 17 Brokerage, Banking-Related and Custodial Arrangements and Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Brokerage Trading Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Brokerage Execution for Discretionary Style Manager Strategies and PAS Style Manager Strategies. . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Brokerage Arrangements for Certain Securities Transactions . . . . . . . 19 Cash Sweep Program and Other Banking-Related Services . . . . . . . . . 19 Custodial Arrangements and Services . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Proxy Voting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Proxy Voting Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Implementing Your Proxy Voting Selection . . . . . . . . . . . . . . . . . . . . . . . 22 Delivery of Trade Confirmations on a Periodic Basis . . . . . . . . . . . . . . 23 Delivery of Program Materials and Electronic Access . . . . . . . . . . . . . . 23 Optional Account Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 MAA Tax Efficient Management Overlay Services. . . . . . . . . . . . . . . . . 24 Rebalancing Service and Automatic Contribution/Withdrawal Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 Account and Program Choice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 Affiliated Investments of a Style Manager or a PAS Manager. . . . . . . 49 Offering of Investments or Programs Managed by Us or Our Affiliates and Use of a Related Strategy in Your Account . . . . . . . . 49 Variable Compensation by Product and Service . . . . . . . . . . . . . . . . . . . 49 Compensation Received by Us for Sub-accounting Services . . . . . . . . 50 Mutual Funds Arrangements and Compensation . . . . . . . . . . . . . . . . . . 50 Certain Alternative Investment Fund Arrangements and Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 Cash Sweep Program Compensation Received by Us and Our Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 Other Compensation Received by Us and Our Affiliates. . . . . . . . . . . . 52 Third-Party Firm Business Relationships and Support . . . . . . . . . . . . . 53 The Program Fee and Other Charges. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Program Fee and Services Covered by the Program Fee . . . . . . . . . . . 25 The Merrill Lynch Fee Component of the Program Fee. . . . . . . . . . . . . 25 The Manager Fee Component of the Program Fee . . . . . . . . . . . . . . . . 27 Payment of the Program Fee. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 How the Program Fee is Charged . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Fees and Expenses Not Covered by the Program Fee . . . . . . . . . . . . . . 30 Ability to Obtain Certain Services Separately and for Different Fees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 The MGI, MGI with Advisor and MEAA Programs. . . . . . . . . . . . . . . . . . 31 Access to Managed Strategies through SPA and MAS and from BANA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Participation or Interest in Client Transactions and Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 Cash Balances and Cash Sweep Program . . . . . . . . . . . . . . . . . . . . . . . . 54 Principal Trade Execution. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 Internal Cross, Agency Cross and other Cross Transactions. . . . . . . . . 55 Treatment and Allocation of Equity Initial Public Offerings . . . . . . . . . 55 Order Flow, Order Routing and Rebates . . . . . . . . . . . . . . . . . . . . . . . . . 55 Participation in Affiliate Lending Programs and Margin . . . . . . . . . . . . 55 Provision of Diversified Financial Services . . . . . . . . . . . . . . . . . . . . . . . 56 Activity by Merrill, Affiliates and Personnel . . . . . . . . . . . . . . . . . . . . . . 56 Covered Entities under the Volcker Rule . . . . . . . . . . . . . . . . . . . . . . . . . 57 Account Review and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57 Referral Arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 Financial Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 Funding and Operation of Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Enrolling Your Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Funding your Account and Contributions. . . . . . . . . . . . . . . . . . . . . . . . . 32 Holding Funds in your Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Withdrawals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Cash Balances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Your Responsibilities for Account Operation and Management. . . . . . 34 Terminating Enrollment in the Program . . . . . . . . . . . . . . . . . . . . . . . . . 34 Legal Matters and Related Notifications. . . . . . . . . . . . . . . . . . . . . . . . . 35 Tax Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Client and Financial Advisor Eligibility . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Program Minimums . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 All capitalized terms used in the Brochure are defined in the body of this Brochure and/or in the Glossary. Investment Advisory Program Brochure | 3 IAPB-032025 About Us and the Program Both Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) and Managed Account Advisors LLC (MAA), its Affiliate, offer investment advisory services under the Merrill Lynch Investment Advisory Program (Program or IAP) as discussed in this Brochure. Both MLPF&S and MAA are registered with the U.S. Securities and Exchange Commission (SEC) as an investment adviser and MLPF&S is registered as a broker dealer. Our parent company, Bank of America Corporation (BofA Corp.), through Bank of America, N.A. (BANA), BofA Securities, Inc. (BofAS) and other Affiliates, provides integrated investment services and is a leading banking institution for consumers, corporations and institutions. When we use the terms “Merrill,” “we,” “our” or “us” in this Brochure, we are generally referring to MLPF&S. We also use the terms “Merrill,” “we,” “our” or “us” to apply to both MLPF&S and MAA for those aspects and services of the Program that MLPF&S and MAA perform jointly. We also indicate where certain services are provided by MAA in its separate capacity. Both Merrill and MAA provide services under the Program in their capacity as a registered investment adviser under the Investment Advisers Act of 1940, as amended (Advisers Act). Our Services as an Investment Adviser and Relationship with You under the Program. You work with your dedicated personal Merrill financial advisor to determine if the Program is appropriate for you given your financial goals and circumstances. At Merrill, you can work with (1) a “Wealth Management Advisor,” “Private Wealth Advisor,” “Financial Advisor” or “Portfolio Advisor,” whom we refer to in this Brochure as an “Advisor” or (2) a “Merrill Financial Solutions Advisor” or “MFSA,” who, based on our internal polices, only offers specifically designated managed strategies under the Program. In this Brochure, we use the general term “financial advisors” to refer to both our Advisors and MFSAs. Certain services and investment solutions and products available under the Program are only provided by Advisors who meet certain qualifications. We provide a disclosure document called the “Form ADV Part 2B—Brochure Supplement,” which describes information about the financial advisor or financial advisors you are working with, their designation, role and the services they can provide, among other things. We can change our designations, roles and services for our financial advisors in our discretion and at any time. We also provide in your enrollment materials Form ADV Part 2B-Brochure Supplements for other Merrill investment professionals who provide portfolio management services for the investment strategies we offer. To obtain the investment advisory services and range of financial services and investment solutions under the Program as described in this Brochure (Program Services), you will enter into a written agreement with us (Agreement). The Agreement defines the scope of the investment advisory relationship with you and sets forth our obligations to you for the accounts that you enroll into the Program (each, an Account). This Brochure describes the Program Services we provide, the fees you will pay, our role and that of our personnel, our other business activities and financial industry affiliations and the economic and other benefits and arrangements that create conflicts of interest in certain situations. You will be provided a Program Report and account statements that identify those of your Accounts enrolled in the Program. Termination of an Account’s enrollment in the Program will end that investment advisory fiduciary relationship with respect to that Account and will typically cause the Account to be converted to, and designated as, a Merrill brokerage account. If you inform us that you wish to terminate the Agreement, we will terminate the enrollment of all Accounts enrolled in the Program which will end the investment advisor fiduciary relationship and typically will cause such Accounts to be converted to brokerage accounts. Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences which are described in our Client Relationship Summary on Form CRS (Form CRS) and in the Summary of Programs and Services, both of which are available at ml.com/relationships or upon request. In addition, these documents provide a summary of the other available investment advisory programs we offer. Certain aspects of these investment advisory programs are similar to the Program Services. Please refer to “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Under the Program, we are a fiduciary to you. Merrill and MAA each have certain fiduciary obligations in providing the Program Services. As a fiduciary, we will act in your best interest and will endeavor to provide you material facts and information relating to the Program Services. This Brochure is a key element in meeting this disclosure obligation. The fiduciary standards we aim to follow are established under the Advisers Act and, where applicable, state laws. In addition, for Retirement Accounts, we provide the Program Services as a “fiduciary” under Section 3(21) of the Employee Retirement Income Security Act of 1974 (ERISA) and under the Internal Revenue Code of 1986 (Code). For Retirement Accounts subject to ERISA that are discretionary accounts managed by us, we provide the relevant Program Services as an “investment manager” under Section 3(38) of ERISA. Generally, the Program is designed for clients who: • Want to implement an investment plan or strategy with the advice and guidance of their dedicated personal financial advisor. • Want access to an investment professional for the management of their investment assets. • Want discretionary investment management services. • Want to receive the Program Services, including target asset allocation and other on-going monitoring as described in this Brochure. • Anticipate trading activity in the Account, including rebalancing transactions. • Prefer the consistency of asset-based fee pricing instead of transaction-based pricing. While this Program is designed to help clients meet a variety of investment needs, it is not designed for clients who: • Plan to engage in little to no investment activity, including rebalancing transactions. • Maintain concentrated positions in securities and anticipate there being little to no selling or rebalancing activity over time. • Have an interest in maintaining consistently high levels of cash and/or cash alternatives in their Account for a prolonged period of time. • Want to engage in excessive trading and “day trading” activity or want to engage in a significant level of unsolicited trade activity. • Are not interested in target asset allocation and other on-going monitoring or complying with Program guidelines. Investment Advisory Program Brochure | 4 IAPB-032025Merrill Lynch Investment Advisory ProgramBrochure Overview of the Program Profiling Client Reviews Portfolio Target Asset Allocation Strategies & Investments Advice & Portfolio Management Your financial advisor provides on-going advice and guidance relating to the management of your investment portfolio, including rebalancing and adjusting your investments. Your dedicated financial advisor gets to know you on a personal and financial level and works with you to identify your financial goals and objectives. You and your financial advisor review, on at least on an annual basis, the status of your investment portfolio and strategies and your financial goals and objectives. You select the way you want your investment portfolio to be managed, choosing from a robust offering of investment solutions, including those from Merrill and third-party managers. You and your financial advisor work together on a personalized financial strategy based on your financial situation and your investment portfolio’s risk tolerance and time horizon. To take advantage of the Program Services, you must first enter into the Agreement. The Agreement will cover each account that that you choose to enroll in the Program. You are generally able to enroll subsequent accounts in the Program without signing a separate Agreement for those subsequent accounts; however, in certain circumstances we will require that you sign a separate Agreement or complete additional documentation. Y O U R In the Agreement, we agree to act as your investment adviser and agent and to provide the Program Services described in this Brochure and you grant to us the investment discretion and trading authority necessary to deliver the Program Services you select and agree to the terms and conditions of the Program. For your Accounts, Merrill will provide you with personalized investment advice and guidance through your dedicated financial advisor and the Program Services described in this Brochure. I I I For each Account, you will select how you want your assets to be managed in the Program in accordance with our available Program Strategy types. In addition, you can group one or more Accounts together into a group of Accounts (a Portfolio Group) for ongoing portfolio management to a selected Target Asset Allocation and for consolidated reporting. Under the Agreement, you are generally able to select or change certain Program Services with verbal instructions to your Advisor. R E L A T O N S H P W T H U S & O V E R V I The Program offers managed investment strategies of third-party managers and of Merrill as well as the ability to invest on a discretionary or client-directed basis. In addition, the Program offers the ability to invest in individual securities and other investment products, including equities, fixed income securities, mutual funds, exchange-traded funds (ETFs), closed-end funds, unit investment trusts (UITs), other pooled vehicles and those investments designated by us from time to time in our sole discretion as Alternative Investments. The Program allows you to manage your investment assets under our available Program Strategy types. E W O F T H E P R O G R A M The nature of the investment approach you take for the investment and management of the assets in your Account and the type of financial advisor with whom you have chosen to work will determine the investment solutions available for your Account. When you work with an Advisor, you have access to a full set of investment strategies managed by third-party investment managers and by Merrill and MAA investment management professionals. You can also delegate investment discretion for managing your investments to your Advisor or another Advisor and/or you can retain investment discretion to manage your investments while receiving advice and guidance from your Advisor. When you work with an MFSA, you have access to specifically designated managed investment strategies available through the Program. We charge a Program Fee for each Account which will be calculated separately for each Account. Each of your Accounts may be subject to a different Program Fee. The Program Fee you pay per Account will differ from that paid by other clients based on the scope and size of relationships and accounts, the complexity of the client’s needs, and the role, practice approach and qualifications of your financial advisor, as well as other factors. Apart from your Account’s initial Program Fee, your Program Fee is payable monthly in advance and generally will be calculated based on the value of the assets in your Account as of the last business day of the prior month. Unless otherwise agreed to between you and Merrill in writing, the Program Fee and any other fees payable under the Agreement will be deducted directly from your Account. Information about the Program Fee and rates applicable to each of your Accounts will be shown in a Program Report that we send to you upon Program enrollment and that we update for important information, including when you enroll any new Accounts, make certain changes to your Account or Portfolio Group and if changes are made to the Merrill Lynch Fee Rate component of the Program Fee. Please review the section “The Program Fee and Other Charges” carefully. By enrolling in the Program and paying the Program Fee, you have access to: • Investment advice and guidance services of your financial advisor and those services delivered through us. • Managed investment strategies from third-party investment managers or from Merrill and its Affiliates. • Investments in individual securities selected by you or, if you grant investment discretion, by your Advisor. • Certain incidental services, such as trading, execution and settlement for trading, custody, performance reporting and related account services. We will execute any transactions in your Account in accordance with our best execution obligations. We supervise the Program Services, our financial advisors and other personnel responsible for the Program in accordance with our obligations under the Agreement, the Program guidelines that we establish from time to time and the ethical standards we require. There are certain material relationships and conflicts of interest discussed in this Brochure, including those described in “Compensation, Conflicts of Interest and Material Relationships” and “Participation or Interest in Client Transactions and Conflicts of Interest” in Item 9. Please review these sections carefully before you make a decision to enroll an account in the Program. Details of the Program are provided throughout this Brochure. Investment Advisory Program Brochure | 5 IAPB-032025  I ITEM 4. SERVICES, FEES AND COMPENSATION Advice and Guidance Services Profiling and Setting a Target Asset Allocation. Your Advisor or MFSA will gather from you important financial and personal information that will be used as a basis for advice and guidance about how to manage your Account. You may have more than one Account enrolled in the Program. You may choose to organize your investments in a single Account or as a group of Accounts. We refer to that single Account and those grouped Accounts as a “Portfolio” or “Portfolio Group.” You have the option to create multiple Portfolios or Portfolio Groups. A grouping of accounts into a Portfolio Group may only be implemented with Accounts enrolled in the Program. For each Portfolio, your financial advisor will work with you to determine an appropriate Target Asset Allocation, which takes into account: (1) your risk tolerance for the Portfolio assets (your tolerance for potential loss of some or all of the assets in your Portfolio in exchange for greater potential returns) and (2) your time horizon (determined by how long you expect to invest in order to achieve your investment objectives). At Merrill, risk tolerance is expressed in three gradations: Conservative, Moderate and Aggressive and time horizon is segmented into the time spans of 0–1 Years, 1–5 Years, 5–10 Years, and 10+ Years. The risk tolerance and time horizon you designate for the Portfolio, along with other information, including your investment objectives, goals, liquidity and other preferences, are used to determine the types of investments and Program Strategies to recommend to you for your Portfolio. Any changes to your risk tolerance or time horizon may lead to a different recommended Target Asset Allocation and potential changes to the strategies and investments in a Portfolio. It is your responsibility to ensure that the information you provide is complete and accurate and to notify your financial advisor promptly of any changes so that your financial advisor will be better able to make appropriate recommendations. I Target Asset Allocation Categories. In general, the Target Asset Allocation categories we have established for the Program are: • Moderately Aggressive • Aggressive • Conservative • Moderately Conservative • Fixed Income-Focused • Alternative Investment-Focused • Moderate • Equity-Focused • Custom Allocation A description of each of these categories is in the Glossary under the term “Target Asset Allocation.” Each of these categories have associated asset class allocation ranges. The associated allocation ranges and our method of monitoring activity may change from time to time and without prior notice to you. Our more conservative Target Asset Allocations typically recommend a greater percentage of your assets be allocated to the fixed income and cash asset classes, rather than to the equity asset class. Our more aggressive Target Asset Allocations typically recommend a greater percentage of your assets be allocated to the equity and Alternative Investment asset classes, rather than to the fixed income and cash asset classes. N O T A C O L L A T E S S A T E G R A T A G N T A E R C D N A G N I L I F O R P O I L O F T R O P The Equity-Focused, Fixed Income-Focused and Alternative Investment-Focused Target Asset Allocation categories allow you to orient your Portfolio towards that particular type of asset class and obtain more significant exposure to that asset class than is suggested by the target asset allocation ranges that we have set in other Target Asset Allocation categories or be consistent with the asset allocation guidance and recommendations made by us through our Chief Investment Office (CIO). These Target Asset Allocations provide less diversification and therefore have a greater degree of risk than the other Target Asset Allocations. Under certain circumstances and at our discretion, you may establish a Custom Allocation which does not have to necessarily align with the target asset allocation ranges that we have set for our other Target Asset Allocation categories or be consistent with the asset allocation guidance and recommendations made by us through the CIO. Any such custom allocation will have degrees of risk. Monitoring Adherence to Target Asset Allocation. The assets comprising the Portfolio taken together should be aligned to the designated Target Asset Allocation for the Portfolio. On a periodic basis, we will monitor the assets in each Portfolio against the applicable Target Asset Allocation within certain parameters. If you create a Portfolio Group with multiple Accounts, we will monitor the assets in that Portfolio Group to the designated Target Asset Allocation within certain parameters. If there is a prolonged misalignment, you will be requested to take action in order to remain in the Program, including rebalancing, changing your investments or updating your risk tolerance or time horizon to fall within Program guidelines. Ability to Establish Multi-Client Portfolio Groups. As an additional feature of the Program, you may choose to group one or more of your Accounts with the accounts of other Program clients into one or more Portfolio Groups in order to pursue a common goal. For this grouping to be effective, each client in the multi-client Portfolio Group must execute a written letter of authorization that will set forth your and the other group members’ instructions on grouping and the terms and conditions associated with setting up a multi-client Portfolio Group. You continue to own the assets held in your Account within the multi- client Portfolio Group and none of the other clients in the Portfolio Group can make any changes to, or direct your Advisor to take any action in, your Account. Each of the Accounts in the multi-client Portfolio Group will incur its own fees, trading or other costs for activity occurring in the respective Account. We may terminate the ability to create or have in place multi-client Portfolio Groups at any time upon written notice to you. By setting up a multi-client Portfolio Group, you authorize us to share information about your included Account with the other clients participating in that Portfolio Group. We will not be responsible for any loss or expense arising out of the action of creating the multi-client Portfolio Group, the sharing of information or for any act (or failure to act) by you or the other clients with respect to any decisions, changes or instructions to be made or given for a multi-client Portfolio Group. Program Guidelines. We have established certain guidelines relating to the management of assets in the Program, including Target Asset Allocation guidelines, which are designed to help supervise and monitor on an on-going basis the activity in your Account or Portfolio Group. The Program guidelines change at our discretion or can be waived under certain circumstances for certain clients. In certain situations, you may be notified if your investment activity or holdings in an Account or a Portfolio Group deviate from our internal guidelines and will be requested to comply with these guidelines. If you decide not to take the requested action, we have the right to terminate the Account (or the Account that is part of a Portfolio Group, if applicable) from the Program. Taking this action will convert the Account to a brokerage or other account type. Our supervision and monitoring do not substitute for your own continued review of your Program assets and the performance of your investments in your Account or Portfolio Group. You are responsible for reviewing the Program communications, including performance reports, trade confirmations and periodic account statements we send to you. If you identify any discrepancies or inaccurate information, you should promptly report them to your financial advisor. Treatment of Cash Balances in your Account While enrolled in the Program and subject to Program guidelines, your Account will have an allocation to cash balances (cash allocation). This allocation can result from your and/or your Advisor’s decision to keep a cash balance for various purposes, such as your cash needs, market conditions or as a way to fulfill Investment Advisory Program Brochure | 6 IAPB-032025  your cash allocation target. If your Account invests in a managed investment strategy, the allocation can result from the investment manager’s decision to keep a cash balance for operational and/or investment purposes as part of the investment strategy. This decision is based on a number of factors, including the nature of the investment strategy being implemented, the types of investments being purchased for the strategy and the circumstances relating to the trading for those securities, market conditions as well as for trade execution facilitation, meeting operational contingencies and having funds available to pay the monthly fee charged for Program Services without generating trade activity in the Account. In certain circumstances, including periods of volatile or uncertain market conditions, the cash allocation can comprise all or a substantial portion of your Account assets based on, for example, concerns about the market or a decision to pursue a defensive investment strategy. Your Account’s uninvested cash balance is automatically swept with your consent to a cash sweep option for your Account under the terms of your underlying brokerage account agreement (Cash Sweep Program). The available automatic cash sweep options under the Cash Sweep Program vary based on the Merrill account type and other criteria, such as citizenship, residency status and jurisdictional restrictions. Not all Merrill account types have the same cash sweep option. Except as described below for trust management and certain qualified retirement plan account types, the only automatic cash sweep options currently available for Merrill account types eligible for enrollment in the Program are the Merrill Lynch Bank Deposit Program (MLBD Program), the International Bank Variable Rate Deposit Facility (IBVRD Facility) and, for retirement accounts, the Retirement Asset Savings Program (RASP). Non-U.S. citizens who are not residents of the United States have access to the MLBD Program or the IBVRD Facility. The MLBD Program, RASP and the IBVRD Facility provide for an automatic sweep of cash balances to bank deposits with BANA and other banks affiliated with us (Bank Affiliates). For certain qualified retirement plan account types eligible for enrollment in the Program (i.e., Retirement Cash Management Account and self-directed brokerage Accounts), the accountholder selects either: (1) the MLBD Program; (2) the Insured Savings Account Program (ISA Program), a bank deposit program with our Bank Affiliates and unaffiliated banks; or (3) certain money market mutual funds (money market funds). Certain other Merrill account types for qualified retirement plans eligible for enrollment in the Program only have the automatic cash sweep option of a money market mutual fund. The trust management account type (TMA) which is eligible for enrollment in the Program over which BANA provides various investment and trust-related services has its own automatic sweep options which include bank deposits at Bank Affiliates, the ISA Program and certain money market funds. Please refer to your account agreement and related disclosures for additional information regarding the automatic sweep options for your type of account. The Sweep Program Guide for Merrill Clients, which can be found on mymerrill.com, provides an overview of the automatic cash sweep options and how they work and a chart of automatic cash sweep options by Merrill account type. Please refer to your trust agreement and/or TMA Brochure for additional information regarding the automatic sweep options for your TMA Account. You can obtain a paper copy of these disclosures from your Advisor or MFSA. The current rates and yields for the cash sweep options are available at mymerrill.com and from your Advisor or MFSA. Any cash balances you hold as part of your Account assets can be invested in cash alternatives such as money market funds or in cash management investments (i.e., brokered certificates of deposit (brokered CDs), short-term Treasuries, fixed income securities). Your cash and cash alternatives in all Accounts, like other investments, are subject to the Program Fee (as discussed below). You can elect to hold any cash balances in an account that is not enrolled in the Program (i.e., a brokerage account or bank account) and avoid the Program Fee but you will not receive the Program Services with respect to cash held in an account that is not enrolled in the Program. We discuss the treatment of cash balance and other considerations relating to cash in various parts of this Brochure, including: (1) Item 4 at the sections “Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services,” “The Program Fee and other Charges—How the Program Fee is Charged,” and “Funding and Operation of Accounts—Cash Balances” and (2) Item 9 at the sections “Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Participation or Interest in Client Transactions and Conflicts of Interest—Cash Balances and the Cash Sweep Program.” Investment Strategy Services Available Overview and Program Strategy Types Your Advisor or MFSA will work with you to determine how to invest and manage the assets in your Account. The Program currently offers six types of Program Strategies which provide differing investment approaches or methods: Managed Strategy—selection for the Account of a single managed investment strategy (Style Manager Strategy) constructed by a third-party investment manager or by Merrill, MAA or a Merrill Affiliate. T H E Custom Managed Strategy—construction and implementation of a custom investment portfolio that combines Style Manager Strategies, mutual funds and/or ETFs and cash in the same Account. Premium Access Strategy—selection of an investment strategy for an Account constructed and implemented by a third-party investment manager or by Merrill or a Merrill Affiliate under the terms of a separate contract entered into directly between you and the investment manager (sometimes referred to as a dual contract strategy). P R O G R A M S T R A T E G Y Defined Strategy—investment portfolios of individual securities created and managed by your Advisor (or a designated Advisor) on a discretionary basis based on a specified investment approach for the Account. T Y P E S Personalized Strategy with Advisor Discretion—investments in individual securities determined by your Advisor based on your delegation of discretion to your Advisor for the Account. Personalized Strategy with Client Discretion—investments in individual securities with the advice and guidance from your Advisor where you retain investment authority. Investment Advisory Program Brochure | 7 IAPB-032025  The Program Strategies are generally differentiated by the way we deliver our advice to you and the investments we make available. If you wish to use multiple Program Strategies for your assets in the Program, you will be required to open a separate Account for each Program Strategy. Please note the following about the Program Strategy options: • If you work with an Advisor, you will be able to select from all the different Program Strategy types so long as your Advisor is eligible under our current internal policies. Certain Advisors may not offer, or be eligible to offer, all of the Program Strategy types or the full suite of investment securities and solutions available in the Program. • If you work with an MFSA, you will only be able to select the Managed Strategy option for your Account. In addition, not all Style Manager Strategies available in the Program can be offered to Accounts when working with an MFSA. • You select for your Account the type of Program Strategy that is designed to be most consistent with your investment objectives and approach. • You must meet the eligibility requirements to select the Premium Access Strategy option. • You select the ‘Authority’ type for your Account. ‘Authority’ refers to the authority to make certain investment and/or trading decisions with respect to the assets in your Account as described in this Brochure. You can retain investment discretion over your Account (Client Discretion Authority) or you can delegate to Merrill and an Advisor (and any members of the Advisor team) the Authority to exercise investment discretion over the investments in your Account and to take certain actions without prior notice to you (Advisor Discretion Authority). In addition, you may also select an investment strategy constructed and managed by an Advisor who is not your Advisor or part of your Advisor’s team and thus delegate Authority to that Advisor. • The following Program Strategy types have Client Discretion Authority in the following ways: (1) Managed Strategy, where you will select the Style Manager Strategy for your Account; (2) Custom Managed Strategy with Client Discretion, where you will select the Style Manager Strategy or Strategies, individual mutual funds and/or ETFs, and a cash allocation for your Account; (3) Premium Access Strategy, where you will select the PAS Style Manager Strategy for your Account; and (4) Personalized Strategy with Client Discretion, where you must authorize the purchase and sale of individual securities for your Account. • The following Program Strategy types have Advisor Discretion Authority in the following ways: (1) Custom Managed Strategy with Advisor Discretion, where your Advisor will select the Style Manager Strategies, individual mutual funds and/or ETFs, and a cash allocation for your Account; (2) Defined Strategy where your Advisor will select the investments for your Account consistent with a specified investment strategy; and (3) Personalized Strategy with Advisor Discretion, where your Advisor will select the investments for your Account. • The Program provides access to different types of investment securities but not all investment securities are available in each Program Strategy type. • The assets in your Portfolio can be allocated to cash at various amounts for one or more investment and/or operational purposes at the same or different times as described throughout this Brochure. • We determine the manner and extent to which Program Strategy types, Style Manager Strategies, PAS Style Manager Strategies and different investment securities and investment solutions are made available to clients through the Program, including when they may no longer be offered. Under certain circumstances, we determine what strategies or securities will be used as replacement strategies or securities as described below in the descriptions of the various Program Strategy types. • We may add to or make changes to the Program Strategy types available in the Program at our discretion and, under certain circumstances, we may take action to change the Program Strategy type for your Account prior to receiving your authorization. In such case, we will endeavor to choose a replacement Program Strategy type with an investment style that is consistent with the investment strategy being replaced. The replacement may be subject to higher fees than you had been paying. If you do not instruct us to the contrary, your continued participation in the Program after receiving written notice of any such replacement or other action will be your consent to the action. We will take this outlined action regardless of the Authority that you have chosen for your Program Strategy. • Your Advisor may offer to different clients the same or similar investment strategy and investment solutions available in the Program depending on such clients’ preferences, investment restrictions, tax considerations and other factors and the Advisor may agree to charge a different Program Fee for the Program Services. Ability to Request Reasonable Investment Restrictions Other than for an Account that has selected the Premium Access Strategy type, you may request that we impose certain investment restrictions on the management of the assets in your Account. You may request to have different investment restrictions applicable to each of your Accounts. For a restriction to be acceptable under the Program, it must first be determined to be “reasonable” by us (a Reasonable Investment Restriction). If accepted, the Reasonable Investment Restrictions that Merrill or MAA are responsible for managing or implementing in your Account will be included in the Program Report or other periodic Program communications and will be applied until: (1) you take action to change, withdraw or waive the restriction; (2) we determine that it is no longer a Reasonable Investment Restriction based on factors we deem relevant in our discretion, including for example, the level of the security holding percentage in the Style Manager Strategy; or (3) we are no longer able to implement the restriction in our systems due to changes in our systems or changes in the security identifier or symbol, corporate action events, or otherwise. We reserve the right to modify our practices regarding investment restrictions in our sole discretion at any time without notice. Further, we reserve the right to deem any requested investment restriction to be unreasonable and to not accept the requested investment restriction. If one or more investment restrictions are determined to be unreasonable, the restriction will not be applied and you should consider whether to remain in the Program or consider other investment strategies. Please note that Reasonable Investment Restrictions will not apply to securities that are part of a registered or unregistered investment company, including a mutual fund, money market fund, ETF, closed-end fund, UIT, non-traditional mutual fund or ETF (each, an NTF), Alternative Investment Fund (as defined below) or any other type of pooled vehicle (each, a Fund), or that are part of an annuity product. Along these lines, a client’s Reasonable Investment Restriction other than with respect to the purchase of a particular Fund itself would likely not have any practical effect on an Account comprised primarily of Funds or those annuities that provide for Fund investments. The termination or removal of an Account from the Program will terminate Reasonable Investment Restrictions, and such Restrictions will not be applied to the resulting brokerage account or other account outside of the Program. If you authorize a solicited or unsolicited purchase of a security covered by a Reasonable Investment Restrictions, your trade authorization will be considered a waiver by you of the Reasonable Investment Restriction for that trade and security in that Account. Investment Advisory Program Brochure | 8 IAPB-032025 Implementing certain Reasonable Investment Restrictions result in securities in your Account being sold which could result in taxable events. If you elect to impose Reasonable Investment Restrictions, you accept any effect that such Reasonable Investment Restrictions may have on the investment performance and diversification of your Account. The performance of an Account with a Reasonable Investment Restriction will differ from, and may be lower than the performance of, an Account without such restrictions. In addition, your decision to impose a Reasonable Investment Restriction that alters the allocation of any Style Manager Strategy or strategy being implemented in a Defined Strategy or that results in a replacement security exposes you to additional (and potentially unforeseeable) risks that are inconsistent with the objective of your investment strategy. For Accounts with the Managed Strategy and Custom Managed Strategy Type. Depending on the Style Manager Strategy selected, MAA or the Style Manager for a discretionary Style Manager Strategy or for a Direct Indexing/TEM Style Manager Strategy that has been selected for the Account will determine whether a restriction request is reasonable and how to allocate investments based on an accepted Reasonable Investment Restriction. MAA will allocate the assets that would have been invested in the security impacted by the Reasonable Investment Restriction in one of the following ways: (1) pro- rata across other investments held in the Portfolio or that are part of the Style Manager Strategy; (2) using one or more replacement securities which could include ETFs; and (3) remaining uninvested in cash. You can request that MAA or a discretionary Style Manager implement available investment screens to restrict investments (1) with a specific identifier (such as a security number or ticker symbol), (2) in certain security types, (3) in companies in certain sectors or industries, (4) in companies that do not meet certain environmental, social and governance (ESG) characteristics, and/or (5) in fixed income securities that have certain credit ratings and maturities. MAA relies on analyses by third-party providers of investment screens, including those offering sector and industry classification and industry grouping data and ESG screens. Neither MAA nor Merrill guarantee or validate third-party screening or processes nor do we conduct an independent review of the underlying nature of the companies’ businesses or ESG characteristics. The screenings and processes to implement category investment restrictions are not absolute, may change at any time and could result in the Portfolio holding investments in companies that derive revenue from the restricted category. MAA and the Style Manager may use different vendors and/or providers in considering whether restrictions requested by clients are reasonable. For Accounts with the Defined Strategy and Personalized Strategy Types. Your Advisor managing the Account with these Program Strategy types will make the determination of whether a restriction request is reasonable and how to allocate investments based on an accepted Reasonable Investment Restriction. Please note the ability to request certain types of investment restrictions or screens is limited for Accounts that have these Program Strategy types. Your Advisor may not be able to implement specific types of investment restrictions or utilize the investment screens. If you authorize a solicited or unsolicited purchase of a security covered by a Reasonable Investment Restriction, your trade authorization will be considered a waiver by you of the Reasonable Investment Restriction for that trade and security in that Account. For Accounts with the Premium Access Strategy Type. You may request that the investment manager with whom you have directly entered into a separate contract for the provision of investment management and advisory services apply certain investment requirements and restrictions, instructions or guidelines or that they follow an investment policy statement (IPS). We are not responsible for implementing any such restriction requests. See “Premium Access Strategy as a Program Strategy Type” below. Managed Strategy as a Program Strategy Type Nature of the Program Strategy and Investment Options. With this Program Strategy type, you have the ability to select a single managed investment strategy (Style Manager Strategy) for your Account. A Style Manager Strategy, which is constructed and/or managed by an investment manager (Style Manager), consists of individual securities, other Style Manager Strategies and a cash allocation. Both M A N A G E D S T R A T E G Y Advisors and MFSAs can work with Accounts that have selected this Program Strategy type but MFSAs can only offer a subset of the Style Manager Strategies available. Each Style Manager Strategy available in the Program has been identified by us and approved for the Program. As a general matter, we decide whether to make available or remove particular Style Manager Strategies from the Program based on a variety of factors. These factors include client needs, available investment styles, platform capacity and client demand. We also consider the outcome of due diligence and evaluation reviews conducted by our CIO or conducted by third parties subject to our supervision. For more information, see “Item 6 Portfolio Manager Selection and Evaluation—Selection and Review of Investment Strategies and Funds Available in the Program.” As of March 2025, there are over 900 separate Style Manager Strategies available in the Program. They cover equity, fixed income and hybrid investment strategies and styles. Approximately 385 of these Style Manager Strategies are available to you when you work with an MFSA. The Style Manager Strategies available under the Program and other information can be found in the Style Manager Strategy List, a document accessible at mymerrill.com/ADV/ materials or available from your Advisor or MFSA. The Style Managers, the Style Manager Strategies and the eligibility requirements relating to offering these Style Manager Strategies are subject to change in our discretion at any time without notice. The Style Manager of the Style Manager Strategy constructs, implements and/or manages its respective managed portfolios and determines the asset classes, security holdings and weightings in the Style Manager Strategy, including any cash allocation. The cash allocation is held as a cash balance and/or invested in cash alternatives such as money market funds as determined by the Style Manager. If no action is taken by a Style Manager, cash balances will automatically be swept under the Cash Sweep Program. The cash allocation can be higher at certain times depending on the nature of the Style Manager Strategy, the asset allocation, the investment determinations, rebalancings, market conditions and the Style Manager’s cash management approach and market view and concerns. Some types of Style Manager Strategies include investments that take an extended period of time to purchase due to the type of security, market availability and selection criteria. Until invested, the cash for these investments is typically automatically swept under the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the Style Manager as a temporary investment pending purchase of the individual security. For more information on the treatment of cash balances, see “Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking Related Services“ and “Funding and Operation of Accounts—Cash Balances” in this Item 4. You select the Style Manager Strategy for your Account. Any changes to the Style Manager Strategy for your Account will require your consent because you retain Client Discretion Authority. In the future, Merrill may offer the Managed Strategy type with Advisor Discretion Authority. When available, by selecting this option, you would authorize us or your Advisor to change the Style Manager Strategy for the Account without your consent. Style Managers. A Style Manager can be a third-party investment manager, Merrill, a Merrill Affiliate, or an entity in which BofA Corp. or its Affiliates have a material ownership interest (a Related Entity). Where the Style Manager Strategy is managed or constructed by Merrill, a Merrill Affiliate or a Related Investment Advisory Program Brochure | 9 IAPB-032025  Entity, it is referred to as a Related Style Manager Strategy. Each third-party Style Manager files its own Form ADV brochure or has an equivalent document that describes their strategy and role and makes available Form ADV Part 2B-Brochure Supplements for its investment professionals providing portfolio management services for the Style Manager Strategies. We make these materials accessible to you at mymerrill.com/ADV/materials. A third-party Style Manager will not ordinarily know your identity and you will not enter into a separate written investment advisory agreement with a Style Manager in order to select a Style Manager Strategy for your Account. Under the Agreement, you have authorized and directed MAA to provide any necessary information about you to a Style Manager as needed to provide the Program Services to you in the Program. Depending on the particular Style Manager Strategy, the Style Manager can: • Provide investment recommendations to MAA in the form of model portfolios and investment guidelines and instructions (a model-based Style Manager Strategy). • Manage and implement its recommendations for the investment portfolio on a full or partial basis (a Discretionary Style Manager Strategy). • Manage a direct indexing or tax efficient management investment strategy by exercising full investment discretion and providing MAA with its investment directions which involves investing in a selected market index, engaging in opportunistic selling of securities with a loss, investing proceeds in strategy-aligned replacement securities and taking other tax loss harvesting approaches (a Direct Indexing/TEM Style Manager Strategy). A Style Manager can have Style Manager Strategies in our Program that are model-based Style Manager Strategies, discretionary Style Manager Strategies and/or Direct Indexing/TEM Style Manager Strategies. A Style Manager of a discretionary Style Manager Strategy is sometimes referred to as a Discretionary Manager and a Style Manager of a Direct Indexing/TEM Style Manager Strategy is sometimes referred to as a Direct Indexing/TEM Style Manager. A Style Manager can also provide investment managed strategies that are offered as PAS Style Manager Strategies. See “Premium Access Strategy as a Program Strategy Type” below. Types of Style Manager Strategies. For a model-based Style Manager Strategy, the Style Manager provides advisory services under an agreement with MAA by furnishing to MAA investment recommendations for the Style Manager Strategy in the form of model portfolios or other investment guidelines and/or instructions. MAA will generally implement the Style Manager’s recommendations without change, subject to the application of any Reasonable Investment Restrictions which MAA has determined to accept as reasonable, cash commitments and other operational or investment considerations, including frequency of rebalancing. MAA may determine, in light of operational or investment considerations in its sole discretion, to deviate from the model portfolio on a limited basis (i.e., to select another security or increase the cash allocation within a model portfolio). By selecting a model-based Style Manager Strategy, as provided in the Agreement, you grant MAA investment discretion and trading authority for investments occurring in that Style Manager Strategy. Through this authority, MAA has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. This authority will remain in place until we have received and accepted instructions to either change the Style Manager Strategy or terminate the Account from the Program. Certain Style Managers with model-based Style Manager Strategies may place trades themselves after consulting with MAA. In this case, you grant the Style Manager trading authority on a partial basis for certain investments. In these situations, the Style Manager is considered a Discretionary Manager for trading authority only for the Account. For a Discretionary Style Manager Strategy, by agreement with the Discretionary Manager, MAA arranges for investments to be implemented within your Account directly by the Discretionary Manager. The Discretionary Manager executes trades through Merrill or a Merrill Affiliate or through a broker or dealer other than Merrill or a Merrill Affiliate (an Unaffiliated Trade Counterparty). MAA does not exercise investment or trading discretion or responsibility for implementing investment or trade execution decisions other than implementing any Reasonable Investment Restrictions in your Account. By selecting a Style Manager Strategy with a Discretionary Manager for an Account, as provided in the Agreement, you grant the Discretionary Manager investment discretion and trading authority for investments occurring in the Account. Through its trading authority, the Discretionary Manager has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. This authority will remain in place until we have received and accepted instructions to either change the Style Manager Strategy or terminate the Account from the Program. Certain Style Managers will respond to requests for customization such as state specific or state preference, credit quality maturity or duration and sector and employ those on a best efforts basis and subject to certain limitations as described in the Style Manager Strategy Profile. MAA is not responsible for implementing any such customization requests. The Discretionary Manager has the authority to determine whether a requested restriction is reasonable for their Discretionary Style Manager Strategy and MAA and the Discretionary Manager may use different vendors and/or providers in considering whether restrictions requested by clients are reasonable. For a Direct Indexing/TEM Style Manager Strategy, the Direct Indexing/TEM Style Manager provides to MAA its investment decisions and related transaction orders that it determines meets the objective of its Direct Indexing/TEM Style Manager Strategy. By selecting this type of managed strategy, as provided in the Agreement, you grant the Style Manager investment discretion for investments and you grant MAA full trading authority for implementing the investment directions of the Style Manager. Through this authority, MAA has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets without any prior notice. This authority will remain in place until we have received and accepted instructions to either change the Direct Indexing/TEM Style Manager Strategy or terminate the Account from the Program. MAA will implement any Reasonable Investment Restrictions accepted by the Direct Indexing/TEM Style Manager as reasonable and will manage cash commitments and other considerations within the Account. Any tax efficient management activities or loss harvesting that takes place in the Direct Indexing/TEM Style Manager Strategy will only take into consideration the investments and trading activity in the Account holding the Direct Indexing/TEM Style Manager Strategy. There are other risks and limitations associated with these types of Style Manager Strategies. See “Item 4 Tax Matters” below and the description of the Direct Indexing/TEM Style Manager Strategy in the respective Profile. Use of Manager-Related Funds in a Style Manager Strategy. A Style Manager may construct or provide model recommendations for a Style Manager Strategy that utilizes Funds. These Funds may include those that are sponsored or advised by the Style Manager or its Affiliates (Manager-Related Funds). The Style Manager typically views certain types of Manager-Related Funds it includes in the Style Manager Strategy as an integral part of its investment strategy and that there are no appropriate substitutions that can be utilized as replacements. Therefore, MAA implements the investment advice from the Style Manager as to the inclusion of these types of Manager-Related Fund in model-based Style Manager Strategies without change other than as a result of withdrawal requests and rebalancing. Merrill does consider whether the Style Manager Strategy uses these types of Manager-Related Funds as one of Investment Advisory Program Brochure | 10 IAPB-032025 the factors in deciding whether to make available or remove particular Style Manager Strategies from the Program. Note that these Manager-Related Funds have no internal advisory or distribution fees (but do have certain ongoing expenses) and may not be held outside of the particular Style Manager Strategy. Style Manager Strategy Fees. Generally, you will pay a Style Manager Fee as part of your Program Fee, which will be used to compensate the Style Manager. Any fee paid to a Style Manager will vary depending on, among other factors, the particular investment style or approach and the type of securities included in the investment strategy. The Style Manager Strategy List (accessible at mymerrill.com/ADV/materials and available from your Advisor) provides detail of the Style Manager Fees associated with the Style Manager Strategies. You can invest in Related Style Manager Strategies that have a Style Manager Fee and those that do not. We reserve the right, with prior written notice, to charge a Style Manager Fee for any Related Style Manager Strategies. There are Merrill-constructed Style Manager Strategies that contain an allocation to a third-party Style Manager Strategy or a Related Style Manager Strategy where you will be charged a pro rata portion of the Style Manager Fee rate that is payable to the third-party Style Manager or Related Style Manager. In addition, certain third-party Style Managers have Style Manager Strategies for which they do not charge a Style Manager Fee. These Style Managers allocate a significant percentage of their Style Manager Strategies to investment strategies, mutual funds and/or ETFs for which they and/or their Affiliates serve as the investment manager and as to which they (or their Affiliates) receive compensation that presents a conflict of interest for the Style Manager. Where a Style Manager receives a Manager Fee and utilizes a Manager-Related Fund that is charged a fund management fee by the Style Manager or its Affiliate, Merrill will work with the Style Manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Manager Fee. See “Item 4 Funding and Operation of Accounts— Holding Funds in your Account” and “Compensation, Conflicts of Interest and Material Relationships—Affiliated Investments of a Style Manager or a PAS Manager” in Item 9. Style Manager Strategy Profiles. We make available information about each Style Manager Strategy through a document known as a “Profile.” The Profile will describe the relevant objectives, styles and risks of the particular strategy. It will also describe the roles of the Style Manager and MAA in implementing the Style Manager Strategy. The Profile will typically include performance history and data as indicated in the Profile. For model-based and Direct Indexing/ TEM Style Manager Strategies that are implemented by MAA, the Profile will include actual composite performance data developed by MAA in its implementation of the Style Manager Strategy. Where the MAA composite data is not available in order to present ten years of performance history, the Profile typically includes available composite performance data provided by the Style Manager related to its implementation of the Style Manager Strategy with Program Accounts and/or non-Program accounts that the Style Manager manages. For Discretionary Style Manager Strategies, the Profile will include its performance history and data provided to Merrill by the Discretionary Manager. Style Managers have the obligation to establish and maintain each Style Manager Strategy in the manner generally described in the then-current Profile and to provide us notice on a timely basis of any changes made. We cannot guarantee the accuracy or consistency of the information contained in the Profiles but we obtain periodic confirmations from the Style Managers to help us confirm they continue to be materially accurate and complete. MAA’s Role and Authority. MAA has authority to make certain investment and trading decisions including: • Implementing, as applicable, the model-based recommendations or other investment guidelines and/or instructions of the Style Manager for a model- based Style Manager Strategy. • Implementing investment decisions and related trade orders for Direct Indexing/TEM Style Manager Strategies as directed by the Style Manager. • Processing all contributions including initial and any subsequent cash deposited in the Account, withdrawal requests and Account terminations. • Periodically rebalancing Accounts for a Style Manager Strategy as further described below. • Implementing your Reasonable Investment Restrictions, if any, described in the section “Ability to Request Reasonable Investment Restrictions.” • Implementing your tax-selling instructions (if any) where acceptable to MAA, as further described in the section “Tax Matters.” • Implementing TEM Overlay Services if this service has been selected by you for the Account as described in the section “Optional Account Services”. Merrill and MAA are authorized and directed by you to sell promptly any investments you contribute that are not eligible or not acceptable for a Program Service or a Style Manager Strategy. Certain Style Manager Strategies have target allocations and are subject to automatic rebalancing on a periodic basis. Others are dynamically managed and are not subject to periodic rebalancing in the same manner. In light of other considerations in an Account, MAA can effect rebalancing and other transactions even though they may generate tax liabilities, including short-term taxable income. In its discretion, MAA may decide not to process certain rebalancing transactions. Delays in the processing of any rebalancing activities that MAA undertakes can occur from time to time, based on, among other things, market conditions, illiquid securities or those with limited subscription and redemption schedules, as well as the availability of Funds and other factors. MAA arranges for trades to be executed through Merrill or a Merrill Affiliate and may arrange for trades to be executed through an Unaffiliated Trade Counterparty. In its discretion and subject to legal requirements, MAA may utilize its Affiliates and third party vendors for investment, trading and administrative support. MAA generally takes necessary actions consistent with implementing a Style Manager Strategy, including for any investments subject to regulatory limitations and restrictions and related internal policies applicable to us and our Affiliates’ overall investment activities described further in the section “Activity by Merrill, Affiliates and Personnel.” Replacing a Style Manager Strategy. Changes to a previously selected Style Manager or Style Manager Strategy can occur due to: (1) your instruction to replace a Style Manager Strategy or (2) Merrill or a Style Manager closing a Style Manager Strategy or terminating a Style Manager from the Program for any reason. Where Merrill determines to close a Style Manager Strategy to new investments and/or additional contributions or otherwise require a Style Manager Strategy held by investors to be replaced, Merrill may (1) replace the identified Style Manager Strategy with another Style Manager Strategy selected by us; (2) maintain current positions in the identified Style Manager Strategy and invest any new contributions and sale or redemption proceeds in a replacement Style Manager Strategy selected by us; and/or (3) maintain in cash any new contributions or sale or redemption proceeds relating to the identified Style Manager Strategy until a replacement is chosen by us or you direct us to invest in an alternative Style Manager Strategy. MAA is responsible for implementing our decisions and related actions. Investment Advisory Program Brochure | 11 IAPB-032025 If we determine to replace the identified Style Manager Strategy, we will endeavor to choose a replacement with an investment style that is consistent with the identified Style Manager Strategy. The replacement may be subject to higher fees than you had been paying. If you do not instruct us to the contrary, your continued participation in the Program after receiving written notification of any such replacement or other action will be your consent to the action. If you hold the identified Style Manager Strategy, we generally will provide you with notice of any discontinuation, closing or replacement event prior to it taking place. We, however, may provide you with notice of such event after we have already taken action. Having the flexibility to act quickly helps us take action where we believe the replacement and its timing are in clients’ best interest. Registered Fund Prospectus Delivery. When a fund that is registered under the Investment Company Act of 1940 (Registered Fund) is purchased for an Account that has selected the Managed Strategy, the firm with discretionary Authority in connection with managing the Account (which could be either Merrill, MAA, a Discretionary Manager or a Direct Indexing/TEM Style Manager, as relevant) is authorized to receive the Registered Fund prospectus in lieu of it being automatically delivered to you. This is because by choosing a Style Manager Strategy, you grant discretionary authority relating to the investments in your Account and authorize such delivery on your behalf in the Agreement. If you would like a copy of the Registered Fund prospectus, you may obtain one by contacting your financial advisor who will arrange for it to be sent to you free of charge. Notwithstanding the foregoing, Merrill may continue to send the Registered Fund prospectus to you in its sole discretion. Custom Managed Strategy as a Program Strategy Type Nature of the Program Strategy and Investment Options. For a Custom Managed Strategy, you can group one or more Style Manager Strategies, mutual funds, ETFs and/or a cash allocation together in a single Account. We may add or change the types of securities that can be grouped in a Custom Managed Strategy in our discretion. The Style Manager Strategies, mutual funds and ETFs as well as the eligibility rules relating to this Program Strategy type are subject to change in our discretion at any time without notice. We may decide to discontinue offering a Style Manager Strategy and/or close an investment product to new investments and/or additional contributions from existing investors and you will not necessarily be provided with prior notice of any such discontinuation or termination. MFSAs are not eligible to offer this Program Strategy type. C U S T O M M A N A G E D S T R A T E G Y The information in “Managed Strategy as a Program Strategy Type” above applies to Style Manager Strategies that can be selected for this Program Strategy. The Style Manager Strategies and their minimum investments are covered in the Style Manager Strategy List (accessible at mymerrill.com/ADV/ materials and available from your Advisor). Direct Indexing/TEM Style Manager Strategies and PAS Style Manager Strategies are not eligible to be part of a Custom Managed Strategy. You will pay the applicable Style Manager Fee for the Style Manager Strategy component of your Custom Managed Strategy. See “The Program Fee and Other Charges—Style Manager Fee Component of the Program Fee” in this Item 4 for more information. A Custom Managed Strategy can also consist of mutual funds and ETFs or in combination with Style Manager Strategies. The Style Manager Strategies, mutual funds and ETFs that may comprise a Custom Managed Strategy have been identified by us and approved for inclusion in the Program. As a general matter, we decide whether to include or to remove particular Style Manager Strategies, mutual funds and ETFs for investment in the Program based on a variety of factors, including client needs, available investment styles, platform capacity and client demand. For mutual funds and ETFs, we also consider the outcome of due diligence and evaluation reviews conducted by the CIO or conducted by third parties subject to our supervision. For more information, see “Item 6 Portfolio Manager Selection and Evaluation—Selection and Review of Investment Strategies and Funds Available in the Program.” A Custom Managed Strategy can be constructed by you or your Advisor to have a cash allocation for investment purposes. It will include at a minimum an allocation to cash for operational and implementation purposes. The cash allocation is held as a cash balance and/or invested in cash alternatives available for your Account such as money market funds. If no action is taken by you or your Advisor, cash balances will be automatically swept under the Cash Sweep Program. The cash allocation can be higher at certain times depending on the nature of the investment approach, the asset allocation, the investment determinations, rebalancings, market conditions and your or your Advisor’s cash management approach and market view and concerns. For more information on the Cash Sweep Program and cash balances, see ““Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services“ and “Funding and Operation of Accounts—Cash Balances” in this Item 4. Investment Discretion and Trading. You can select the Custom Managed Strategy with Advisor Discretion as the Authority type. This is where you delegate the discretion to Merrill through your Advisor. Your Advisor selects the Style Manager Strategy or Strategies (which can include a Related Style Manager Strategy), mutual funds, ETFs and/or cash and cash alternatives, assigns a corresponding allocation percentage (including as to the cash allocation) and determines the rebalancing frequency. Any changes will not require your consent, because by choosing this Program Strategy type, you grant to Merrill and MAA the Authority to select and implement these investment decisions consistent with your investment objective. You may also select the Custom Managed Strategy with Client Discretion as the Authority type. This is where you retain the discretion as to certain actions. With the assistance of your Advisor, you select with the investments (Style Manager Strategies, mutual funds and/or ETFs) and/or cash and cash alternatives that are part of the Custom Managed Strategy, assign a corresponding allocation percentage (including as to the cash allocation) and determine the rebalancing frequency. Any change will require your consent because you retain the investment Authority. MAA’s Role and Authority. MAA has authority to make certain investment and trading decisions including: • Implementing, as applicable, the model-based recommendations or other investment guidelines and/or instructions of the Style Manager for a model- based Style Manager Strategy. • Processing all contributions (including initial and any subsequent cash deposited in the Account), withdrawal requests and Account terminations. • Periodically rebalancing Accounts as described further below. • Implementing your Reasonable Investment Restrictions, if any, as described further in the section “Ability to Request Reasonable Investment Restrictions.” • Implementing your tax-selling instructions (if any) where acceptable to MAA, as described further in the section “Tax Matters.” • Implementing TEM Overlay Services if this service has been selected by you for the Account as described below in the section “Optional Account Services”. Merrill and MAA are authorized and directed by you to sell promptly any investments you contribute that are not eligible or not acceptable for a Program Service or a Style Manager Strategy. Investment Advisory Program Brochure | 12 IAPB-032025  Certain Style Manager Strategies have target allocations and are subject to automatic rebalancing on a periodic basis and others are dynamically managed and are not subject to rebalancing in the same manner. MAA rebalances an Account in a Custom Managed Strategy approximately to the selected allocation among the components and at the frequency selected by you or your Advisor depending on the Authority type. In addition, at the component level, certain Style Manager Strategies have target allocations and are subject to rebalancing on a periodic basis while other Style Manager Strategies are dynamically managed and are not subject to periodic rebalancing in the same manner. In light of other considerations in an Account, MAA can effect rebalancing and other transactions even though they may generate tax liabilities, including short-term taxable income. In its discretion, MAA may decide not to process certain rebalancing transactions. In addition, delays in the processing of any rebalancing may be caused by market conditions, illiquid securities, securities with limited subscription and redemption schedules, as well as the availability of Funds and other factors. MAA arranges for trades to be executed through Merrill or a Merrill Affiliate and may arrange for trades to be executed through an Unaffiliated Trade Counterparty. In its discretion and subject to legal requirements, it may utilize its Affiliates and third party vendors for investment, trading and administrative support. MAA generally takes necessary actions consistent with implementing an Account’s allocation and rebalancing and a Style Manager Strategy component, including for any investments subject to regulatory limitations and restrictions and related internal policies applicable to us and our Affiliates’ overall investment activities described further in the section “Activity by Merrill, Affiliates and Personnel.” Replacing a Style Manager Strategy, Mutual Fund or ETF that is Part of the Custom Managed Strategy. Changes to a previously selected Style Manager Strategy, mutual fund or ETF can occur due to: (1) your instruction to replace a Style Manager Strategy, mutual fund or ETF; (2) Merrill or a Style Manager or fund manager closing a Style Manager Strategy, mutual fund or ETF for any reason; or (3) where the Custom Managed Strategy is with Advisor Discretion, your Advisor replacing a Style Manager Strategy, mutual fund or ETF. Where Merrill determines to close a Style Manager Strategy, a mutual fund or ETF to new investments and/or additional contributions or otherwise require a particular Style Manager Strategy, mutual fund or ETF to be replaced, Merrill may (1) replace the identified Style Manager Strategy, mutual fund or ETF with another Style Manager Strategy, mutual fund or ETF selected by us; (2) maintain current positions in the identified Style Manager Strategy, mutual fund or ETF and invest any new contributions and sale or redemption proceeds in a replacement Style Manager Strategy, mutual fund or ETF selected by us; and/or (3) maintain in cash any new contributions and sale or redemption proceeds for the identified Style Manager Strategy, mutual fund or ETF until a replacement is chosen by us or you direct us to invest in an alternative Style Manager Strategy, mutual fund or ETF. MAA is responsible for implementing our decisions and related actions. If we determine to replace the identified Style Manager Strategy, mutual fund or ETF, we will endeavor to choose a replacement with an investment style that is consistent with the identified Style Manager Strategy, mutual fund or ETF being replaced. The replacement may be subject to higher fees than you had been paying. If you do not instruct us to the contrary, your continued participation in the Program after receiving written notification of any such replacement or other action will be your consent to the action. We will take this outlined action regardless of the Authority that you have chosen for your Program Strategy. If you have selected the Custom Managed Strategy with Client Discretion to apply to your Account, we generally will provide you with notice of any discontinuation, closing or replacement event prior to it taking place; however, it is possible that we will provide you with notice of such event after we have already taken action. I Registered Fund Prospectus Delivery. Where you have selected a Custom Managed Strategy with Advisor Discretion, when an eligible Registered Fund is purchased, the firm with discretionary Authority relating to that investment (which could be either Merrill, MAA, a Discretionary Manager, or a Direct Indexing/TEM Style Manager, as relevant) is authorized to receive the Registered Fund prospectus in lieu of it being automatically delivered to you. This is because by choosing this Program Strategy type, you grant discretionary authority relating to the investments in your Account and authorize such delivery on your behalf in the Agreement. If you would like a copy of the Registered Fund prospectus, you may obtain one by contacting your Advisor who will arrange for it to be sent to you free of charge. Notwithstanding the foregoing, Merrill may continue to send the Registered Fund prospectus to you in its sole discretion. Where you have selected a Custom Managed Strategy with Client Discretion, you retain discretionary Authority to select and implement the investments in the Account, including Registered Funds. Therefore, we will arrange for you to receive the relevant Fund prospectus and the foregoing delivery approach does not apply. P R E M U M A C C E S S Premium Access Strategy as a Program Strategy Type S T R A T E G Y Nature of the Program Strategy. This Program Strategy type is a dual contract approach to selecting an investment strategy and management of the Account. You must meet certain eligibility requirements to be able to select this Program Strategy type for your Account. Client eligibility and minimum investment requirements are established by Merrill and the PAS Manager in their discretion and can change from time to time. MFSAs are not eligible to offer this Program Strategy type. A PAS Style Manager Strategy, which is constructed and managed by an investment adviser (PAS Manager), consists of specific securities, other managed investment strategies and a cash allocation. As of March 2025, there are over 100 PAS Style Manager Strategies available in the Program. The Style Manager Strategy List (accessible at mymerrill.com/ADV/materials and available from your Advisor) includes the PAS Style Manager Strategies. The PAS Style Manager Strategies include those that are characterized as Direct Indexing/TEM Strategies. Certain PAS Style Manager Strategies may be the same as or substantially similar to other Style Manager Strategies that can be selected in the Program or managed strategies in other Merrill investment advisory programs. Depending on the PAS Manager Rate that you agree to with the PAS Manager, the PAS Manager Rate may be higher or lower than the rate charged to access those other Style Manager Strategies or managed investment strategies. Each PAS Style Manager Strategy available in the Program has been identified by us and approved for the Program. As a general matter, we decide whether to make available or remove a particular PAS Style Manager Strategy from the Program based on a variety of factors. These factors include client needs, available investment styles, platform capacity and client demand. We also consider the outcome of due diligence and evaluation reviews conducted by the CIO or conducted by third parties subject to our supervision. For more information, see “Item 6 Portfolio Manager Selection and Evaluation—Selection and Review of Investment Strategies and Funds Available in the Program.” A PAS Manager constructs, implements and manages its respective managed portfolios and determines the asset classes, security holdings and weightings in the PAS Style Manager Strategy itself on a fully discretionary basis and with full trading authority, including any cash allocation. The cash allocation is held as a cash balance and/or invested in cash alternatives such as money market funds as determined by the PAS Manager. The cash allocation will be Investment Advisory Program Brochure | 13 IAPB-032025  higher at certain times depending on the nature of the PAS Style Manager Strategy, the asset allocation, the investment determinations, rebalancings, market conditions and the PAS Manager’s cash management approach and market view and concerns. If no action is taken by the PAS Manager, cash balances will automatically be swept under the Cash Sweep Program. Some types of PAS Style Manager Strategies include investments that take an extended period of time to purchase due to the type of security, market availability and selection criteria. Until invested, the cash for these investments is typically automatically swept under the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the PAS Manager as a temporary investment pending purchase of the individual security. For more information on the treatment of cash balances, see “Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services“ and “Funding and Operation of Accounts—Cash Balances” in this Item 4. A PAS Manager can be a third-party investment manager, a Merrill Affiliate or a Related Entity. Each third-party PAS Manager files a Form ADV brochure or has an equivalent document that describes their strategy and role. It is the obligation of the PAS Manager to provide its Form ADV brochure and other disclosures to its clients. The materials provided to us by the PAS Manager are included at mymerrill.com/ADV/materials for your convenience. Once PAS Style Manager Strategy is selected for your Account, your Advisor will assist and facilitate discussions with the PAS Manager over the terms of the investment management relationship. To obtain the PAS Style Manger Strategy for your Account, you must enter into a separate investment management contract directly with the PAS Manager (PAS Manager/Client Contract) which sets forth the terms and conditions under which the PAS Manager will provide discretionary managed strategies and related investment advisory and trading services (PAS Manager Services). Upon confirmation from the PAS Manager that the PAS Manager/Client Contract has been executed and upon the funding of the Account as required, Merrill will arrange for the implementation of the PAS Style Manager Strategy in the Account by the PAS Manager and provide Program Services under the Agreement. Investment Discretion and Trading Authority. In the PAS Manager/Client Contract with the PAS Manager, you grant the PAS Manager investment discretion and trading authority for investments occurring in such PAS Style Manager Strategy. Through that discretion, the PAS Manager will have complete and full investment and trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. This discretionary investment and trading authority granted to the PAS Manager will remain in place until we have received and accepted instructions from you to either change the PAS Style Manager Strategy, move the Account to a different Program Strategy type or terminate the Account from the Program. Any changes to this Program Strategy type or PAS Style Manager Strategy for your Account will require your consent. By agreement with the PAS Manager, Merrill arranges for investments to be implemented within the client’s Account directly by the PAS Manager. Merrill, by itself or with its Affiliates, will facilitate the investment by the PAS Manager of any initial and any subsequent cash and securities deposited in the Account and process all contributions, withdrawal requests and Account terminations. MAA is not responsible for any of the services provided under the Program through the Premium Access Strategy type. Furthermore, Merrill and MAA do not have discretionary authority or control with respect to the Account or have any authority to make investment and trading decisions related to Accounts with a PAS Style Manager Strategy. Neither Merrill nor MAA assume responsibility for the actions of a PAS Manager and the PAS Style Manager Strategies, including its investment performance, adherence to investment objectives and to any Accepted Investment Instructions (as defined below), compliance with applicable laws or regulations or other matters within the PAS Manager’s control. Neither Merrill nor MAA monitor transactions directed by the PAS Manager for compliance with any applicable restrictions or requirements even where we or an Affiliate execute the transactions. Merrill and MAA are not “investment managers” within the meaning of ERISA as a result of the Program Services provided to an Account that has selected a PAS Style Manager Strategy. Further, neither Merrill nor MAA renders advice on a regular basis pursuant to a mutual agreement, arrangement or understanding that such advice shall serve as a primary basis for investment decisions with respect to the Account. From time to time, a PAS Manager may request that we provide them with information about the client and the Account enrolled in their PAS Style Manager Strategy, including about the investment profile for the Account and trade positions. The selection of a PAS Style Manager Strategy is deemed to be your consent to our providing that information. The consent can be revoked by changing to a different Program Strategy type. Investment Requirements or Instructions. You can request that the PAS Manager apply certain investment requirements, instructions or guidelines or follow an IPS. You must communicate any such requests and instructions to the PAS Manager. It is the PAS Manager that determines whether the requested investment requirements, instructions or guidelines or an IPS are reasonable and whether to agree to apply them to the investment strategy at its discretion (Accepted Investment Instructions). It is your responsibility to monitor any such Accepted Investment Instructions and review them with the PAS Manager and advise it of any discrepancies or modifications to them. The PAS Manager is responsible for communicating, implementing, complying with and monitoring the Accepted Investment Instructions that are part of the PAS Manager/Client Contract. Neither Merrill, MAA nor your Advisor have any responsibility to monitor or manage to your Accepted Investment Instructions or otherwise. You accept any impact that any such Accepted Investment Instructions have on the investment performance and diversification of your Account. Your decision to request and have apply Accepted Investment Instructions that alter the allocation of a managed investment strategy or that require investment in a replacement security may result in exposure to additional (and potentially unforeseeable) risks that are inconsistent with the objective of your investment strategy. Use of Manager-Related Funds in a PAS Style Manager Strategy. The PAS Manager can utilize Manager-Related Funds in its PAS Style Manager Strategy. Note that these Manager-Related Funds have no internal advisory or distribution fees (but do have certain ongoing expenses) and may not be held outside of the particular PAS Style Manager Strategy. The PAS Manager typically views these as an integral part of its investment strategy with no appropriate substitutions that can be utilized as replacements. Where a PAS Manager receives a Manager Fee and utilizes a Manager-Related Fund that is charged a fund management fee, Merrill will work with the PAS Manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the PAS Manager Fee. See “Item 4 Funding and Operation of Accounts—Holding Funds in your Account” and “Compensation, Conflicts of Interest and Material Relationships—Affiliated Investments of a Style Manager or a PAS Manager” in Item 9. PAS Style Manager Fee. Generally, you will pay a PAS Manager Fee to compensate the PAS Manager for the investment management services it provides under the PAS Manager/Client Contract. The PAS Manager Fee will be included as a component of the Program Fee charged See “Item 4 The Program Fee and Other Charges” for more information. The PAS Manager Fee is determined by reference to the PAS Manager Rate, a negotiated rate that is agreed to by the client and the PAS Manager in their respective discretion and that is reflected in their PAS Manager/Client Contract. The PAS Manager has complete discretion in determining the PAS Manager Rate, including whether to charge, waive or discount the rate. It will take into account any number of factors or criteria, including, among others, the nature of the PAS Style Manager Strategy, the size of the investment in the PAS Style Manager Strategy, the complexity of the Accepted Investment Instructions requested for the Account, any custom services provided by the PAS Manager, the PAS Manager’s own Investment Advisory Program Brochure | 14 IAPB-032025 competitive considerations, the size of the client’s assets and anticipated investment opportunity, the client’s household assets, the client’s relationship with the PAS Manager, Merrill’s relationship with the PAS Manager, the breadth of the client’s relationship with Merrill and/or with other financial institutions with which the PAS Manager does business. At any time, the PAS Manager can decide to no longer consider these criteria in determining its PAS Manager Rate for a client. The Style Manager Strategy List (accessible at mymerrill.com/ADV/materials and available from your Advisor) provides the maximum PAS Manager Fee Rate associated with the PAS Style Manager Strategies. The PAS Manager informs Merrill of the agreed-upon PAS Manager Rate in the form required by Merrill. We will include the PAS Manager Rate in the Program Report provided to you upon enrollment in the Program Strategy and, when informed by the PAS Manager, upon any change in such rate. Merrill will pay the PAS Manager the PAS Manager Fee it collects on a monthly basis. PAS Style Manager Strategy Profiles. We make available information about each PAS Style Manager Strategy through the Profile. The Profile will describe the relevant objectives, styles and risks of the particular PAS Style Manager Strategy. It will also describe the role of the PAS Manager in implementing the PAS Style Manager Strategy. The Profile will typically include performance history, data and other information provided by the PAS Manager. The PAS Manager has the obligation to establish and maintain its PAS Style Manager Strategies in the manner generally described in the then- current Profile and to provide us notice on a timely basis of any changes made. We cannot guarantee the accuracy or consistency of the information from the PAS Managers contained in the Profiles but we obtain periodic confirmations from the PAS Managers to help us confirm they continue to be materially accurate and complete. Replacing a PAS Style Manager Strategy. Changes to a previously selected PAS Manager or PAS Style Manager Strategy can occur due to: (1) the client’s instruction to replace or terminate a PAS Style Manager Strategy; (2) Merrill terminating a PAS Style Manager from the Program or closing a particular PAS Style Manager Strategy; or (3) a PAS Manager terminating its participation in the Program or closing their PAS Style Manager Strategy to their clients. A client may change or terminate a PAS Style Manager Strategy for any reason by complying with our procedures for PAS Style Manager Strategy changes and termination. Where Merrill determines to close a PAS Style Manager Strategy, Merrill generally will provide notice of any discontinuation, closing or termination event prior to it taking place. It is possible, however, that notice of such event will be provided after the action has already been taken. In the event of a discontinuation or closing to new investment event, Merrill can take action in its discretion to hold any cash contributions or sale or redemption proceeds in cash until you provide Merrill with instructions. If Merrill determines to close a PAS Style Manager Strategy and is not provided with prior alternative instructions by you, Merrill will terminate the enrollment of the Account in the Program and the Account will typically revert to a brokerage account. Registered Fund Prospectus Delivery. Where a PAS Manager purchases an eligible Registered Fund for the PAS Style Manager Strategy selected for an Account, the PAS Manager is authorized to receive the Registered Fund prospectus in lieu of it being automatically delivered to the client. This is because by choosing the Premium Access Strategy as the Program Strategy type for the Account, the client grants the PAS Manager discretionary authority relating to the investments in the Account and authorizes such delivery. A copy of the Registered Fund prospectus can be obtained by contacting the PAS Manager. Defined Strategy as a Program Strategy Type Nature of the Strategy and Investment Options. A Defined Strategy is one where your Advisor (or one you select) constructs, selects and manages an investment portfolio of individual securities and a cash allocation to meet a specified investment style or discipline. In constructing the Defined Strategy, the Advisor may purchase different types of securities or investments, including equity securities, fixed income securities, brokered CDs, mutual funds, ETFs, money market funds, NTFs and certain types of Alternative Investments. The mutual funds, ETFs, NTFs and eligible Alternative Investments available for investment in a Defined Strategy are those that have been approved for inclusion in the Program; see “Item 6 Portfolio Manager Selection and Evaluation—Selection and Review of Investment Strategies and Funds Available in the Program.” Securities that are eligible to be part of a Defined Strategy may change over time as determined by us in our discretion. We may decide to discontinue offering a type of investment product and/or close a particular investment product to new investments and/or additional contributions from existing investors and you will not necessarily be provided with prior notice of any such discontinuation or termination. D E F I N E D S T R A T E G Y The cash allocation for the Defined Strategy is held as a cash balance and/or invested in cash alternatives such as money market funds as determined by the Advisor. If no action is taken by your Advisor, cash balances will be automatically swept under the Cash Sweep Program. The cash allocation will be higher at certain times depending on the nature of the investment style or discipline of the Defined Strategy, the asset allocation, the investment determinations, rebalancings, market conditions and the Advisor’s cash management approach and market view and concerns. Some types of investments take an extended period of time to purchase due to the type of security, market availability and selection criteria. Until invested, the cash for these investments is typically automatically swept under in the Cash Sweep Program or invested cash alternatives or other investment products as determined by the Advisor as a temporary investment pending purchase of the individual security. For more information on the treatment of cash balances, see “Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services“ and “Funding and Operation of Accounts—Cash Balances” in this Item 4. Only Advisors that meet certain eligibility requirements can offer this Program Strategy type to their clients. Advisors must be approved to participate in this Program Strategy type and to manage assets subject to different Program investment policies and guidelines depending on Advisor qualifications within this Program Strategy type. See Item 6 “Portfolio Manager Selection and Evaluation—Advisory Services Provided by Merrill, its Advisors and Certain Affiliates.” You may choose to select a Defined Strategy that is managed by an Advisor who is not your Advisor or part of the team of Advisors primarily responsible for your relationship with Merrill. In that case, that Advisor selected to manage your assets under a Defined Strategy will be responsible for implementing the Defined Strategy. MFSAs are not eligible to offer this Program Strategy type. Investment Discretion and Trading Authority. A Defined Strategy is managed with Advisor Discretion Authority. We, through the Advisor, have investment and trading discretion (including as to rebalancing) over the assets in your Account. This discretion empowers the Advisor to make investment and trading decisions with respect to those assets without contacting you. By choosing a Defined Strategy for your Account, you grant to us the authority to trade your investments and to select and implement any change to investments, asset allocation, or rebalancing within the same investment objective. Additionally, where your Advisor is a member of a team of Advisors, other members of that team may also exercise discretion over certain investment decisions made in your Account. The Advisor may make changes to the Defined Strategy used to manage your Account based on various factors, including market conditions. Investment Advisory Program Brochure | 15 IAPB-032025  Defined Strategy Review Process. Defined Strategies are subject to our review and evaluation. In certain circumstances, we may terminate the Defined Strategy offered by an Advisor or the Defined Strategy will no longer be available for an Account. Generally, in such a situation, we will work with you to recommend an alternate investment solution, but, under certain circumstances, we may determine to select a replacement Program Strategy type and/or a Style Manager Strategy or Strategies for your Account that we believe to be in your best interest. A Style Manager Rate will apply for any replacement Style Manager Strategy selected and the Style Manager could be Merrill, one of our Affiliates or a third party investment manager. The replacement may be subject to higher fees than you had been paying. We generally will provide you with notice of any discontinuation, closing or replacement event prior to it taking place. We, however, may provide you with notice of such event after we have already taken action. Having the flexibility to act quickly helps us take action where we believe the replacement and its timing are in clients’ best interest. If you do not instruct us to select a different replacement or change to a different type of Program Strategy, your continued participation in the Program after receiving written notice of the replacement will be your consent to the replacement selected. If there is no acceptable alternative to the terminated Defined Strategy or your Account is not eligible for the selected replacement, we may elect to terminate your Account from the Program. Defined Strategy Profile. Where available, your Advisor will provide you a Profile for the Defined Strategy being followed which provides general information, asset allocation and top holdings. Not all Advisors prepare a Profile for the Defined Strategy that they implement. If provided, these Profiles are typically updated quarterly to include performance information as of the most recent quarter-end and can be obtained from your Advisor upon request. Registered Fund Prospectus Delivery. When an eligible Registered Fund is purchased as part of the Defined Strategy, we are authorized to receive the Registered Fund prospectus in connection with managing your Account in lieu of it being automatically delivered to you. This is because you have granted discretionary authority to us and an Advisor relating to the investments in your Account and authorize such delivery on your behalf in the Agreement. If you would like a copy of the Registered Fund prospectus, you may obtain one by contacting your Advisor who will arrange for it to be sent to you free of charge. Notwithstanding the foregoing, Merrill may continue to send the Registered Fund prospectus to you in its sole discretion. Personalized Strategy with Advisor Discretion as a Program Strategy Type Nature of the Strategy and Investment Options Available. With this Program Strategy type, you grant investment authority to your Advisor and your Advisor will manage an investment portfolio to meet the Target Asset Allocation and other objectives for your Account. Only Advisors that meet certain eligibility requirements can offer this Program Strategy type to their clients. Advisors must be approved to participate in this Program Strategy type and to manage assets subject to different Program investment policies and guidelines depending on Advisor qualifications within this Program Strategy type. See Item 6 “Portfolio Manager Selection and Evaluation—Advisory Services Provided by Merrill, its Advisors and Certain Affiliates.” MFSAs are not eligible to offer this Program Strategy type. P E R S O N A L I Z E D S T R A T E G Y T Y P E S Your Advisor may purchase or recommend different types of securities, including equity securities, fixed income securities, brokered CDs, mutual funds, ETFs, money market funds, NTFs and certain other Alternative Investments. Each mutual fund, ETF, NTF and eligible Alternative Investment available for investment in this Program Strategy type have been approved for inclusion in the Program after due diligence and evaluation reviews conducted by our CIO or conducted by third parties subject to our supervision. See “Item 6 Portfolio Manager Selection and Evaluation—Selection and Review of Investment Strategies and Funds Available in the Program.” Securities that are available in the Program may change over time as determined by us in our discretion. We may decide to discontinue offering a type of investment solution and/or close an investment product to new investments and/or additional contributions from existing investors. You will not necessarily be provided with prior notice of any such discontinuation or termination. Your Advisor can also make a cash allocation which can be held as a cash balance and/or invested in cash alternatives available for your Account such as money market funds as determined by the Advisor. If no action is taken by your Advisor, cash balances will be automatically swept under the Cash Sweep Program. The cash allocation will be higher at certain times depending on the nature of the investment style or discipline, the asset allocation, the investment determinations, rebalancing being made, market conditions and the Advisor’s cash management approach and market view and concerns. Some types of investments take an extended period of time to purchase due to the type of security, market availability and selection criteria. Until invested, the cash for these investments is typically automatically swept under the Cash Sweep Program or invested in cash alternatives, such as a money market fund or in other investment products as determined by the Advisor as a temporary investment pending purchase of the individual security. For more information on the treatment of cash balances, see “Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking- Related Services“ and “Funding and Operation of Accounts—Cash Balances” in this Item 4. Investment Discretion and Trading Authority. This Program Strategy type is managed with Advisor Discretion Authority. We, through your Advisor, have investment and trading discretion (including as to rebalancing) over the assets in your Account. This discretion empowers your Advisor to make investment and trading decisions with respect to those assets without contacting you. By choosing this Program Strategy, you grant to us the authority to trade your investments and to select and implement any change to investments, asset allocation or rebalancing. Additionally, where your Advisor is a member of a team of Advisors, other members of that team may also exercise discretion over certain investment decisions made in your Account. Registered Fund Prospectus Delivery. When an eligible Registered Fund is purchased as part of an Account that has selected the Personalized Strategy with Advisor Discretion, we are authorized to receive the Registered Fund prospectus in connection with managing your Accounts in lieu of it being automatically delivered to you. This is because you have granted discretionary authority to us and an Advisor relating to the investments in your Account and authorize such delivery on your behalf in the Agreement. If you would like a copy of the Registered Fund prospectus, you may obtain one by contacting your Advisor who will arrange for it to be sent to you free of charge. Notwithstanding the foregoing, Merrill may continue to send the Registered Fund prospectus to you in its sole discretion. Personalized Strategy with Client Discretion as a Program Strategy Type Nature of the Strategy and Investment Options Available. With this Program Strategy type, you retain investment discretion and trading authority (except as noted below) to buy, hold and sell individual investment securities and to hold an allocation to cash to meet your Target Asset Allocation and other investment objectives. This Program Strategy type is intended for clients who seek to receive the Program Services, including ongoing advice and guidance and monitoring with respect to investments but who want to retain investment and trading Authority. It is not designed for clients that intend to maintain or hold high levels of cash, money market funds and/or highly concentrated equity positions, in each case, consistently and over a prolonged period of time. MFSAs are not eligible to offer this Program Strategy type. The different types of securities or investments that can be purchased or held in an Account that has selected this Program Strategy include equity and fixed income securities, brokered CDs, mutual funds, ETFs, money market funds, UITs, variable rate demand obligations (VRDOs), unsecured debt securities Investment Advisory Program Brochure | 16 IAPB-032025  linked to the performance of an underlying market measure (MLIs), variable annuities, variable indexed annuities and fixed indexed annuities (together, Annuities). In addition, Alternative Investments that are currently available for this Program Strategy type include NTFs, hedge funds, certain types of private equity funds, non-traded real estate funds, physical gold, silver, platinum and palladium bullion bars and/or gold, silver or palladium coins (Precious Metals), non-traded business development companies, real asset funds, commodity pools, interval funds and certain other Funds that invest in alternative asset classes or other Funds that invest in whole or in part in any of the foregoing types of Funds. Each mutual fund, ETF, NTF, Alternative Investment and certain annuities have been approved for the Program after due diligence and evaluation reviews conducted by our CIO or conducted by third parties subject to our supervision. For more information, see “Item 6 Portfolio Manager Selection and Evaluation—Selection and Review of Investment Strategies and Funds Available in the Program.” Securities that are available in the Program may change over time as determined by us in our discretion. We may decide to discontinue offering a type of investment solution and/or close an investment product to new investments and/or additional contributions from existing investors. You will not necessarily be provided with prior notice of any such discontinuation or termination. This Program Strategy can include a cash allocation as directed by you. The cash allocation can be held as a cash balance and/or invested in cash alternatives available for your Account such as money market funds. If no action is taken by your Advisor with your authorization, cash balances will be automatically swept under the Cash Sweep Program. The cash allocation will be higher at certain times depending on the nature of the investment style or discipline, the asset allocation, the investment determinations, rebalancings, market conditions and your cash management approach and market view and concerns. Some types of investments take an extended period of time to purchase due to the type of security, market availability and selection criteria. Until invested, you can hold the cash for these investments in the Cash Sweep Program or invest in cash alternatives, such as a money market fund, or in other investment products as a temporary investment pending purchase of the individual security. For more information on the treatment of cash balances, see “Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services“ and “Funding and Operation of Accounts—Cash Balances” in this Item 4. Investment Discretion and Trading Authority. You, with the assistance of your Advisor, will select the investments that make up the Portfolio and, if desired, assign a corresponding asset allocation percentage for each investment and/or select a rebalancing frequency for the assets. Any change to investments (on a transaction by transaction basis), asset allocation or rebalancing will require your consent because you retain the Authority to select and implement these changes. Merrill and your Advisor have no investment or trading discretion. Certain Guidelines regarding Trade Activity. This Program Strategy type is not intended to be used by clients who engage in activity that is inconsistent with the investment advice provided through the Program or who intend to engage in a very low or very high volume of trading in their Portfolio. It is also not intended for clients who engage in high levels of unsolicited trading activity. Generally, unsolicited orders are those that you request your Advisor to effect without having received a recommendation or call to action from your Advisor or those orders that you instruct us to make that are contrary to your Advisor’s advice, guidance or recommendation. Unsolicited trade activity is subject to Program guidelines. We have the right, in our sole discretion, to decline to accept or effect any unsolicited orders at any time, without providing you prior notice. If your activity contravenes our Program guidelines on these and other matters, we will request that you take certain corrective action. We have the right to terminate your Account from the Program if the requested action or other action is not taken. Portfolio Reviews, Program Reports and Information An important part of the Program is providing you with the opportunity to engage in periodic reviews with your financial advisor or a designated member of the team servicing your Portfolio. These reviews provide updates on the progress of your Portfolios, Accounts and other important information about your investments. A periodic review of your Account should typically occur on an annual basis; however, under our Program guidelines, both you and Merrill have the ability to extend or defer the timing of the review under certain circumstances and for certain periods of time. If you do not participate in a review within the timeframes we have established in our Program guidelines, we have the right to terminate an Account from the Program in our discretion. We also provide you with a Program Report in connection with the review and upon certain changes being made to your Portfolio. For an Account that has selected a PAS Style Manager Strategy, you may also receive reports concerning the Portfolio directly from the PAS Manager in accordance with the terms of the agreement separately entered into between you and the selected PAS Manager. See “Account Review and Reporting” for more information. Brokerage, Banking-Related and Custodial Arrangements and Services The primary purpose of the Program is to provide you with ongoing fiduciary investment advice and guidance for your Portfolio and access to investment strategies and ongoing monitoring. The Program Fee you pay covers these Program Services and your payment for the trade execution, clearance and settlement services. It also covers custody of assets if you maintain your Account with Merrill. Note that certain fees unrelated to investment activity, like fees for banking-related or cash transfer activities, wire transfer fees, foreign currency wire and conversion fees, account service fees, transaction fees and certain transactional costs, are not covered by the Program Fee, including those described in the section “The Program Fee and Other Charges” below. B R O K E R A G E S E R V I C E S Brokerage Trading Services In effecting transactions for your assets in the Program, Merrill and its Affiliates will be acting exclusively as a broker-dealer and can arrange for trades to be executed through Merrill or a Merrill Affiliate or through an Unaffiliated Trade Counterparty. If we or one of our Affiliates effect the transaction through an Unaffiliated Trade Counterparty, we will take into account various factors, such as the nature and quantity of the securities involved, the markets involved, the reputation and perceived soundness of the firm, the firm’s clearance and settlement capabilities and other factors relevant to the selection of a broker-dealer for the execution of client securities transactions. Trades will be handled by us consistent with our best execution and other regulatory obligations. Even in meeting these obligations, it is possible that you may be able to obtain better prices for transactions if such trades were executed with other broker-dealers or third parties, including having smaller spreads (the difference between the bid and the offer price) or at more favorable net prices. We seek to effect transactions correctly, promptly and in the best interests of clients. In the event an error occurs in our handling of client transactions, we seek to identify and correct any errors as promptly as possible without disadvantaging you. In general, in instances where we are responsible for effecting the transaction incorrectly, we may reimburse you for any losses directly resulting from trade errors, credit to you any profits directly resulting from such trade errors that are corrected after the settlement of the transaction or retain for ourselves any profits directly resulting from such trade errors that are corrected prior to the settlement of the transaction. Investment Advisory Program Brochure | 17 IAPB-032025  We may, but are not required to, aggregate orders for the sale or purchase of securities for your Accounts with orders for the same security for our other clients, for our own accounts or the accounts of our employees (including your financial advisor) and/or a Related Entity. Where order aggregation is employed, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro-rata share of any fees. To the extent Style Managers provide similar investment recommendations or trade orders for their particular Style Manager Strategy to MAA for implementation, MAA’s ability to implement those recommendations will be affected by the liquidity of the security, market volatility and any price limits imposed by the Style Managers. This may in turn have a negative impact on the performance of a Style Manager Strategy. For Personalized Strategy with Client Discretion Accounts, your Advisor will enter your trade orders promptly upon your instruction. In implementing your instructions, Merrill, as broker-dealer, has discretion as to the price or time at which it executes an order for a transaction, as long as the transaction is executed the same day the order is given to your Advisor and is consistent with our duty to seek best execution. If we believe that it may be appropriate to execute an order later than on the same day that we receive the order, we will ask for your authorization to do so. Advisors also have broad discretion to trade Accounts participating in a Defined Strategy. There can be no assurance that an Advisor will purchase or sell the same securities for all such Accounts in the Defined Strategy at the same time, or that the Advisor will aggregate your orders with those of other client Accounts participating in the Defined Strategy. As a result, you may receive different prices and executions for the same securities as compared to other clients making the same investment in that security. In addition, although we do have routines that monitor performance dispersion within a particular Defined Strategy that an Advisor is implementing, investment opportunities will not necessarily be allocated among participating Accounts in the same manner or at the same time. Brokerage Execution for Discretionary Style Manager Strategies and PAS Style Manager Strategies If you have selected a Style Manager Strategy with a Discretionary Manager or any PAS Style Manager Strategy, the Discretionary Manager or the PAS Manager, as the case may be, has the authority to place orders for transactions with broker-dealers that it selects, including with us or any of our Affiliates that act as a trade counterparty (Affiliated Trade Counterparty) and with an Unaffiliated Trade Counterparty. For certain Style Managers that are Discretionary Managers, we may provide administrative support to the Discretionary Managers to assist with the placement of orders at their direction. In selecting a firm to execute transactions and the markets in which the transactions will be executed, neither the Discretionary Manager nor the PAS Manager is obligated to solicit competitive bids for each transaction or seek the lowest available commission cost so long as it reasonably believes that the firm it selects can be expected to obtain a “best execution” market price on the particular trade. Each is responsible for ensuring that it complies with its own best execution obligations. Discretionary Managers and PAS Managers are able to transact with us or an Affiliated Trade Counterparty on a principal basis when permitted by law. They may place trades for purchases of securities in underwritten offerings with BofAS or any of our other Affiliates or with an Unaffiliated Trade Counterparty under which certain underwriting compensation is earned by BofAS or any of our Affiliates or by the Unaffiliated Trade Counterparty. When these transactions are effected on a principal basis, we will receive additional compensation. Both Discretionary Managers and PAS Managers have the discretion to aggregate orders for the sale or purchase of securities with orders of the same security for other clients (either at Merrill or at other firms) in the same Style Manager Strategy or PAS Style Manager Strategy, as the case may be, for its own accounts or for the accounts of its or our employees and/or related persons. They are not required to aggregate orders. Where aggregation of orders occurs, each Account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro-rata share of any fees. Certain Style Managers with model-based Style Manager Strategies may place orders for particular (but not all) transactions with us, an Affiliated Trade Counterparty or an Unaffiliated Trade Counterparty if the Discretionary Manager determines, after consultation with us, that (1) they are able to aggregate a particular trade for Program clients in a block trade and (2) they expect such aggregation will be for the overall benefit of our Program clients. Important Information about “Step Out Trades” by Discretionary Managers and PAS Managers. An order placed by a Discretionary Manager or a PAS Manager with an Unaffiliated Trade Counterparty is commonly referred to as a “step out” or a “step out trade.” The Discretionary Style Managers and PAS Managers that we have identified as having engaged in “step out trades” either on a regular or a limited basis are designated in the Step Out Information Document (accessible at mymerrill.com/ADV/materials and available from your Advisor or MFSA). The information in the Step Out Information Document is based solely on the historical information provided to us by the Discretionary Style Managers and the PAS Managers. We do not make any representation regarding their future trading practices. In addition, we recommend that you review the applicable investment manager’s Form ADV brochure (accessible at mymerrill.com/ADV/materials, the SEC website at adviserinfo.sec.gov and available from your Advisor or MFSA). For “step out trades” placed by a Discretionary Manager or by a PAS Manager in fixed income or other securities where the Unaffiliated Trade Counterparty imposes a mark-up, mark-down and/or a dealer spread charge (dealer spread charges), the net price of the security will include these dealer spread charges and you bear these costs. Please note that this is also the case where a Discretionary Manager or a PAS Manager places a trade order with an Affiliated Trade Counterparty for the purchase or sale of fixed income or other securities where dealer spread charges are imposed. In both of these types of trade executions, the dealer spread charges (that are part of the net price of the security) will be in addition to your Program Fee. These dealer spread charges will not be listed in your trade confirmation or account statement; however, upon written request, we will undertake to obtain the amount of these charges for a given transaction in your Account. See “Item 4 The Program Fee and Other Charges—Fees and Expenses Not Covered by the Program Fee.” Where a Discretionary Manager or a PAS Manager places a trade order for an equity security or any other security where commissions are charged with Merrill, an Affiliated Trade Counterparty or with an Unaffiliated Trade Counterparty as the executing broker, the brokerage commissions for such trade will not be a separate charge or cost to you. This does not apply for a “step out trade” in foreign ordinary shares and American Depositary Receipts (ADRs); see the heading “Foreign Ordinary Shares and ADRs Transactions” below. You should consider the costs of “step out trades.” If you hold a Style Manager Strategy or a PAS Style Manager Strategy in an Account, you will pay a Style Manager Fee or a PAS Manager Fee, as applicable, for the investment management and related services they provide. The rates charged by these managers vary among each other and among other Style Manager Strategies. For trades in fixed income securities, whether executed as a “step out trade” or a trade with an Affiliated Trade Counterparty, you will pay the dealer spread charges associated with such trade. It is possible that the Manager Fee rates for Discretionary Style Manager Strategies and PAS Style Manager Strategies may be higher than other available Style Manager Strategies and PAS Style Manager Strategies. You could be deemed to be indirectly bearing the cost of the “step out trades” by virtue of any such higher charges. In addition, you will Investment Advisory Program Brochure | 18 IAPB-032025 pay the same fee rate for a particular Style Manager Strategy or PAS Style Manager Strategy regardless of whether or not the Discretionary Manager or PAS Manager executes “step out trades.” You should consider the use by the Discretionary Manager and/or the PAS Manager in executing “step out trades” when selecting a Discretionary Style Manager Strategy or a PAS Style Manager Strategy. Brokerage Arrangements for Certain Securities Transactions Foreign Ordinary Share and ADR Transactions. For foreign ordinary security transactions executed outside the United States, we may use a foreign Unaffiliated Trade Counterparty (or its Affiliate). The foreign Unaffiliated Trade Counterparty (or its Affiliate) will handle the order and will assess trading- related charges and costs (i.e., commissions, mark-ups/downs, dealer spreads and other fees and charges). In addition, fees associated with transactions in foreign ordinary securities can also include local country costs and fees, stamp taxes and foreign currency exchange or conversion fees. To the extent a foreign currency conversion transaction is required, the foreign Unaffiliated Trade Counterparty (or its Affiliate) will be remunerated in the form of a dealer spread or a mark-up/down. These trading-related and currency conversion-related charges and costs are included in the net price of the security and are charges and costs that are in addition to your Program Fee. In addition, these fees, charges and costs will not be reflected as separate charges on your trade confirmations or account statements. We will undertake, at your written request, to obtain the amount of this remuneration for a given transaction in your Account. You will pay charges for transactions in ADRs (or other similar securities) when executed by the Discretionary Manager or the PAS Manager as a “step out” trade. See “Item 4 The Program Fee and Other Charges—Fees and Expenses Not Covered by the Program Fee.” Annuities. Merrill, as a broker-dealer, and Merrill Lynch Life Agency Inc. (MLLA), as general agent and insurance broker, have entered into selling agreements with insurance companies (that are not our Affiliates) to make available Annuities to Merrill clients. Not all Advisors may offer Annuities. Your Annuity assets are maintained at the specific insurance company that issued the Annuity (“Annuity Issuer”). For any Annuity in your Portfolio, you authorize your Advisor to process all transactions relating to your investment decisions regarding the Annuity. We will provide you with investment advice and guidance regarding the Annuity and its role in your Portfolio and as to any constituent underlying investments, where applicable, associated with the Annuity. Transactions in Precious Metals. For purchases or sales under the program that makes available allocated units of Precious Metals (Precious Metals Program), we will enter into a corresponding agency trade on your behalf with the third-party provider of certain precious metal services. The third-party provider is responsible for seeking pricing for the purchase or sale transaction from its network of dealers approved under the Precious Metals Program and will execute the transaction on a principal basis. Margin Rules, Margin Loans and Securities Based Lending Programs. As a broker-dealer, Merrill is responsible for compliance with federal margin rules. Except where margin has been specifically permitted, Accounts are set up as cash Accounts. This account notation means that margin is not permitted and purchases of securities must be fully paid for on the date of the trade. With a cash Account, if securities are sold before the payment for their purchase has settled, an event known as a “free-riding violation” has occurred. Freeriding is prohibited under margin rules and our Program guidelines. Having a “free-riding” violation may result in your Account being restricted for 90 days or “frozen.” The imposition of such a freeze could have a negative effect on your Account and performance. The risk of engaging in an inadvertent “free riding” violation and therefore freezing of your Account is enhanced: (1) when you have selected for your Account multiple Style Manager Strategies, as they operate independently and are unaware of purchase or sale activity for other strategies; (2) when you change Style Manager Strategies and reconstitute your investments; (3) when you engage in periodic rebalancing (which results in purchases and sales of securities over a short period of time); or (4) when you withdraw cash from your Account when there is a pending order to purchase a security. Under certain circumstances and for Accounts that have selected the Personalized Strategy with Client Discretion, you may use margin in respect of your non-retirement Account assets. The collateral for the margin debit will be the assets in your Accounts and other accounts at Merrill. The costs, risks and other features and conditions of margin are more fully described in our Margin Lending Program Client Agreement. If you use margin to purchase additional securities, the value of your Account can increase and therefore the amount of fees you pay under the Program will increase. You will also be charged margin interest on the debit balance in your Account. You are responsible for notifying us if you decide that you no longer want to use margin in your Account. We are not responsible for any losses resulting from our failure or delay in implementing such instructions. C A S H S W E E P Certain of your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through certain Affiliated loan programs (i.e., the Loan Management Account® and Mortgage 100®/Parent Power® mortgage programs) or through unaffiliated loan programs (together, Lending Programs). There are risks, costs, and conflicts of interests associated with margin loans and Lending Programs. The costs, risks and other features and conditions of a loan under the Affiliated Lending Programs are more fully described in the separate lending documentation you receive in connection with any such loan and are not described in this Brochure. The costs, including interest, associated with a margin loan or a loan through any Affiliated Lending Program are not included in the Program Fee and will result in additional compensation to us, our Affiliates, and our financial advisors. The interest charges on any loan combined with the fees charged for Program Services may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. See the sections ”Investment Strategies and Risk of Loss—Engaging in Margin and Securities-Based Lending with your Account” in Item 6 and the sections “Compensation, Conflicts of Interest and Material Relationships—Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel;” and “Participation or Interest in Client Transactions and Conflicts of Interest—Participation in Affiliated Lending Programs and Margin” in Item 9. P R O G R A M Cash Sweep Program and Other Banking-Related Services As provided in the relevant brokerage account agreement and documents you executed to open your account, unless you elected the “No Sweep” option, you have consented to having cash held in your account being treated as a cash balance and being automatically “swept” on the day following the cash deposit to the cash sweep option applicable to your underlying brokerage account under the Cash Sweep Program. Unless the cash allocation is invested, either in a cash alternative or in other securities, the cash allocation will be treated as a cash balance in the Program Account subject to the automatic sweep functionality. “Bank Deposit” Sweep Option. Under the MLBD Program, RASP and the IBVRD Facility, an Account’s cash balance is swept to accounts held at our Bank Affiliates. Under the ISA Program, an Account’s cash balance is swept to accounts that are held at participating banks (ISA Participating Banks). To view a list of the depository institutions currently participating in the ISA Program, visit www.ml.com/ISA. Investment Advisory Program Brochure | 19 IAPB-032025  Under each of the MLBD Program, RASP, IBVRD Facility and ISA Program, Merrill as your agent establishes the bank deposit accounts on your behalf at the Bank Affiliate or the ISA Participating Bank as provided for in your underlying brokerage account agreements. Bank deposits in the MLBD Program, RASP and the ISA Program are insured by the Federal Deposit Insurance Corporation (FDIC). Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection programs. Merrill is not a bank and FDIC deposit insurance only covers the failure of an FDIC-insured bank. Certain conditions must be satisfied for deposit insurance coverage to apply when bank deposits are opened on your behalf in the name of Merrill as your agent. Merrill has in place business requirements and practices that are reasonably designed to satisfy those conditions, which include, but are not limited to, proper account titling and recordkeeping. The sweep deposit accounts at banks in the MLBD Program, RASP and the ISA Program are protected by FDIC insurance, up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership category, per bank. FDIC insurance covers both principal and credited interest, up to applicable limits. Any such deposits in the same account ownership category, whether directly, through other Merrill accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If your total cash balances in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of bank product (i.e., brokered CD) of a Bank Affiliate in the MLBD Program or RASP or of any ISA Participating Bank exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Neither Merrill nor the Bank Affiliates manage or monitor the deposits swept under the MLBD Program, the RASP or the ISA Program for FDIC insurance limit purposes. Deposits are not aggregated or limited under the MLBD Program, RASP and the ISA Program based on the FDIC limits for the same depositor in the same bank across Merrill accounts. Merrill does not undertake through the Program or the Agreement or the underlying brokerage agreement to provide you notice that cash balances in your Account or Accounts or in any of your brokerage accounts exceeds the FDIC coverage limit for any of our Bank Affiliates or any other Participating Bank. Monitoring FDIC insurance coverage limits is expressly not a Program Service. You are responsible for monitoring the total amount of deposits held at the Bank Affiliates and at any ISA Participating Bank in order to determine the extent of FDIC insurance. The agreements and disclosures that you received in connection with establishing your underlying Merrill brokerage account and the Sweep Program Guide for Merrill Clients include additional information about FDIC insurance. A paper copy can be obtained from your Advisor or MFSA. For additional information on FDIC insurance, visit fdic.gov. Cash balances swept under the Cash Sweep Program to a bank deposit account of our Bank Affiliates will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts will be periodically set and reset by the Bank Affiliates in their discretion. The rate is variable and may change at any time after the account is opened without notice or limit. Under the MLBD Program and RASP, interest rates are tiered based upon a client’s relationship with Merrill. Accounts with the MLBD Program and RASP as their Cash Sweep Program that are enrolled in the Program and in other specified Merrill investment advisory programs receive the highest tier rate available under the MLBD Program or RASP. A brokerage account with cash swept into MLBD Program or RASP that enrolls in the Program will continue to receive interest at the tier assigned to the account until the beginning of the month after enrollment. That following month, the enrolled Account will have an updated tier assigned, and interest will begin accruing at that rate. There is no interest rate tiering offered under the IBVRD Facility. Cash balances held in the IBVRD Facility are not covered by FDIC or other deposit protection and receive a lower rate than the highest rate available under the MLBD Program or RASP. Please note that the interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. “Money Market Fund” Sweep Option for Certain Account Types. Under account agreements covering TMA and certain retirement accounts, you can select from several money market funds as a sweep option. These money market funds have certain internal expenses and costs and also include a 0.40% asset-based administration fee per annum that is paid to Merrill. Merrill rebates the amount of the asset-based administration fee it receives to the clients with this sweep option. The amount of such rebate may be less than this 0.40% fee in certain rate environments where the fund manager waives or reduces the amount of such fee in order to avoid a negative return on the money market fund. You will bear your proportionate share of the sweep money market fund’s fees and expenses including, but not limited to, management fees paid to the fund’s investment managers or their Affiliates, fees payable to the fund’s professional and other service providers, transaction costs and other operating costs. The Program Fee does not cover or offset any fees and expenses that the sweep money market fund incurs for transactions occurring within the fund itself. Please consult the prospectuses and offering material for the sweep money market funds. “No Sweep” Option. Certain account types have the option to select the “No Sweep” option under their underlying brokerage agreement which results in cash being held as a cash balance and not ‘swept’ to any available sweep option under the Cash Sweep Program. The cash balance will not earn interest or dividends. The cash will be covered by the Securities Investor Protection Corporation (SIPC) up to $500,000 per client, inclusive of $250,000 for cash. As a registered broker-dealer, Merrill benefits from the possession or use of cash balances, also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under the Securities Exchange Act of 1934 (Exchange Act). Ability to Invest Cash Balances. For an Account that has selected Personalized Strategy with Client Discretion as their Program Strategy type, rather than having the cash balances being automatically swept under the Cash Sweep Program or remain in the sweep bank deposit, you can instruct your Advisor at any time to invest any cash balances in cash alternatives (such as money market funds) or in other investment securities. As rates and yields offered in the Cash Sweep Program change and/or your personal financial circumstances and other factors change, it may be in your financial interest to invest cash balances in investment products that generate a higher rate of interest or yield tax benefits. For Style Manager Strategies and PAS Style Manager Strategies and for those Program Strategy types where your Advisor has Advisor Discretion Authority, it is the Style Manager, PAS Manager or your Advisor, as the case may be, can direct that your Account’s cash allocation be invested in a cash alternative investment. Conflicts of Interest related to the Cash Sweep Program. There are conflicts of interest associated with the Cash Sweep Program which are discussed in “Compensation, Conflicts of Interest and Material Relationships” in Item 9 at the sections “Cash Sweep Program Compensation Received by Us and Our Affiliates,” “Compensation Received by Us for Sub-accounting Services” and “Mutual Funds Arrangements and Compensation” and at “Participation or Interest in Client Transactions and Conflicts of Interest—Cash Balances and Cash Sweep Program.” Investment Advisory Program Brochure | 20 IAPB-032025 Custodial Arrangements and Services Custody with Merrill. Generally, we will act as the custodian for the securities held in the Program. Your assets will be maintained in one or more central asset accounts established at MLPF&S through the applicable brokerage or other account agreement. Any assets held in the Program must be and remain free from any lien, charge or other encumbrance, unless we agree otherwise or it is a lien, charge or other encumbrance in favor of us or our Affiliates through our brokerage or other account agreements. You must notify us in writing prior to effecting any loans secured or collateralized by your Account, including effecting any loans with our Affiliates. No specific securities in your Account should be held as collateral to secure any loans you may have. We will not provide advice on, or oversee any of, your collateral arrangements. Unless we otherwise agree, the terms of the Agreement will prevail in the event of any conflict between the terms of the Agreement and your collateral arrangements. You must also disclose to any lender the terms of the Agreement. There are adverse effects of collateralizing your Account, including, but not limited to, the fact that the lending institution may require additional collateral or liquidation of securities to meet a call, as well as the related tax consequences. Custody with an Affiliated Custodian or an Unrelated Custodian. In limited circumstances, upon your request and direction and with our consent, you may enter into arrangements for your assets in the Program to be maintained with (1) certain of our Affiliates for that Affiliate to act as a custodian (Affiliated Custodian) or (2) a custodian that is not related to or affiliated with Merrill (Unrelated Custodian). You will be responsible for all fees and expenses charged by the Affiliated Custodian or the Unrelated Custodian subject to applicable law and the custodial arrangements you agree to. These fees and expenses are not covered by the Program Fee. Our rights and authority respecting your assets enrolled in the Program, including as to transfers of assets held with the Affiliated Custodian or the Unrelated Custodian, are limited to those set forth in the Agreement, regardless of any separate agreements or arrangements you may have or may enter into. We disclaim any broader rights that may be contained in your separate agreement with an Affiliated Custodian or the Unrelated Custodian. Cash held in Accounts with a custodian other than MLPF&S are not covered by the Cash Sweep Program and will not be subject to MLPF&S’ cash sweep arrangements. You are responsible for separately establishing appropriate sweep arrangements with the Affiliated Custodian or Unrelated Custodian. We will include the cash positions in your Account in the value of your Program assets for the calculation of the Program Fee. Assets held in Accounts with an Affiliated Custodian and the Unrelated Custodian are not subject to Merrill’s SIPC coverage. You will be responsible for ensuring that we (and all vendors used by us) are provided with daily access to the Affiliated Custodian’s or Unrelated Custodian’s systems, transaction and account data and other information necessary to provide adequate account supervision, transaction, billing and other client reports and other necessary services to your Account. You understand that as a result of your use of a custodian other than Merrill, you will receive more limited information and reporting. You will not receive performance reporting from Merrill. Furthermore, any performance and other reports or statements provided by us for your Portfolio will be based on information provided by the Affiliated Custodian or Unrelated Custodian. We will use this information to calculate the Program Fee, monitor your Target Asset Allocation and for other purposes. Merrill and MAA are not responsible for verifying the accuracy of the information provided by such custodian and are not responsible or liable for any losses or errors, including but not limited to, errors in performance reports and fees charged to the Account, if caused by, or in any way related to, our reliance on such information from, and the acts or omissions of, such custodian with respect to the Account. You agree to promptly notify us about any additions or withdrawals of assets to or from your Account maintained at any such custodian. Neither Merrill nor MAA will be responsible or liable for any losses due to your failure to provide such prompt notification. It is the responsibility of the Affiliated Custodian or an Unrelated Custodian to implement your proxy delivery instructions. See “Item 4 Proxy Voting— Implementing Your Proxy Voting Selection.” Accounts that are custodied with an Affiliated Custodian or an Unrelated Custodian are not eligible to elect periodic trade confirmation delivery. See “Item 4 Delivery of Trade Confirmations on a Periodic Basis.” Special Custody Arrangements for Certain Program Assets. Annuity assets purchased for an Account will be maintained at the Annuity Issuer. Custody of Precious Metals purchased through the Precious Metals Program will be maintained at approved vaults in the name of Merrill as agent for your exclusive benefit. Although the Precious Metals Program provides for periodic verification procedures, Merrill may not be able to regularly confirm the existence and amount of Precious Metals held under the Precious Metals Program at a given approved vault location. In lieu of having these assets custodied at one of the approved vaults, subject to certain restrictions, you may elect to take physical delivery of Precious Metals purchased under the Precious Metals Program; however, doing so involves the possibility of significant additional costs and risks. Merrill is not obligated to satisfy your request to take physical delivery. For more information, please review the Precious Metals Disclosure Statement for the Precious Metals Program. Proxy Voting Proxy Voting Options You have the right to vote proxies for securities held in your Account. For certain Program Strategies, you also have the option to delegate proxy voting authority directly to a proxy voting service provider we have engaged and made available to you. The proxy voting service provider that Merrill has made available under the Program based on its oversight processes is Institutional Shareholder Services, Inc. (ISS or Proxy Delegation Vendor). ISS offers the ability to select certain proxy voting policies (ISS Voting Policies) that take certain positions on corporate governance and other issues. The ISS Voting Policies available as of the date of this Brochure for your Account are: • ISS Benchmark Guidelines designed to promote total shareholder value and company risk mitigation (ISS Benchmark Guidelines). P R O X Y • ISS Socially-Responsible Investing Guidelines designed to reflect a broad consensus of the socially responsible investor community (ISS SRI Guidelines). I • ISS Catholic Faith-Based Guidelines designed to reflect the teachings of Catholicism and Christianity as a whole (ISS Catholic Guidelines). V O T N G Not all ISS Voting Policies may be available to all clients. For more information on ISS and its Voting Policies, see the “Implementing Your Proxy Voting Selection-Electing the Proxy Delegation Vendor Option” below. A client that is an ERISA Plan may select among the available ISS Voting Policies based on its own determination that the selected ISS Voting Policy meets the requirements imposed on it under ERISA regulations. An “ERISA Plan” is a plan subject to the provisions of ERISA or any other entity deemed to hold assets of such a plan, including SIMPLE, SEP and other IRAs subject to ERISA’s fiduciary responsibility provisions. We may require additional documentation from the ERISA Plan client as to its selection. If your Account is enrolled in the Premium Access Strategy type, the PAS Manager will have proxy voting authority for the Account (PAS Manager Delegation), unless you notify us to the contrary in writing. Investment Advisory Program Brochure | 21 IAPB-032025  Implementing Your Proxy Voting Selection General Approach. You may not delegate to us, and we do not accept or assume from you, proxy voting authority for any securities in your Account. As a broker-dealer, Merrill uses a third-party service provider for certain proxy-related functions, including processing and forwarding proxy and other issuer- related materials, and receives amounts collected by the vendor for the costs of these services as permitted by applicable securities regulation. You provide your initial instruction regarding proxy voting in the section “Account Elections/Signature Page” in your Agreement or by a client attestation within our enrollment system that we use to open accounts and capture IAP enrollment by electronic means or otherwise in writing by contacting your financial advisor. You may have a different election for each of your Accounts. Each election will apply to the Account specified unless the proxy voting option you elect is no longer available or until you make a different election. For each Account, your proxy voting election will be reflected in your initial Program Report. As indicated in the Agreement, unless you instruct otherwise on the “Account Elections/Signature Page” of the Agreement, through a client attestation within our enrollment system that we use to open accounts and capture enrollment in the Program by electronic or digital means (electronic enrollment tool), or by means of a separate writing, you instruct your proxy delegation as follows: • You retain proxy voting discretion and authority for any Account that has selected the Program Strategy type of Personalized Strategy with Client Discretion. • You delegate voting discretion and authority to the Proxy Delegation Vendor and select the ISS Benchmark Guidelines for any Account that has selected any of the following Program Strategy types: Managed Strategy, Custom Managed Strategy, Defined Strategy or Personalized Strategy with Advisor Discretion. • You delegate voting discretion and authority for any Account that has selected the Program Strategy type of Premium Access Strategy to the PAS Manager of the selected PAS Style Manager Strategy for the Account. If you subsequently change your Account to one with the Program Strategy type of Personalized Strategy with Client Discretion, any delegation as set forth above will cease and you will retain proxy voting authority for your Account. Retention by You of Proxy Voting Authority. Where you retain proxy voting authority for securities held in an Account at MLPF&S, we will promptly send you proxy ballots and related shareholder communications that we receive, as well as any other information intended for distribution to you, except as described in the section “Circumstances When No Proxy Voting May Occur” below. You are responsible for taking any actions. If we are the custodian of your Account and do not receive voting instructions from you or your delegate, we will comply with the rules of the SEC and applicable self-regulatory organizations relating to such matters, as required by law. If your Account is an ERISA Plan, you represent that plan documents and applicable law authorize voting authority to be reserved to the trustee either in the discretion of the trustee or pursuant to the discretion of a named fiduciary. Where you retain proxy voting authority for securities held in an Account at an Affiliated Custodian or an Unrelated Custodian, you are responsible for ensuring arrangements are in place for the Affiliated Custodian or Unrelated Custodian to deliver proxy ballots and related shareholder communications to you. You are responsible for taking any actions. Electing the Proxy Delegation Vendor Option. Where you elect to have the Proxy Delegation Vendor vote the proxies for the securities in your Account for Program Strategy types where it is permissible under the Program, you are delegating proxy voting authority directly to the Proxy Delegation Vendor for the securities in your Account, voting under the ISS Voting Policies that you select. As provided in the Agreement, where applicable, the ISS Benchmark Guidelines will apply to your Account unless you make a written selection for another of the ISS Voting Guidelines available to you. If you elect to have the Proxy Delegation Vendor vote the proxies for securities held in an Account at an Affiliated Custodian or an Unrelated Custodian, we will use reasonable efforts to notify such Custodian of the appropriate delivery instructions for proxy-related communications based on your election and the information you provide us about the Custodian. ISS, the Proxy Delegation Vendor, will exercise the applicable voting authority in its sole discretion to vote proxies in accordance with its proxy voting policies and procedures and populate votes on its electronic voting platform. The applicable ISS Voting Policies and how ISS voted proxies for securities held in your Account are available at https://vds.issgovernance.com/vds/#/MzU4NA== (Proxy Website). ISS will vote proxies in accordance with the ISS Benchmark Guidelines unless you elect otherwise in writing, either in the Agreement at the Account Election/Signature Page or in a separate written authorization. The other ISS Voting Policies available for your selection are the SRI Guidelines and the Catholic Guidelines. Each of these ISS Voting Policies and Guidelines are updated annually by ISS and are available via the Proxy Website or upon request. ISS has significant relationships with companies on which ISS also furnishes proxy voting advice as part of its proxy voting guideline services. Information relating to ISS’ significant relationships with companies whose securities are held in your Account and as to other information is available on ISS’ website at issgovernance.com or by contacting your finanical advisor. The ISS ADV 2A brochure is also accessible at mymerrill.com/ADV/materials and at the SEC’s website at adviserinfo.sec.gov. If the Proxy Delegation Vendor declines to exercise its proxy voting authority in respect of a proxy meeting for an issuer, the proxy voting authority will revert directly to you. In that event, we take all reasonably practicable action to promptly send or have sent to you all issuer-related materials for such security held in your Account. Delivery of those issuer-related materials to you will constitute notice that proxy voting authority with respect to a security has reverted to you. In instances where we have determined that it is not possible to send the materials to you given timing or other circumstances, the proxies of such securities will not be voted. If we replace the current Proxy Delegation Vendor with another Proxy Delegation Vendor, we will provide you with notice of the change. You may choose to rescind the proxy voting authority that you have delegated to the Proxy Delegation Vendor by contacting your Advisor or MFSA. PAS Manager Delegation. Unless you instruct us otherwise in writing, by selecting the Premium Access Strategy as a Program Strategy type for an Account, you are delegating proxy voting authority directly to the PAS Manager for the securities in that Account. A PAS Manager will exercise the applicable voting authority in its sole discretion in accordance with its proxy voting policies and procedures. For more information regarding the PAS Manager’s proxy voting, you should refer to your PAS Manager/Client Contract and the PAS Manager’s Form ADV brochure on the SEC website at adviserinfo.sec.gov. Circumstances When No Proxy Voting May Occur. Voting proxies in certain situations involves logistical issues that can impact Merrill’s or the PAS Manager’s ability to transmit a vote. We will not arrange for proxy voting under the Program in circumstances where we conclude, based on reasonable Investment Advisory Program Brochure | 22 IAPB-032025 efforts and good faith belief and understanding, that the costs and burdens of voting exceed the potential benefit to you. The circumstances where this may occur include the following: • The proxy or other relevant materials are not received in a sufficient time to allow a vote to be cast by the voting deadline. • The quantity or quality of materials received is insufficient. • The proxy materials are provided in a language other than English. • There are voting restrictions that may apply to shareholders not resident in a security issuer’s place of listing or incorporation (applicable in certain non- U.S. jurisdictions). • The non-U.S. issuer or the non-U.S. jurisdiction has imposed a requirement that you vote the proxy in person and/or appoint a local agent or provide a local agent with powers of attorney in order for a voting instruction to be accepted. • Share-blocking rules apply under local law or regulation that result in the sale of the security being prohibited for a period of time (usually the time between the record and meeting dates) if you cast a proxy vote for a shareholder meeting. • Share re-registration requirements are imposed that affect liquidity. • The issuer or the non-U.S. jurisdiction of the issuer requires that you provide personal, client-specific information (e.g., passport identification, personal client data) and/or whether you have a controlling or personal interest in the issuer, in order for your ballot to be accepted and/or counted for the meeting. • Securities are on loan (i.e., securities may not be voted by the lender unless the loan is recalled). In light of significant costs and burdens, including privacy concerns, we have determined that we will generally not arrange for the voting of non-U.S. company proxies. A PAS Manager with delegated voting authority may make a different decision regarding voting of non-U.S. company proxies based on their own guidelines and contractual agreement with you. If you retain the proxy voting authority for an Account, Merrill will provide pre-ballot notices we receive about non-U.S. company meetings where required. If you wish to receive proxy voting materials for a particular meeting of a non-U.S. company, you may contact your financial advisor and we will arrange for proxy materials and forms to be provided to you on a best efforts basis. To vote, you will need to provide us with the information and other documentation that may be required. Merrill will arrange with its agents to transmit your completed ballot for a particular meeting provided the appropriate information is timely received. In transmitting your vote, this information will be provided to various intermediaries unrelated to us. Merrill is not responsible for any misuse of your client information and data provided to these intermediaries or to the issuer and its agents. Clients holding securities of European companies or issuers are also entitled to receive confirmation of proxy votes, which may be requested via dg.msg-proxy@ml.com. Delivery of Trade Confirmations on a Periodic Basis You may elect to receive trade transaction information on a periodic basis (at least quarterly) in lieu of trade-by-trade confirmations for an Account unless (1) it is enrolled in Personalized Strategy with Client Discretion or (2) the assets in your Account are held at an Affiliated Custodian or Unrelated Custodian. In our discretion and from time to time, we will take action to ensure trade-by-trade confirmation delivery for your Account if you are not eligible to elect periodic delivery of trade confirmations. To receive periodic trade transaction information, you must make an election on the “Account Elections/Signature Page” in your Agreement, attest to this election within our electronic enrollment tool, or provide us with a separate written letter of authorization. The election to have periodic delivery of trade confirmations will apply to the eligible Accounts you designate until you instruct your Advisor or MFSA to the contrary. You can rescind this election at any time. If you enroll in the electronic delivery service for trade confirmations at mymerrill.com after this election, we will provide you with an electronic communication of your periodic trade transaction information being available for your review in your inbox at mymerrill.com. Your Program Report will indicate whether you have elected the periodic delivery of trade confirmations option. Making this election will not result in any change to the Program Fee and is not a condition to receiving the Program Services. You may request to receive, at no additional cost, trade-by-trade confirmations for transactions effected for your Account for up to one year after we send the last periodic statement reflecting those transactions. You may request interim updates and further details concerning any transaction by calling your financial advisor or reviewing your activity at mymerrill.com. If your Account is enrolled in Custom Managed Strategy with Client Discretion, any election that you make for periodic delivery of trade confirmations will only apply as to trades that occur as part of a Style Manager Strategy that is included in the Account. If you include mutual funds and ETFs in the Account, you will receive trade by trade confirmations as to any transactions related to those securities. Delivery of Program Materials and Electronic Access When you enroll in the Program, you acknowledge in the Agreement that you received certain Program materials, such as this Brochure, the ADV Part 2B Brochure Supplements and other related materials applicable to your enrollment. Additional copies may be requested from your Advisor or MFSA at any time and will be provided without charge. For your reference and convenience, we have posted this Brochure and other information at mymerrill.com/ADV/ materials. We provide access to Style Manager disclosure documents and brochures by the digital media format at mymerrill.com/ADV/materials. We provide access to Profiles of any Style Manager Strategies you select by the digital media format at Merrill website address provided to you in your enrollment materials and in the Program Reports or communications that you receive from us about your selection. You may request a paper copy of these disclosure documents and Profiles at any time from your Advisor or MFSA. For clients that have selected a PAS Style Manager Strategy, the PAS Manager, and not Merrill, will provide you with copies of the PAS Manager disclosure documents and brochures. We have posted these materials for your information and convenience at mymerrill.com/ADV/materials. Profiles of any PAS Style Manager Strategies are provided to you in the digital media format at Merrill website address provided to you in your enrollment materials and in your Program Reports or communications that you receive from us about your selection. You may revoke your consent to electronic delivery of Program documents, disclosures and Style Manager disclosure documents and brochures and receive paper copies by contacting your Advisor or MFSA. From time to time, we may deliver paper copies of documents relating to your Account notwithstanding your Account preference. Investment Advisory Program Brochure | 23 IAPB-032025 If you consent to electronic delivery at mymerrill.com, you will generally authorize us to deliver Program documents, disclosures and notices to you electronically. There are separate procedures for enrollment and unenrollment through mymerrill.com. In accordance with any such consent, we will send electronically certain Program materials, including the Brochure, any Account-specific documents (and any changes or amendments), Program Reports as well as other Program notices and materials. Electronic delivery through this process may not be available for all Program-related communications, and, in that case, we will send paper copies to you. Certain of our materials, including this Brochure, are accessible to clients as required under the Americans with Disabilities Act (ADA) and other of our Program materials, including your Program Report, will be provided to you in an ADA compliant format upon request to your Advisor or MFSA. Optional Account Services Merrill and MAA offer you the ability to elect certain optional services for your Account to help meet certain of your goals and objectives for the Account. Except as otherwise provided in the Agreement, neither Merrill, MAA nor our Affiliates, employees, or agents will be liable for any loss or expense that may result from your use of any of these optional Account Services. There could be current tax consequences with any transaction occurring under these optional Services. Neither we nor our financial advisors provide tax, accounting or legal advice and you should review any planned financial transactions or arrangements with your professional tax or legal advisors for these matters. MAA Tax Efficient Management Overlay Services For those Accounts that have selected eligible Style Manager Strategies, we make available certain tax efficient management overlay services (each, a TEM Overlay Service) that are intended to help manage the investment activity in a more tax-efficient manner as considered under U.S. tax rules and regulations. Through rules-based rebalancing, portfolio management and loss harvesting approaches, the TEM Overlay Services generally try to increase post-tax value for the electing Account by seeking to: • Opportunistically sell securities that have a loss and invest proceeds in strategy-aligned replacement securities for at least 30 days. • Engage in tax lot management by prioritizing sales of securities that result in the lowest tax cost, as circumstances warrant. • Defer short-term gains by restricting sales of short-term tax lots if the tax lot holding period will go long-term within 31 days or less. • Engage in tax efficient management by realigning the Account’s portfolio to underlying Style Manager Strategy weights and giving a sell preference to depreciated securities. • Overweight gains and underweight losses by not selling appreciated securities and selling depreciated securities relative to the underlying Style Manager Strategy, as circumstances warrant. • Avoid wash sales in the Account. We describe the available TEM Overlay Services in offering materials (available at mymerrill.com/ADV/materials), including the approach for the particular TEM Overlay Service and the related risks and limitations. You should read these offering materials carefully. The risks and limitations associated with the TEM Overlay Services and other TEM-related Offerings are also covered in this Brochure in the section “Tax Matters.” You can elect that a TEM Overlay Service apply to an Account with verbal instructions to your Advisor. By selecting a TEM Overlay Service, you authorize MAA to effect the TEM Overlay Service or Services selected and the related securities transactions on an ongoing basis without making any additional contact with you. This authority will continue in effect until you change or cancel the TEM Overlay Service (which you may do at any time) or terminate the associated Account from enrollment in the Program. The TEM Overlay Services will only be available to taxable Accounts that have enrolled in a Managed Strategy or Custom Managed Strategy and have selected as investments for that Account a Style Manager Strategy or Strategies that are eligible for the TEM Overlay Services and/or mutual funds and ETFs. The TEM Overlay Service will only take into consideration the trading activity that occurs in that enrolled Account and will only apply to eligible investments within the Account for which it was selected. It therefore may not apply to all investments or managed strategies that are part of a Custom Managed Strategy. If there are any Reasonable Investment Restrictions in place for the enrolled Account, MAA will seek to take those investment restrictions into consideration when applying the TEM Overlay Services and identifying appropriate replacement securities (if any). MAA may add to the TEM Overlay Services that it offers from time to time. There is no separate or additional fee that is charged by Merrill or MAA for adding one or more of the TEM Overlay Services to an eligible Account. MAA reserves the right to charge a fee for any TEM Overlay Service upon prior written notice. We make no guarantee that any tax liability in the Account will be reduced or that any indicated limits or mandates will be met. MAA can, in light of other considerations in an Account, effect transactions even though they may generate tax liabilities, including short-term taxable income, or exceed or violate any of the limits or mandates identified by the client. If the client discontinues TEM Overlay Services, MAA will manage the investments in the Account as if the Account was never tax-managed, which may result in the recognition of significant short-term taxable gains. MAA will not be responsible for any such gains that may be realized in managing the client’s Account after the termination of TEM Overlay Services. TEM Overlay Services are not available to be selected for an Account that has invested in a PAS Style Manager Strategy. If you have tax requests or instructions with respect to that Account, you must separately request the PAS Manager to implement investment instructions providing for tax-efficient management of the Account. Rebalancing Service and Automatic Contribution/Withdrawal Service For any of your Accounts having a Personalized Strategy with Client Discretion, you may enroll at no additional cost in (1) the Rebalancing Service which offers scheduled automatic rebalancing of selected securities in your Account and/or (2) the Automatic Contribution/Withdrawal Service which offers scheduled contributions to or withdrawals from your Account. The Rebalancing Service and the Automatic Contribution/Withdrawal Service are referred to as “Automatic Services.” Only certain equity securities, mutual funds, ETFs, NTFs, publicly traded closed-end funds and cash and cash alternatives are eligible for these optional Services. We may, from time to time, change which assets will be eligible. You can enroll in either of these Automatic Services by executing the required written letter of authorization (Automatic Service LOA) which sets forth the terms and conditions of, and enrolls you in, the service that you select. You authorize us in the Automatic Service LOA (which supplements your Agreement) Investment Advisory Program Brochure | 24 IAPB-032025 to effect the chosen scheduled service and related securities transactions) on an ongoing basis without making any additional contact with you. Your instructions will continue in effect until any expiration date in the Automatic Service LOA is reached (if applicable), you change or cancel your instructions or your Account is terminated. You can change or cancel your instructions at any time. We may terminate the offering of these optional Automatic Services at any time upon prior notice to existing participants. Having an Account with an Automatic Service may affect other of your Accounts that enroll in a TEM Overlay Service or that invest in a Direct Indexing/TEM Style Manager Strategy or a PAS Direct Indexing/TEM Style Manager Strategy. See “Item 4 Tax Matters.” The Program Fee and Other Charges Program Fee and Services Covered by the Program Fee You agree to pay the Program Fee to Merrill for the Program Services provided under the Agreement for each Account. The Program Fee for each Account is the sum of (1) the Merrill Lynch Fee and (2) the Style Manager Fee or PAS Manager Fee if you chose a Style Manager Strategy and/or a PAS Style Manager Strategy for your Account, as applicable. Note the following: • The Merrill Lynch Fee is the fee charged by Merrill for the Program Services that Merrill and its financial advisors provide under the Program based on a fee rate determined as set forth below (Merrill Lynch Fee Rate). • The Style Manager Fee is the fee charged by the Style Manager if a Style Manager Strategy is selected for your Account as determined below. • The PAS Manager Fee is the fee charged by the PAS Manager if you select a PAS Style Manager Strategy for your Account as determined below. The Style Manager Fee and PAS Manager Fee may also be referred to collectively as the “Manager Fee.” P R O G R A M F E E Each of your Accounts may be subject to a different Program Fee which will be calculated separately for each Account. Your Program Fee is payable monthly in advance and generally will be calculated based on the value of the assets in your Account as of the last business day of the prior month. Unless otherwise agreed to between you and Merrill in writing, the Program Fee and any other fees payable under the Agreement will be deducted directly from your Account. The Program Fee does not include all of the charges that may apply to your Account. Please see the heading “Fees and Expenses Not Covered by the Program Fee” below. Information about the Program Fee and rates applicable to each of your Accounts will be shown in a Program Report that we prepare for you. We will send you a Program Report upon enrollment into the Program and provide an updated Program Report when you enroll any new Accounts, make certain changes to your Account or Portfolio Group and if there are any changes made to your Merrill Lynch Fee Rate other than, as applicable, as a result of your Account or Portfolio Group qualifying for a different rate based on an applicable rate schedule. For participating TMAs which are accounts over which BANA has investment discretion, please refer to your trust agreement and/or TMA Brochure and Fee Schedule in addition to this Program Brochure for information relating to fees and expenses and other matters regarding your TMA account. The Program provides you with ongoing fiduciary investment advice and guidance for your Portfolio. The Merrill Lynch Fee component of the Program Fee is an asset based fee that covers the various services we and our financial advisors provide in the Program. The Program Fee covers our and, as applicable, a Style Manager’s or PAS Style Manager’s investment advisory services, including investment advice and guidance under the Program, access to investment strategies and ongoing monitoring as described in this Brochure, as well as trade execution, clearance and settlement of transactions, custody of assets and reporting and other administrative services. The Program Fee will not be adjusted for your use of, or failure to use, the Program Services, including (1) the level of your trade activity (including low or no trading activity); (2) your choice of a Style Manager Strategy or a PAS Style Manager Strategy where the manager engages in trading activity away from us for certain security types; (3) your decision to custody your assets at a financial institution other than Merrill; (4) the level of Excluded Assets (as defined below) in an Account; or (5) your determination to not implement or follow the investment advice we provide to you within Personalized Strategy with Client Discretion and Custom Managed Strategy with Client Discretion or for Program Strategy type selection. Obtaining incidental services and trade execution should not be a principal consideration in deciding to enroll or remain in the Program. We offer similar programs and/or investment strategies in different sales channels and at different fee levels. The Program Fee (or component of the Program Fee) paid by a client may be higher or lower than the fees other clients pay in the same Program or another investment advisory program and/or the cost of similar services offered through other financial firms. See “Ability to Obtain Certain Services Separately and for Different Fees” in this Item 4. The Merrill Lynch Fee Component of the Program Fee The Merrill Lynch Fee Rate—Working with an Advisor. We have set the maximum Merrill Lynch Fee Rate for the Program at 1.75%. The Merrill Lynch Fee Rate is negotiable, meaning you and your Advisor may agree to a Merrill Lynch Fee Rate for an Account that is lower than 1.75%. In addition, the following requirements and information apply: • The Merrill Lynch Fee Rate that applies to your Account is the rate agreed to between you and your Advisor for the Account and that is set forth in a Program Report provided to you by us upon enrollment. This rate can be either set up as a specified rate or determined by reference to a schedule with different rates based on asset levels (a Merrill Lynch Fee Rate schedule). • The maximum Merrill Lynch Fee Rate that can be charged under the Program is 1.75%. This maximum Merrill Lynch Fee Rate is subject to change from time to time upon notice to you. Your continued use of Program Services after this notice will constitute your agreement to the change in the maximum Merrill Lynch Fee Rate. • You and your Advisor may agree to a Merrill Lynch Fee Rate for an Account that is lower than the maximum rate. The extent to which you and your Advisor agree to a rate that is lower than the maximum Merrill Lynch Fee Rate is solely within your and your Advisor’s discretion and is subject to our policies regarding the Program. • You and your Advisor can agree to a different Merrill Lynch Fee Rate for each of your Accounts. • If you and your Advisor subsequently agree to a change to the Merrill Lynch Fee Rate applicable to your Account, we will provide you an updated Program Report to reflect this change. You will not receive an updated Program Report as a result of your qualifying for a different rate based on an applicable Merrill Lynch Fee rate schedule. Your continued use of our Program Services will be confirmation by you of your agreement to any such change to the Merrill Lynch Fee Rate reflected in the updated Program Report Investment Advisory Program Brochure | 25 IAPB-032025  • If you and your Advisor agree to a Merrill Lynch Fee Rate schedule for an Account based on asset levels, for purposes of determining the Merrill Lynch Fee Rate from month to month, we will consider the value of the assets in your Account and the value of certain assets and liabilities (Household value) held by you and/or others in your designated household at Merrill and its Affiliates (Household), as determined by us in accordance with our polices. This may result in a Merrill Lynch Fee Rate that is lower than the one that would have been applicable to your Account if only the value of your Account assets were used in making such determination. Once determined, the applicable Merrill Lynch Fee Rate will apply to that Account and generally will not change within any given month even if there are fluctuations in the value of your Account and/or your Household value. At any time, we may decide to no longer consider the Household value in determining a Merrill Lynch Fee Rate for an Account where a schedule has been agreed to. We have a financial incentive and related conflict of interest if our decisions relating to use of the Household value results in a higher Merrill Lynch Fee Rate for an Account because it results in a greater amount of Merrill Lynch Fees paid to us and more compensation to your Advisor. • In certain instances and in our discretion and in the manner we determine in our discretion, we may waive, reduce or rebate for a period of time some or all the monthly Merrill Lynch Fee applicable to your Account or other Merrill client accounts enrolling or enrolled in the Program. Any such waiver, reduction or rebate will not necessarily apply to all clients enrolled in the Program. We may make available introductory offers for the Program to certain clients, including institutional clients and/or their employees, through promotional programs. Merrill compensates your Advisor on an ongoing basis derived from the Merrill Lynch Fee Rate that applies to your Account. When considering whether to offer or agree to charge a lower Merrill Lynch Fee Rate, an Advisor typically will consider a number of factors, including the type and size of your Account, the breadth of our relationship with you, your engagement with the Advisor, the Program Strategy type you selected for your Account, competitive considerations and how Merrill compensates the Advisor. Because the amount of compensation paid to your Advisor is based on the Merrill Lynch Fee Rate for your Account, your Advisor has a financial interest in that Rate. In general, Advisors receive “production credits” toward their compensation formula based on the amount of the Merrill Lynch Fee that you pay for your Account. Merrill’s policies result in Advisors receiving fewer production credits (by 10% or more) if the weighted average of the Merrill Lynch Fee Rates for a client’s Accounts and for Accounts that are part of the Household is lower than the rate levels for specific wealth asset tiers that Merrill establishes. Merrill and Advisors have a conflict of interest based on this structure because the Advisor is incentivized not to offer a Merrill Lynch Fee Rate below such rate levels since that would reduce their compensation earned. In addition, as part of Merrill’s practice management guidance, Merrill provides Advisors statistical information about the Merrill Lynch Fee Rates charged in the Program. This information can encourage Advisors to not agree to a lower Merrill Lynch Fee Rate. The selection of the Program Strategy types of Defined Strategy, Personalized Strategy with Advisor Discretion and Personalized Strategy with Client Discretion result in you only paying the Merrill Lynch Fee component of the Program Fee. The Program Strategy types of Managed Strategy and Custom Managed Strategy can involve you only paying the Merrill Lynch Fee component of the Program Fee if, for example, the selected Style Manager Strategy has no Manager Fee and/or your Account in Custom Managed Strategy only invests in mutual funds or ETFs. Recommending Program Strategy types, Style Manager Strategies and PAS Style Manager Strategies where the Program Fee for the Account consists solely of the Merrill Lynch Fee present the Advisor with an opportunity to negotiate a higher Merrill Lynch Fee Rate than might otherwise be the case for an Account with a Manager Fee. This opportunity provides the Advisor with an incentive to recommend Program Strategy types with only a Merrill Lynch Fee or to include a Style Manager Strategy or PAS Style Manager Strategy with no Manager Fees over such Strategies that have Manager Fees. The ability to negotiate a higher Merrill Lynch Fee Rate benefits Merrill as well as the Advisor since Merrill retains a certain percentage of the Merrill Lynch Fee. Merrill typically pays a portion of the Merrill Lynch Fee it receives from each client to the Advisor for that client. The exact portion paid by Merrill to the Advisor varies among the Advisors and depends on factors such as each Advisor’s overall annual revenue production. The amount received by an Advisor as a result of a client’s participation in this Program may be more than the Advisor would receive if the client participated in certain other of our investment advisory programs, or paid separately for investment advice, brokerage and other services covered by the Merrill Lynch Fee. In those circumstances, the Advisor has an incentive to recommend an investment advisory program that would pay higher compensation. If you work with an Advisor as opposed to an MFSA, the Merrill Lynch Fee Rate you agree to with your Advisor for your Account could be higher than the Merrill Lynch Fee Rate that is applied to your Account when working with an MFSA even where you may select a Style Manager Strategy for your Account that is also available when working with an MFSA. For more information about Advisor conflicts, see “Item 9 Compensation, Conflicts of Interest and Material Relationships at the sections “Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel-Advisor Compensation” and “Account and Program Choice.” The Merrill Lynch Fee Rate—Working with an MFSA. Where you work with an MFSA as your financial advisor, based on qualifications and our internal policies, you will be limited to selecting the Managed Strategy as your Program Strategy type and then to selecting certain designated Style Manager Strategies. In light of the limited capabilities that an MFSA can offer under the Program, the Merrill Lynch Fee Rate applied to your Account is determined based on the following Merrill Lynch Fee Rate schedule for Accounts where you work with an MFSA: • 1.10% where your assets are below $2 million. • 1.00% where your assets are at $2.0 million and above. The maximum Merrill Lynch Fee Rate that can be charged when working with an MFSA under the Program is 1.10%. The Merrill Lynch Fee Rate schedule applicable to Accounts serviced by MFSAs is subject to change from time to time, upon notice to you. Your continued use of Program Services after this notice will constitute your agreement to the change in the Merrill Lynch Fee Rate. For purposes of determining the Merrill Lynch Fee Rate from such schedule, we will consider the value of your Account assets and the Household value. This may result in a Merrill Lynch Fee Rate that is lower than the one that would have been applicable to your Account if only the value of your Account assets were used in making such determination. Once determined, the applicable Merrill Lynch Fee Rate will apply to that Account and generally will not change within any given month even though there may be fluctuations in the value of your Account and/or the Household value during the month. At any time, we may decide to no longer consider using the Household value in determining a Merrill Lynch Fee Rate under this schedule. We have a financial incentive and related conflict of interest if our decisions relating to use of the Household value results in a higher Merrill Lynch Fee Rate for an Account because it results in a greater amount of Merrill Lynch Fees paid to us. The Merrill Lynch Fee Rate applicable to your Account is determined and adjusts based on the level of assets at the end of a billing period. It may vary from month to month but generally will not change within any given month. Investment Advisory Program Brochure | 26 IAPB-032025 Merrill has the discretion to approve a Merrill Lynch Fee Rate that is lower than the rates in the schedule above. The extent to which we agree to and approve any such lower rate is solely within your MFSA’s and our discretion and is subject to factors that we determine in our discretion and which may change. For more information on MFSA compensation, see “Compensation, Conflicts of Interest and Material Relationships—Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel-MFSA Compensation and Awards” in Item 9. The Manager Fee Component of the Program Fee Style Manager Fee Component of the Program Fee. If you select a Style Manager Strategy for your Account, your Program Fee will consist of the Style Manager Fee, if any, for each such Style Manager Strategy selected and the Merrill Lynch Fee component discussed above. The Style Manager Fee is a fee charged by a Style Manager based on the assets invested in the Style Manager Strategy and the rate set by the Style Manager either as a specified rate or by reference to a schedule implemented for that Style Manager Strategy by the Style Manager (Style Manager Rate). Certain Style Manager Strategies have no Style Manager Fee Rate. The following applies to the determination and calculation of the Style Manager Fee component of the Program Fee: • The Style Manager Strategy List (accessible at mymerrill.com/ADV/materials and available from your Advisor or MFSA) provides a listing of the Style Manager Strategies available in the Program and their associated Style Manager Rates schedule or schedule of rates. The Profile for the Style Manager Strategy will also indicate the applicable Style Manager Rate or whether a schedule applies. • The Style Manager Rates will vary, even for comparable strategies, depending on the Style Manager Strategy. Certain Style Manager Strategies have no Style Manager Fee or have a lower rate than others. The Style Manager Rates (and the maximum Style Manager Rates in the Style Manager Rate schedules, if applicable) generally range from 0.00% to 0.65%. If a Style Manager Strategy is offered that has a Style Manager Rate above 0.65%, you will be provided with prior notice through the Profile or otherwise prior to its selection. • The Style Manager Rate (including the rates in the Style Manager Rate schedule) may change from time to time and you will receive notice of any Style Manager Rate increase for a Style Manager Strategy. • Where a Style Manager Rate schedule based on assets is applicable to the Style Manager Strategy selected for your Account, in determining the applicable Style Manager Rate from month to month, we and the Style Manager will consider the value of the assets in your Account and in the Accounts and other accounts of your Household that are invested in the Style Manager Strategy and the other Style Manager Strategies of the Style Manager (other than assets invested in in any PAS Style Manager Strategy of the Style Manager). This may result in a Style Manager Fee Rate that is lower than the one that would have been applicable to your Account if only the value of your Account assets were used in making such determination. The Style Manager Rate applicable to your Account may vary from month to month based on the fluctuations in the value of these assets. At any time, we and a Style Manager may decide to no longer consider these assets in determining a Style Manager Rate for an Account selecting a particular Style Manager Strategy where a schedule applies. • If the Program Strategy selected includes a combination of Style Manager Strategies, each applicable Style Manager Rate will be applied proportionately to the value of your assets in your Account with each Style Manager Strategy. In the event that the actual asset allocation is not available, the strategy allocation of the Style Manager Strategies (instead of your actual allocation) will be used to calculate the Style Manager Fee component of the Program Fee. Once calculated, the Style Manager Fee will be charged to the account as a blended rate. Recommending Style Manager Strategies that charge no Manager Fee or have lower Manager Rates than others present the Advisor with an opportunity to negotiate a higher Merrill Lynch Fee Rate than might otherwise be the case. The opportunity to negotiate a higher Merrill Lynch Fee Rate provides the Advisor with a financial incentive to recommend Style Manager Strategies with no or lower Manager Fees over other Style Manager Strategies. The ability to negotiate a higher Merrill Lynch Fee Rate benefits Merrill as well as the Advisor since Merrill retains a certain percentage of the Merrill Lynch Fee. For more information, see “Compensation, Conflicts of Interest and Material Relationships—Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel-Advisor Compensation and Awards” in Item 9. PAS Manager Fee Component of the Program Fee. If a client selects a PAS Style Manager Strategy for their Account, the client will be charged a PAS Manager Fee for the PAS Style Manager Strategy. The PAS Manager Fee is a fee charged by a PAS Manager based on the assets invested in the PAS Style Manager Strategy and the rate agreed to between the client and the PAS Manager (PAS Manager Rate), which can be a fixed specified rate or a rate determined by an agreed-upon fee rate schedule. The following applies to the determination and calculation of the PAS Manager Fee component of the Program Fee: • The PAS Manager Rate is a negotiated rate or a negotiated fee schedule, in each case, determined between the client and the PAS Manager. The PAS Manager has complete discretion in determining the PAS Manager Rate with the client, including whether to charge, waive or discount the rate. It will take into account any number of factors or criteria, including, among other things, the nature of the PAS Style Manager Strategy, the complexity of the Accepted Investment Instructions, the nature of the client requests for their Account, the PAS Manager’s own competitive considerations, the size of the client’s assets and anticipated investment opportunity, the client’s household value, the overall relationship with the PAS Manager, Merrill’s relationship with the PAS Manager, the size of Account investment, the breadth of the client’s relationship with Merrill and/or with other financial institutions with which the PAS Manager does business. At any time, the PAS Manager can decide to no longer consider these criteria in determining its PAS Manager Fee rate for a client. • The client can accept or decline any proposed PAS Manager Rate as part of the negotiation process. • The Style Manager Strategy List (accessible at mymerrill.com/ADV/materials and available from your Advisor) provides a listing of the PAS Style Manager Strategies available in the Program and their associated maximum PAS Manager Rate. The Profile for the PAS Style Manager Strategy will also indicate the applicable maximum PAS Manager Rate. • The PAS Manager informs Merrill of the agreed-upon PAS Manager Rate in the form required by Merrill. Merrill will include the PAS Manager Fee rate in the Program Report provided to you at time of enrollment. The PAS Manager Fee rate that is provided to us by the PAS Manager will apply until we are provided with notice from the PAS Manager in the form required by Merrill that a different rate has been agreed to between you and the PAS Manager. We will provide you with notice upon any change to such rate (other than as result of a rate change within the agreed upon fee schedule). • Where a PAS Manager Rate schedule based on assets is applicable to the PAS Style Manager Strategy selected for your Account, in determining the applicable PAS Manager Rate from month to month, the PAS Manager will consider the value of the assets in your Accounts invested in, and in other of Investment Advisory Program Brochure | 27 IAPB-032025 your accounts and those of your Household invested in, the PAS Style Manager Strategy and in other PAS Style Manager Strategies of the PAS Manager. This may result in a PAS Manager Fee Rate that is lower than the one that would have been applicable to your Account if only the value of your Account assets were used in making such determination. The PAS Manager Rate applicable to the your Account may vary from month to month based on the fluctuations in the value of these assets. At any time, a PAS Manager can decide to no longer consider these assets in determining a PAS Manager Rate for an Account selecting a particular PAS Style Manager Strategy. • In certain instances, the PAS Manager may waive, reduce or rebate the PAS Manager Fee applicable to a client’s Account or to other clients’ Accounts enrolling or enrolled in the PAS Style Manager Strategy. Any such waiver, reduction or rebate will not necessarily apply to all clients enrolled in the Program. Recommending PAS Style Manager Strategies that charge no Manager Fee or have lower PAS Manager Rates than others present the Advisor with an opportunity to negotiate a higher Merrill Lynch Fee Rate than might otherwise be the case. The opportunity to negotiate a higher Merrill Lynch Fee Rate provides the Advisor with a financial incentive to recommend PAS Style Manager Strategies with no or lower Manager Fees over other PAS Style Manager Strategies. The ability to negotiate a higher Merrill Lynch Fee Rate benefits Merrill as well as the Advisor since Merrill retains a certain percentage of the Merrill Lynch Fee. For more information, see “Compensation, Conflicts of Interest and Material Relationships—Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel-Advisor Compensation and Awards” in Item 9. Payment of the Program Fee Initial Program Fee Assessment. When you enroll a new Account in the Program, an initial Program Fee will be assessed during the week following the date on which you have contributed the required minimum level of assets to the Account for the Program Strategy you select. The initial Merrill Lynch Fee component of the Program Fee will be calculated and paid to Merrill based on: (1) the value of the assets in your Account as of the earlier to occur of the last business day of the week or the last business day of the month following required funding and (2) one-twelfth (1/12) of the annual Merrill Lynch Fee Rate applicable to such value, prorated based on the number of days remaining in the month from the date of required funding. The initial Manager Fee component of the Program Fee (e.g., the Style Manager Fee and/or the PAS Manager Fee) will be calculated based on: (1) the value of your assets in your Account for the Style Manager Strategy or PAS Style Manager Strategy, as the case may be, as of the earlier to occur of the last business day of the week or the last business day of the month following required funding and (2) one-twelfth (1/12) of the annual Style Manager Rate or PAS Manager Rate applicable to such value, prorated based on the number of days remaining in the month from the date of required funding. Monthly Program Fee Assessment. After the initial Program Fee, the Program Fee is typically charged to your Account during the first week of the current calendar month. The Merrill Lynch Fee component will be calculated and paid to Merrill based on: (1) the value of the assets in your Account as of the last business day of the previous calendar month and (2) one-twelfth (1/12) of the annual Merrill Lynch Fee Rate applicable to such value. Similarly, after the initial Manager Fee, the Manager Fee component will be calculated based on: (1) the value of your assets in your Account for each Style Manager Strategy or PAS Style Manager Strategy as of the last business day of the previous calendar month and (2) one-twelfth (1/12) of the annual Style Manager Rate or PAS Manager Rate applicable to such value. The following changes to your Account that occur during the month will not change the Program Fee calculated for the month but will be applied in determining the next month’s Program Fee. These include but are not limited to: • Changes in the value of your Program Account. • Fluctuations in the value of your assets and liabilities that we, in our discretion, have decided to consider or to no longer consider in calculating the Program Fee. • Changes in the Program Strategy type. • Changes in the individual Style Manager Strategies or PAS Style Manager Strategies selected or your allocations among them. • Changes in the Merrill Lynch Fee Rate or the Style Manager Rate or PAS Manager Rate (either as a specified rate or in the form of a schedule). This means that any fee rate change associated with any such change will be implemented for purposes of determining the next month’s Program Fee and there will be no interim adjustment if such events happen intra-month. Treatment of the Program Fee upon Termination of Your Account or Certain Program Strategy Changes. If you or we terminate your Account, we will refund to you a pro-rata portion of the Program Fee based on the number of calendar days remaining in the month. The refund, if any, will be applied to your Account typically during the week following Account termination. For more information, see “Item 4 Funding and Operation of Accounts.” If you make certain changes to your Program Strategy, we consider the change as an initial enrollment into the new Program Strategy and we will calculate the Merrill Lynch Fee and any applicable Manager Fee for the remainder of the month of the change as outlined in the section “Initial Program Fee Assessment” above. How the Program Fee is Charged General. Except as noted, you will be charged the Program Fee on all assets in your Account, including cash and cash alternatives. Generally, all Account values used to determine the Program Fee are based on the value of the assets in your Account, as determined by us. In calculating such Account values, we will use a variety of pricing sources, including our Affiliates. When utilizing a Style Manager or a PAS Manager, there may be a difference in the determination of the Account values for the Style Manager Fee or PAS Manager Fee versus the Merrill Lynch Fee applicable to your Account. Cash and Cash Alternatives. The Program Fee will be applied to any cash and cash alternatives held within your Account, including (1) cash that is treated as a cash balance which is automatically swept into a cash sweep option applicable to your Account in accordance with the Cash Sweep Program; (2) cash in your Account due to your having chosen the “No Sweep” option for your cash balances; and (3) cash alternatives held in the Account such as money market funds. The Program Fee is in addition to other compensation that we and our Affiliates earn on cash and cash alternatives held in your Account. Depending on interest rates and other market factors, the yield that you earn on cash balances and cash alternatives has been, and can be in the future, lower than the Program Fee that you pay on assets held in your Account. As a result, depending on the interest rate environment, you may experience a negative overall investment return with respect to cash and cash alternatives and, in some situations, the effective return on cash held in a bank deposit account can be negative. For more information on the treatment of cash, see “Item 4 Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services” and “Item 4 Funding and Operation of Accounts—Cash Balances.” Investment Advisory Program Brochure | 28 IAPB-032025 Assets Held with a Custodian other than Merrill. If you maintain the assets in your Account with an Affiliated Custodian or an Unrelated Custodian, we will calculate the Program Fee based on information provided by such custodian, which may use a different method to value the securities in the Account than we do. We will not be responsible for verifying the accuracy of information provided by such custodian regarding your Account or any losses or errors that result from that information. For information regarding the billing methodology used for Accounts with such a custodian (including the circumstances relating to the addition of new Accounts or termination of Accounts), please speak with your Advisor or MFSA. Annuities. Valuations of Annuities used to calculate the Program Fee will be based on the daily end-of-day contract values provided by the Annuity Issuer. We provide no assurance that the end-of-day contract values given to us by the Annuity Issuer and used to calculate the Program Fee are accurate and we do not verify the Annuity contract values provided. Alternative Investment Funds. We generally calculate the Program Fee on an investment in an Alternative Investment Fund (an AI Advisory Unit) on the basis of estimated and unaudited net asset values provided to us on a periodic basis by the investment manager of the Alternative Investment Fund. An Alternative Investment Fund includes a hedge fund, private equity fund, managed futures fund, non-traded business development company, non-traded real estate fund, real asset fund, commodity pool, interval fund, or any other Fund that invests in alternative asset classes or other Funds that invest in whole or in part in any of the foregoing types of Funds. We use the most current valuations that we have been provided to calculate the portion of the Program Fee attributable to your investments in AI Advisory Units. We provide no assurance that the estimated net asset values given to us by an investment manager of the Alternative Investment Funds are accurate and we do not verify the valuations provided by them. It is possible that we will be using a valuation that does not reflect the current net asset value of the particular AI Advisory Units as of the date that the Program Fee is actually calculated for your Account. We will not make any adjustments to your Program Fee if the actual net asset value is subsequently updated. For more information about how net asset value for the AI Advisory Units is determined by the investment manager of the particular Alternative Investment Fund, please refer to the offering materials for the relevant Alternative Investment Fund. The foregoing approach is not applicable to NTFs. The valuation of a non-traditional mutual fund is based on the fund’s net asset value and the valuation of a non-traditional ETF is based on the closing market price. Treatment of Short Positions. The asset value of an Account with margin is based on the market value of the eligible assets, which is the long eligible portfolio value, minus the short cash and short options. All short equity, debt and ineligible securities are excluded from the asset value of the Account. Precious Metals. Valuations of Precious Metals held under the Precious Metals Program and used to calculate the Program Fee and applicable service fees will be based on average daily valuations provided by the third-party provider under the Precious Metals Program. Daily valuations will in turn be based on the closing average of the top three indicative bids for the relevant bar type and will not be verified by us. Assets Subject to Merrill Lynch Fee Deferral. We have determined that we will defer including in the calculation of the Merrill Lynch Fee component of the Program Fee the value of any securities purchased in your Account or transferred into your Account from your brokerage account that had been acquired in the past twelve months through a new-issue offering for which we or an Affiliate were paid under the terms of the new issue offering an underwriting discount, selling concession or other sales commission and as to which an Advisor receives sales compensation (Fee Deferred Assets). The deferral of charging the Merrill Lynch Fee on the Fee Deferred Assets will take place for a period of up to one year after the Fee Deferred Assets were purchased. This treatment does not apply to securities purchased in an initial public offering or other new-issue offering that we have determined should not be treated as Fee Deferred Assets and it will not apply in the circumstance when a client determines after the purchase of any such securities in their brokerage account to later enroll the brokerage account holding such securities in the Program in order to receive the Program Services. Please note that any securities purchased in a Merrill securities account, an account of an Affiliate or an account at another firm and/or that is moved to or becomes part of a Program Account will be subject to the Program Fee immediately other than as described above for Fee Deferred Assets. This means that the securities in such account that is enrolled in the Program are not considered Fee Deferred Assets and will be subject to the Merrill Lynch Fee Rate being applied immediately upon enrollment of the account into the Program. In these situations, you will have paid an up-front commission or transaction charge at the time of purchase because the security was purchased in a brokerage account where per trade charges and fees apply, and once the security is held in a Program Account, you will pay the Program Fee for the Program Services. Once the security is held in an Account enrolled in the Program, we and your Advisor receive compensation from charging the Merrill Lynch Fee Rate in respect of those securities. While the Account is enrolled in the Program, you will receive the Program Services and you will not pay any sales commissions for any subsequent sales or subsequent purchase transactions that would be charged if done in a brokerage account. You should assess your own trading patterns, objectives and intention to utilize the Program Services to determine whether purchases and sales of investment securities should be effected in your Program Account where the Program Fee will apply, whether transactions should be effected in a brokerage account where you will pay up-front commissions and whether such assets should be moved to or from the Account. We reserve the right to designate assets as Fee Deferred Assets and to re-designate a Fee Deferred Asset as an asset covered by the Program Fee without notice to you. Excluded Assets. We have designated certain assets as ineligible for the Program (Excluded Assets). These Excluded Assets are not subject to the Program Fee and are not entitled to access the Program Services. Accordingly, Merrill will not be obligated to provide any investment advice with respect to Excluded Assets, including making any recommendation with respect to the suitability, risks, sale or holding of the Excluded Assets. We may require you to transfer any Excluded Assets out of your Account. Failure to comply with a request to transfer out such Excluded Assets may result in the termination of the Account from the Program. Commissions or other transaction-based compensation apply to purchases and sales of Excluded Assets because we have not charged the Program Fee on the value of these securities. This compensation may be more or less than the Program Fee that would have been charged. We reserve the right to designate assets as Excluded Assets and to re-designate an Excluded Asset as an asset covered by the Program Fee without notice to you. Margin Balances. Margin debit balances do not reduce the value of the Account. Purchasing eligible securities with proceeds from a margin loan increases your Account value by the value of those positions. If the margin loan proceeds are reinvested in securities, the Account value will be affected by any changes in the value of those securities. You will also be charged margin interest on the debit balance in your Account. Margin interest is in addition to the Program Fee. The interest charges, combined with the Program Fee, may exceed the income generated by the assets in your Account and, as a result, the value of your Account may decrease. Investment Advisory Program Brochure | 29 IAPB-032025 Fees and Expenses Not Covered by the Program Fee Your Program Fee does not cover the following expenses, charges and costs, some of which are discussed in more detail below: • Dealer spread charges, mark-ups or mark-downs charged with respect to any principal transaction effected by us or our Affiliate or effected by a Discretionary Manager or PAS Manager with us or by an Affiliated Trade Counterparty acting as a dealer and fees that we or our Affiliate may receive in connection with our Affiliate’s role as a remarketing agent for certain VRDOs. • Dealer spread charges, mark-ups or mark-downs charged with respect to any transaction effected by us, a Discretionary Manager or PAS Manager with an Unaffiliated Trade Counterparty acting as a dealer. • Underwriting discounts, selling concessions or other transaction charges with respect to any new issue securities offering that we or our Affiliate may receive in connection with the offering, a portion of which may be used to pay your financial advisor. • Commissions, mark-ups or mark-downs, sales charges or penalties charged on purchases and sales of Fee Deferred Assets and Excluded Assets, a portion of which may be used to pay your financial advisor. • Margin interest and fees and charges, charged by us or third parties, imposed for any margin strategy or for any securities that are shorted as part of an options strategy and that are in limited supply (i.e., the shorted securities are “in demand”), a portion of which may be used to pay your financial advisor. • Transfer taxes. • Exchange fees, alternative trading system fees, required SEC fees or similar fees charged by third parties, including issuers. • Electronic fund, wire and other Account transfer fees, including any fees or mark-ups charged for foreign currency exchange or conversions relating to transfers or wires to or from your Account, a portion of which may be used to compensate your financial advisor. • Custodial fees and expenses associated with your use of an Affiliated Custodian or an Unrelated Custodian. • Commissions and charges for transactions in foreign ordinary securities and dealer spread charges, mark-ups or mark-downs in connection with foreign currency conversions, including transactions in foreign ordinary shares or ADRs or foreign currency wire transfers either in or out of your Account. • Fees, expenses and charges charged by Funds or by the managers or sponsors of Funds. • Fees and charges that are specific to Annuities or in respect of the Precious Metal program, including administrative and distribution fees, charges for optional benefits, surrender charges as well as charges for the underlying investment options. • Any other charges imposed by law or otherwise agreed to by you and Merrill with regard to your Account, including those charges payable to Merrill and/ or third parties as described in this Brochure. The Program Fee does not include certain fees and charges relating to transfers and terminations, certain corporate actions and banking related services, like lending, check-writing services, money transfers, wire transfers, including foreign currency wire transfers, and conversions. Certain of these fees and charges are detailed in the Merrill Schedule of Miscellaneous Account and Service Fees and the Explanation of Fees (as to fees and charges associated with foreign currency wire transfers and conversion), accessible ml.com/relationships. Please see the brokerage account agreement and account enrollment documents relating to brokerage services and related transactions and account fees for your Merrill account. If you have any questions about any charges or fees applicable to your Account, please consult with your financial advisor. For new issue securities offerings, you will pay the public offering price on securities purchased from an underwriter or selling group member involved in a public offering distribution and such public offering price may reflect costs incurred by the issuer in conducting the offering or distribution with such underwriter or dealer, which may be one of our Affiliates. For certain transactions effected by a Discretionary Manager or a PAS Manager, the trading-related charges and costs (dealer spreads, mark-ups or mark-downs) charged by the Affiliated Trade Counterparty or Unaffiliated Trade Counterparty acting as a dealer are included in the net price of the security and will not be reflected as separate charges on your trade confirmations or account statements. We will undertake, at your written request, to obtain the amount of this remuneration for a given transaction in your Account. For foreign ordinary securities transactions, a foreign Unaffiliated Trade Counterparty we use to effect the transaction will assess trading-related charges and costs and, to the extent a foreign currency conversion transaction is required, it will be remunerated in the form of a dealer spread or a mark-up/down. In addition, fees associated with transactions in foreign ordinary securities can also include local country costs and fees and stamp taxes. These costs, fees and commissions/dealer spreads are included in the net price of the security and will not be reflected as separate charges on your trade confirmations or account statements. We will undertake, at your written request, to obtain the amount of this remuneration for a given transaction in your Account. For investments in Funds, you will bear your proportionate share of such Fund’s fees and expenses including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. In addition, any Fund contingent deferred sales charge, redemption or other fees imposed by a Fund manager as a result of your redeeming the Fund (e.g., to invest in a particular Program Strategy) will be separate from, and in addition to, the Program Fee. The Program Fee does not cover or offset any fees and expenses that any Fund incurs for transactions occurring within the Fund itself, including commissions and other transaction-related charges incurred by the Fund, even if we or any Affiliate effect these transactions for the Fund or provide services to the Fund. All of these fees and costs may be material. An investor in a fund-of-funds or feeder fund vehicle will also bear a proportionate share of the fees and expenses of each underlying investment fund. Please consult the prospectuses and offering material for the Funds for more detailed information on the amounts charged. For investments in Annuities, you will be subject to fees and charges that are specific to these products, which may include, but are not limited to, mortality and expense risk charges, administrative and distribution fees, charges for optional benefits, surrender charges and charges for the underlying investment options. Over time, your total expenses to own an Annuity in an Account enrolled in the Program may be greater than the total expenses to own a similar Annuity in a brokerage account. For investments in Precious Metals, you will be subject to transaction and service fees which will be in addition to, and will not be covered or offset by, the Program Fees. A portion of the service fee you are charged by the third-party provider of the Precious Metals program will be allocated between the Investment Advisory Program Brochure | 30 IAPB-032025 provider and Merrill as compensation for ongoing sub-accounting, reconciliation, transaction and related expenses. Valuations of Precious Metals used to calculate these applicable transaction and service fees will be based on average daily valuations provided by the program provider. Daily valuations will in turn be based on the closing average for the top three indicative bids for the relevant bar type and will not be verified by Merrill. Please consult the Precious Metals Disclosure Document for the Precious Metals Program for further details on the amounts charged and allocation arrangements. Ability to Obtain Certain Services Separately and for Different Fees You may be able to obtain some of the same or similar Program Services or types of investments through a brokerage account or other investment advisory programs and services offered by Merrill. Many of the tools and analytics that are used to support services provided through the Program are also available through Merrill without enrolling in the Program and paying the Program Fee. However, while clients can obtain similar products and services from Merrill without enrolling in the Program, they would not receive the Program Services, including Account monitoring services and access to Style Manager Strategies and PAS Style Manager Strategies. Depending on your asset allocation, Program Strategy selection and Merrill Lynch Fee Rate, certain security types and investment strategies are available to you outside of the Program for more or less than you would pay in the Program. You may also be able to obtain some or all of the Program Services from other firms and at fees that may be lower or higher than the Program Fee we charge. When you compare the account types and investment advisory programs and their relative costs with what is available in the Program, you should consider various factors, including, but not limited to: • Your preference for a fee-based or commission-based relationship. • The nature and breadth of the offering and services provided in the programs you are comparing. • The qualifications of your financial advisor and what they are able to offer you based on their qualifications. • Whether the program has the features and framework to offer you the ability to manage your investment assets in the method you require or prefer. • The ability to access a wider range of investment solutions and products available to you in the Program, including Style Manager Strategies, PAS Style Manager Strategies, along with individual securities, including Funds. • The ability to choose whether to delegate or retain Authority. • Whether you want to work with your Advisor at the Merrill Lynch Fee Rate you agreed to in order to have the ability to access the complete range of available Managed Strategies and investment solutions available in the Program. • Whether you want to work with an MFSA who is qualified to offer you advice and guidance in the Program with respect to the Managed Strategy type only and as to a smaller number of Style Manager Strategies than an Advisor may offer you. • The types of investments available to you through a brokerage relationship. • The types of investment solutions available to you under the MGI and MGI with Advisor programs discussed in more detail below. • How much trading activity you expect to take place in your Account. • How much of your assets you expect to be allocated to cash. • The frequency and type of client profiling reports, performance reporting and account reviews that are available in a brokerage account and in the other investment advisory programs. We have provided you with materials that help to explain the various platforms and programs we offer, including the Form CRS and the Summary of Programs and Services, both of which are available at ml.com/relationships or from your Advisor or MFSA upon request. The MGI, MGI with Advisor and MEAA Programs. We offer the Merrill Guided Investing with Advisor program (MGI with Advisor), the Merrill Edge Advisory Account program (MEAA) and the Merrill Guided Investing program (MGI). These investment advisory programs have a different service model than what is available through the Program. For the MGI with Advisor and MEAA programs, you are provided advisory services from Financial Solutions Advisors (FSAs) who are available to you through our call center or at certain bank branch locations. With MGI, a self-guided investment advisory program through an interactive website, there is no advice or recommendations available from a financial advisor. From a service model perspective under the Program, you have direct access to, and advice and guidance from, your dedicated Advisor or your MFSA, as the case may be, whom you have personally selected and chosen to work with to discuss the particular investment strategy and available alternatives. The MGI with Advisor, MEAA and MGI programs offer only certain Style Manager Strategies constructed by our CIO (CIO Style Manager Strategies). Certain CIO Style Manager Strategies that they offer are also available through the Program. The program fee for MGI with Advisor and the MEAA programs is 0.85% and the program fee for the MGI program is 0.45%. Depending on the Merrill Lynch Fee Rate you pay for Program Services, you could access these same CIO Style Manager Strategies potentially at a lower cost through the MGI with Advisor MEAA and MGI programs; however, you will not have access to your dedicated financial advisor. In addition, through the Program, you have access to a much larger offering of Style Manager Strategies which includes Style Manager Strategies of third-party investment managers, the full complement of CIO Style Manager Strategies and the Merrill-managed Style Manager Strategies. In addition, you have the ability to access the full range of Program Strategy types and investment products and solutions which are not available in the MGI with Advisor, MEAA and MGI programs. Access to Managed Strategies through SPA and MAS and from BANA. Merrill makes available the Merrill Lynch Strategic Portfolio Advisor Service program (SPA), a dual contract investment advisory program. By enrolling into SPA, clients can access discretionary management services and investment strategies and related advisory and trading services of participating third-party and affiliated investment managers (each, a SPA manager). Participation in SPA requires the client and the SPA manager to enter into a separate contract that sets forth the terms of the SPA manager’s services and the negotiated, agreed upon SPA manager fee rate. In addition, the client will enter into the Merrill SPA agreement that provides, among other terms, for the payment of the Merrill SPA fee rate. The maximum Merrill SPA rate that can be charged is 1.50% for equity and hybrid SPA managed strategies and 0.70% for SPA managed fixed income strategies The SPA Fee Rate is subject to negotiation by the client and their Advisor. In certain circumstances, Merrill makes available the Merrill Lynch Managed Account Service program (MAS), a dual contract program which is designed to accommodate a client’s selection of a third-party investment manager that is not currently available in other Merrill investment advisory programs. Under this program, Merrill makes the investment strategy available on an exception basis where the client or the Advisor has a pre-existing relationship with the MAS manager prior to establishing an account relationship with Merrill. Investment Advisory Program Brochure | 31 IAPB-032025 BANA, our Affiliate, makes available certain of its managed strategies through the Program as Style Manager Strategies and as PAS Style Manager Strategies to Accounts and to TMA Accounts enrolled in the Program. These strategies may also be available directly through BANA outside of the Program including though the Select Portfolio Solutions program offered by BANA to its clients for which we provide investment-related services. The fee schedules applicable to TMA clients and clients with accounts directly through BANA are different from that offered in the Program and can be lower than the Merrill Lynch Fee Rate negotiated with an Advisor in light of the fact that the maximum BANA rate that can be charged is lower than the maximum Merrill Fee Rate that can be charged for the Program. In the Program, we may offer or make available from the same investment manager a Style Manager Strategy that is substantially similar to a PAS Style Manager Strategy. By selecting the Premium Access Strategy type for their Account, if eligible, the client has the opportunity to negotiate a lower rate for the PAS Style Manager Strategy than the specified Style Manager Strategy Rate for the Style Manager Strategy. Certain SPA Managers also participate in the Program as PAS Managers and/or Style Managers. There are important differences among the SPA and MAS programs, a BANA account relationship and this Program in terms of the involvement of your Advisor in providing ongoing advice, the services associated with the relevant investment advisory or trust program offering, structure and administration, the depth of research conducted on the managers available in the programs and the applicable fees. You may request a copy of the ADV program brochures for the SPA and MAS programs or TMA or trust account materials by contacting your Advisor. Funding and Operation of Accounts I Enrolling Your Account By signing the Agreement, you can enroll an Account and then any subsequent Accounts into the Program in the same account ownership capacity by providing verbal, electronic or written instructions. Examples of different account ownership capacities include an individual, a joint ownership capacity, a trustee of a trust, a personal representative or executor of an estate, a guardian for a minor, a business entity, a non-IRA retirement plan and an endowment. You may need to sign a separate Agreement if you want to open an Account in an account ownership capacity not covered in the originally signed Agreement. I F U N D N G & O P E R A T O N O F The effective date of the Agreement for each of your Accounts will be the date of its acceptance by us and will be set forth in the Program Report you receive. The effective date of a Program Strategy change will be the date that the change is entered and noted into our systems. Any preliminary discussions or recommendations provided to you before Merrill accepts the Agreement do not constitute investment advice under the Advisers Act and should not be relied on as fiduciary investment advice. Y O U R A C C O U N T Your request to enroll in the Program or to initiate a Program Strategy change is not considered a market order due to the requirements for enrollment, which includes funding as well as the administrative processing time needed to implement enrollment instructions. We will initiate Program Services for new Accounts after your execution of any required Account documentation, approvals and funding of the Account and expect such enrollment to occur promptly. The investment of assets in an Account will only occur when all operational requirements have been met. Account acceptance may be delayed or rejected if the account is overfunded, underfunded, or funded with ineligible assets. For Accounts that are in a Personalized Strategy with Advisor Discretion, a Personalized Strategy with Client Discretion and/or a Defined Strategy, upon enrollment of your Account in the Program, you acknowledge and agree that any open “good ‘til cancelled orders,” “good ‘til date orders” and “day limit orders” for equity securities that have not been executed in your brokerage account will be cancelled for administrative purposes. A “good ‘til cancelled order,” “good ‘til date order,” or “day limit order” for equity securities will not be re-entered in your Account unless you instruct your financial advisor to do so. Any such re-entered orders will be executed by Merrill in the trading capacity permitted for the Account. Funding your Account and Contributions There is typically a short delay between Account inception and initial investment transactions. Until the Account is accepted into the Program, your assets will be treated as brokerage assets for which you will be solely responsible for making any investment decisions and we will not act as an investment adviser with respect to the assets. You may fund your Account by depositing cash and/or securities acceptable to us. You may contribute certain Annuities and certain units of certain Alternative Investment Funds to be held in an Account that has selected the Personalized Strategy with Client Discretion as the Program Strategy type for the Account. Contributions of cash and securities to your Account may be made at any time. For an Account that has selected a Style Manager Strategy, there may be a delay between the date that securities are contributed to the Account and the date that MAA invests such funds and/or liquidates contributed securities, if applicable. For an Account that has selected the Premium Access Strategy type and a PAS Style Manager Strategy, there will be a delay between the date the securities are contributed to such Account and the date that the PAS Manager invests such funds and/or liquidates contributed securities, if applicable. Neither Merrill nor MAA will be liable for any lost opportunity profits that may result from a delay in investing or liquidating contributed securities in order to invest the proceeds except as otherwise provided in the Agreement. If you select a Style Manager Strategy for your Account, we will as a general matter sell any assets you may have in your Account in order to invest in accordance with the Style Manager’s recommendations. If we determine not to sell the particular asset, are unable to sell the asset or if you specifically direct us in writing to not liquidate the asset (before it has been liquidated), we have the right to transfer the asset to a Merrill brokerage account or other account. You are responsible for all tax liabilities arising from any sale of such ineligible or unacceptable assets. If you select a PAS Style Manager Strategy for your Account, the PAS Manager will as a general matter sell any assets you may have in your Account in order to invest such assets in accordance with its PAS Style Manager Strategy. The terms of your PAS Manager/Client Contract with the PAS Manager will determine the treatment of assets held in the Account and whether you can direct the PAS Manager to refrain from liquidation of any asset. You are responsible for all tax liabilities arising from any sale of such ineligible or unacceptable assets. Funding your Account with Ineligible Assets. We may determine in our sole discretion that certain assets, including securities or pending orders relating to securities, are ineligible for the Program or otherwise unacceptable. If we determine any contributed asset is not eligible or is unacceptable, by your execution of the Agreement, you authorize us to transfer this asset to a Merrill brokerage account or sell the asset as promptly as practicable, including on Investment Advisory Program Brochure | 32 IAPB-032025  a principal basis, and charge you a commission for the sale of the asset. You are responsible for all tax liabilities arising from any sale of such ineligible or unacceptable assets. We also may request that you take action to transfer the ineligible assets out of an Account. Failure to comply with such a request may result in that Account’s termination from the Program. Funding Your Account with Mutual Fund Shares. Before contributing mutual fund shares to the Program, you should consider that you may have paid a front-end sales charge or may be obligated to pay a contingent deferred sales charge or redemption fee if the mutual fund shares are redeemed by us in order to invest in the manner you have selected as part of your Program Strategy for the Account. These fees, where applicable, will remain your responsibility and will be in addition to the Program Fee. Each mutual fund has its own system of fund share classes for certain types of clients and accounts. The Program-eligible share classes vary depending on the mutual fund, its roster of share classes and our agreements with the mutual funds. In general, the share classes that are eligible for the Program do not have any sales loads and annual asset-based fees. Annual asset-based fees include “service fees” or “12b-1 fees” charged by mutual funds. There are some mutual funds available in the Program that have such annual asset-based fees due to share class availability. If you contribute or hold mutual fund shares that we deem to be ineligible for the Program, depending on the Program Strategy you have selected, we will either sell them and purchase the share class eligible for the Program or we will exchange them into the Program-eligible share class as promptly as practicable under the Authority provided to us under the Agreement, the mutual fund prospectus rules and our own policies. We may also require you to remove them from the Account. We may elect to not exchange particular share classes of a mutual fund if, for example, there is no equivalent class eligible for the Program or if other circumstances exist. Depending on your Program Fee, by contributing mutual fund shares to your Account in the Program, you could be subject to higher expenses overall once the shares are exchanged into a class we deem to be eligible or if you held them in your brokerage account. Holding Funds in your Account If you invest in Funds, you will bear your proportionate share of such Fund’s fees and expenses including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. The Program Fee does not cover or offset any fees and expenses that any Fund incurs for transactions occurring within the Fund itself, including commissions and other transaction-related charges incurred by the Fund, even if we or any Affiliate effect these transactions for the Fund or provide services to the Fund. Please consult the prospectuses and offering material for the Funds for more detailed information on the amounts charged. Where a Style Manager or PAS Manager receives a Manager Fee and utilizes a Manager-Related Fund that is charged a fund management fee by the Style Manager or PAS Manager (or their Affiliate), Merrill will work with the Style Manager or PAS Manager, as the case may be, to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Style Manager or PAS Manager Fee. See the information covered in “Holding Funds in your Account” in this section and “Compensation, Conflicts of Interest and Material Relationships—Affiliated Investments of a Style Manager or a PAS Manager” in Item 9. Merrill makes available money market funds with a one dollar ($1) minimum investment through the Program for investment. Money market funds are available with the same day settlement period and with a one day settlement period. For transactions in money market funds implemented by MAA, the available money market funds have a one day settlement period. Advisors have the discretion to purchase money market funds with either a same day or a one day settlement period. Withdrawals For withdrawal requests, the liquidation of certain securities will be required. Withdrawal requests will be implemented as promptly as practicable, although implementation of the withdrawal may be delayed in certain instances, such as during periods of extreme market volatility. The following will apply to our handling of a withdrawal request: • We require at least five business days prior notice before you withdraw assets from an Account. In certain situations, it may take longer than five business days before you can access your requested funds. The ability of MAA, or the PAS Manager in the case of assets invested in a PAS Style Manager Strategy, to liquidate may be impacted by market conditions and events or pending rebalancing or other actions being taken in respect of the Portfolio. • Your withdrawal request will be handled as promptly as practicable given other activities that may be occurring at the same time in an Account or Portfolio, like changes to a Program Strategy, a change to the Style Manager Strategy or PAS Style Manager Strategy applicable to the Account, any rebalancing transactions in process and other activity affecting the Account. • For withdrawals from an Account invested in a PAS Style Manager Strategy, you must take action to notify promptly the PAS Manager with respect to any additions or withdrawals of assets to the Account and to avoid conflicting instructions to Merrill and the PAS Manager. Except as otherwise provided in the Agreement, neither Merrill nor MAA will be responsible or liable for any losses due to your failure to provide such prompt notification of additional or withdrawn assets to the Account or in circumstances where you provide conflicting instructions to Merrill and the PAS Manager. • For Managed and Custom Managed Strategy Accounts, if you do not withdraw the proceeds received from a liquidation from the Account within 15 calendar days after the proceeds have settled in the Account, MAA may take action to reinvest the proceeds without notifying you in accordance with the strategy that was part of the Managed Strategy or Custom Managed Strategy. • We reserve the right to terminate any Account that falls below the required minimum asset size as reflected in the applicable Profile for a Style Manager Strategy or a PAS Style Manager Strategy. • Merrill reserves the right to liquidate, redeem or exchange mutual funds, Alternative Investment Funds, and other securities that are transferred from an Account to a brokerage account. • In certain circumstances, you may not be permitted to redeem all or a portion of your investment in an Alternative Investment Fund at the time of your choosing and you may be required to hold such investments indefinitely. • We will charge the Program Fee on the value of your Account investments until the proceeds from any sale or redemption have moved out of the Account. Investment Advisory Program Brochure | 33 IAPB-032025 • For certain Alternative Investment Funds, all or a portion of your redemption proceeds may not be available to you for a period of time following the effective date of redemption (the date on which the Alternative Investment Fund has provided as the redemption date for the particular investment (i.e., the monthly or quarterly scheduled date). You will continue to pay the Program Fee on the value of your investment in a particular Alternative Investment Fund until the proceeds from any sale or redemption have been withdrawn from the Account unless determined by us in our sole discretion. • Frequent withdrawals from your Account may affect the achievement of your investment objectives and taxable gains and losses may be realized as a result of your withdrawal instructions. Your Account’s trading activity may impact available funds for an Account under margin rules. See “Item 4 Brokerage and Custodial Arrangements and Services” for additional information. Cash Balances Depending on the Program Strategy type you have selected, either you, your Advisor, a Style Manager or a PAS Manager will determine the cash allocation for your Account. The cash allocation can be held in the form of cash balances in your Account or investments in money market funds and other cash alternatives. For transactions in money market funds implemented by MAA, the available money market funds have a one day settlement period. For orders entered by an Advisor, there is a choice of a money market fund with either a same day or a one day settlement period. At times, your Account will have an allocation to cash balances that will be automatically swept to the cash sweep option applicable to your Account under the Cash Sweep Program because you or your Advisor have made a decision to keep a cash balance for various purposes, such as your cash needs or as a way to fulfill your cash asset allocation target. Except for Accounts that have invested in a Style Manager Strategy or PAS Style Manager Strategy, at any time, you can instruct your Advisor to invest cash balances in cash alternatives, such as money market funds, or to invest in securities other than cash alternatives. Where your Account has selected to invest in a Style Manager Strategy or PAS Style Manager Strategy, the Style Manager or PAS Manager, as the case may be, determines whether to keep a cash balance for operational and/or investment purposes and determines how to invest the cash asset in the particular Style Manager Strategy or PAS Style Manager Strategy. See “Item 4 Investment Strategy Services Available.” Any uninvested cash balances in your Account (other than an Account held with a custodian other than Merrill or that has selected the “No Sweep” option) will automatically be “swept” in accordance with the Cash Sweep Program as part of your underlying brokerage account agreement. Except for Accounts that have invested in a Style Manager Strategy or PAS Style Manager Strategy, at any time, you can instruct your Advisor to invest cash balances in cash alternatives, such as money market funds, or to invest in securities other than cash alternatives. For Style Manager Strategies and PAS Style Manager Strategies, the Style Manager or PAS Manager, as the case may be, determines how to invest the assets in the Strategies and may determine to keep a cash balance as part of the strategy as described above. We have a conflict of interest regarding the use of bank deposits as a cash sweep option because such use benefits Merrill and benefits our Bank Affiliates. See Item 9 at “Compensation, Conflicts of Interest and Material Relationships” at the sections “Cash Sweep Program Compensation Received by Us and Our Affiliates,” “Compensation Received by Us for Sub-accounting Services” and “Mutual Funds Arrangements and Compensation” and Item 9 at “Participation or Interest in Client Transactions and Conflicts of Interest-Cash Balances and Cash Sweep Program.” You can hold cash in a separate brokerage account or in a deposit account at a Bank Affiliate or at other banking institution. This cash will not be subject to the Program Fee and will not receive any Program monitoring and other Program Services. We will not be an investment adviser or fiduciary with respect to such cash. Your Responsibilities for Account Operation and Management You must notify your financial advisor promptly of any material change in financial circumstances, investment objectives, or investment restrictions (if any) that may affect the nature of the investment advice and services your financial advisor provides to Program Accounts. Because the management of an Account that is enrolled in a PAS Style Manager Strategy is the responsibility of the particular PAS Manager and not ours, you must provide any such updated information directly to the PAS Manager. We and your financial advisor do not have any obligation to communicate such information to the PAS Manager. You are responsible for monitoring the total amount of deposits, including brokered CDs and other bank deposit products, held at any one bank, including at any of our Bank Affiliates, for FDIC insurance limits. See “Item 4 Brokerage, Banking-Related and Custodial Arrangements and Services—Cash Sweep Program and Other Banking-Related Services.” There is more detailed information about FDIC insurance and limits in the Sweep Program Guide. Terminating Enrollment in the Program The Agreement may be terminated at any time by either us or you, by providing verbal or written notice. The termination of the Agreement will terminate the Program enrollment of all of your Accounts. You may also terminate the enrollment of any Account in the Program by giving us notice of termination. Your termination of Program enrollment of a particular Account will not automatically terminate the enrollment in the Program of any of your other Accounts. Termination of the Agreement will not preclude the consummation of any transaction initiated prior to termination. Termination of your Account will be effective following the completion of processes that may be required to terminate the Account, including any required liquidations. We will not be responsible for market fluctuations in your Account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient liquidation of an Account include, but are not limited to, size and types of securities, liquidity of the markets and market-makers’ abilities. Due to the administrative processing time needed to terminate an Account, termination requests cannot be considered market orders. It could take up to several business days under normal market conditions to process your request, particularly as it relates to Accounts that have selected a PAS Style Manager Strategy for their Account. For an Account that is in a PAS Style Manager Strategy, it is your responsibility to notify both your Advisor and the PAS Manager of your decision to terminate the selection of the PAS Style Manager Strategy for the Account and to terminate the PAS Manager/Client Contract with the PAS Manager. For an Account that is in Personalized Strategy with Advisor Discretion, Personalized Strategy with Client Discretion and/or Defined Strategy, upon termination of your Account from the Program, you acknowledge and agree that any open “good ‘til cancelled orders,” “good ‘til date orders” and “day limit orders” for equity securities will be cancelled. A “good ‘til cancelled order,” “good ‘til date order” or “day limit order” for equity securities will not be re- entered in your brokerage account (if applicable) following termination of your Account from the Program unless you instruct your financial advisor to do so. Any such orders may be executed by Merrill on a principal, agency or agency cross basis if your account has been converted to a brokerage account. Investment Advisory Program Brochure | 34 IAPB-032025  Upon termination of an Account or the Agreement, a pro-rata adjustment to the Program Fees for the remainder of the billing period will be made, which may result in your receiving a refund of a portion of the Program Fee monthly payment. In addition, except for certain types of Account, your Account will be converted to, and designated as, a brokerage account that will be subject solely to the terms and conditions of the Merrill brokerage account agreement. The termination of your financial advisor’s employment with Merrill or a change in the role of your financial advisor will not automatically terminate the Agreement. In such an event, we will transfer your Account to a different financial advisor and we will inform you of this fact. The Account will remain in the Program and incur the Program Fee until you instruct us otherwise. Where the Program Strategy type for an Account is Defined Strategy or Personalized Strategy with Advisor Discretion, your assigned Advisor will work with you to recommend an alternate investment solution, but, under certain circumstances, we may determine to select a replacement Program Strategy type for your Account and/or a Style Manager Strategy or Strategies that we believe to be in your best interest. We generally will provide you with prior notice before selecting such a replacement. If you do not instruct us to select a different replacement or change to a different type of Program Strategy, your continued participation in the Program will be your consent to the replacement we select for your Account. The replacement may be subject to higher fees than you had been paying. Merrill reserves the right to take action under its Program guidelines to terminate the Account from the Program or to authorize or preclude financial advisors from taking action in respect of your Account if we are unable to obtain instructions from you as to your Account in a timely manner. If your Account is terminated and converted to a brokerage account, the brokerage services and activities will be limited to those available from your Advisor or MFSA, as the case may be. The brokerage capabilities you will receive where your financial advisor is an MFSA are more limited than those available from an Advisor. You (or any other party acting on your behalf) will have the sole responsibility for the investment of assets in the brokerage account. In the event of a termination, the Account assets will not be liquidated but will be held in your brokerage account, except where the holding of such security in that account is not permitted. Special Note about Impact of Termination on Holdings of Mutual Funds, Alternative Investment Funds and Annuities. For certain mutual funds (including NTFs) and Alternative Investment Funds, the advisory share class of such funds are not eligible to be held in an account that is not enrolled in the Program. Upon Account termination or termination of the Agreement or if you or we move or transfer mutual fund shares from your Account to a brokerage account, we will automatically liquidate, redeem or exchange these mutual fund shares into another appropriate share or unit class in accordance with applicable offering materials and our own policies, without providing prior notice. Any liquidation, redemption or exchange will generally be effected as soon as practicable, which may be as soon as the close of the next business day following termination or transfer. In addition, certain Manager-Related Funds that may be part of a Style Manager Strategy or a PAS Style Manager Strategy cannot be held outside of the particular managed strategy. Upon termination, we will work with the Style Manager or PAS Manager to liquidate the position. For AI Advisory Units, we may automatically redeem or convert the AI Advisory Units to another appropriate tranche, share, or unit class in accordance with applicable offering materials and our own policies, without providing prior notice. Any liquidation, redemption or exchange will generally be effected as soon as practicable, which may be as soon as the close of the next business day following termination or transfer. For certain securities, such as those traded on a when-issued basis or as odd-lots, the liquidation or redemption process may take longer. Additional fees and expenses may apply upon any such liquidation, redemption, exchange or conversion. Brokerage share classes, tranches or units of mutual funds and Alternative Investment Funds generally will have higher operating expenses than advisory share classes that are eligible for the Program and will charge sales loads and/or trailing commissions, which will be used to compensate Merrill or one of its Affiliates and your financial advisor. Please note that if there is higher compensation resulting from the liquidation, redemption or exchange of mutual fund shares, AI Advisory Units or Annuities, your Advisor has a financial incentive to recommend that you terminate your Account or move individual positions from your Account to a brokerage account and therefore has a conflict of interest. See “Compensation, Conflicts of Interest and Material Relationships—Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel” in Item 9. As to any holdings of Annuities, upon termination of your Account, Merrill and MLLA will no longer act in any capacity as to any Annuity held in your Account, including as broker-dealer of record, custodian (or beneficiary) or as general agent and insurance broker. We will resign all positions and you will have to make alternative arrangements for the holding of this asset. You should discuss with your Advisor the impact of an Account’s termination from the Program with respect to an Annuity. Legal Matters and Related Notifications We will not advise or act for you with respect to any legal matters for securities held in your Account, including bankruptcies or class actions. In its role as a broker-dealer, Merrill will endeavor to send you any documents received with respect to such matters. You may enroll in the Merrill Class Action Settlement Service, a separate administrative service. Please note that this service is not part of the Program or covered by the Program Fee. The type of Program Strategy and Authority you select will determine who responds to corporate actions for securities in the Account. Corporate actions for an Account can include any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. If you have selected the Personalized Strategy with Client Discretion as the Program Strategy type for your Account, corporate actions will be sent to you. In certain cases, we may be unable to forward certain corporate actions, such as when we receive the corporate action within two weeks of the required response date. For Accounts that have selected Custom Managed Strategy with Client Discretion, corporate actions will be sent to you relating to mutual funds or ETFs that are part of the Account. We will respond to corporate actions relating to any securities that are part of a Style Manager Strategy included in the Account. Where you have selected the Program Strategy types of Managed Strategy, Custom Managed Strategy with Advisor Discretion, Defined Strategy and Personalized Strategy with Advisor Discretion, we will respond to corporate actions. For Accounts with Premium Access Strategy, the PAS Manager will respond to corporate actions. Tax Matters General Tax Matters. The wide ranging variety of investments that may be covered by the Program makes it impossible to alert you to the tax risks and consequences of each investment. You are responsible for all tax liabilities and tax-return filing obligations arising from the transactions in your Account(s) enrolled in the Program. You also are responsible for all tax liabilities and tax-return filing obligations arising from all transactions in your Account. We are not responsible for attempting to obtain any tax credit or similar item or preparing and filing any legal document on your behalf. You should review all Investment Advisory Program Brochure | 35 IAPB-032025 disclosures you receive associated with the investments held in and transactions occurring within your Account with a qualified tax professional. We do not, and will not, offer tax advice to you and you need to rely on such qualified tax professional in all instances for tax advice. If you are an investor with special circumstances such as a non-U.S. resident or an entity sensitive to unrelated business taxable income, you should also discuss with your qualified tax professional the tax consequences of each investment held in your Account as there may be additional tax withholding, reporting and payment obligations which may result from such investments. Special tax rules may apply to the investments themselves which may result in unique tax consequences to you. In some circumstances, certain tax elections may be able to be made that will affect the tax consequences arising from such an investment. Certain investments (such as master limited partnerships) may result in tax consequences to investors that are subject to tax on unrelated business taxable income and you will be responsible for the reporting and filing of tax returns and the payment of the associated income tax resulting from such investments. You should be aware that tax consequences may arise when portfolio changes occur in your Account, such as rebalancing, liquidations and redemptions and as a result of any action undertaken as part of a TEM Overlay Service or in implementing a Direct Indexing/TEM Style Manager Strategy or PAS Direct Indexing/TEM Style Manager Strategy. Except to the limited extent described in this section, we specifically disclaim any undertaking of tax management of your Account or investments and assume no responsibility for any resulting tax consequences. Additionally, if you direct us to take certain actions in an Account (other than an Account with a PAS Style Manager Strategy, as to which we cannot take any such instructions) for tax related reasons, there is no assurance that your desired tax effect will be realized. For example, if you direct us to realize gains in your Account, when we resume normal trading activity in your Account, such activity could generate new taxable losses or gains and the same or similar securities may be repurchased. Similarly, if you direct us to realize losses in your Account, when we resume normal trading activity in your Account, such activity could generate new taxable losses or gains. Upon your request to realize losses within an Account (other than an Account with a PAS Style Manager Strategy, as to which we cannot take any such instructions) and not as part of a TEM Overlay Service, we will attempt to undertake the following: (1) restrict purchases of substantially identical securities in the Account for a minimum of thirty-one calendar days following the sale of securities at a loss in the Account; (2) restrict sales of substantially identical securities in the Account that are currently at a loss for a period of thirty-one calendar days following the purchase of securities in the Account; and (3) at our discretion, engage in strategies to invest the available proceeds for varying time periods in substitute securities, current holdings, and/or alternative securities such as ETFs. We also could determine to hold cash in certain circumstances. We do not make any guarantee that these actions will be successful in recognizing the losses. For Accounts in Managed Strategy and Custom Managed Strategy arrangements, MAA will generally accept specific tax gain and loss requests for taxable Accounts but the extent to which it implements such a request may be affected by its qualitative assessment of market liquidity. MAA can reject a client’s request for tax-related trades in whole or in part at its discretion. We are not providing any tax advice with respect to the effects of these transactions including whether a loss has been disallowed pursuant to the wash sale rules under the Code and we do not take into account the trading activity in any of your other accounts, including your other Accounts in the same Portfolio Group, any other Accounts you may have in the Program or any accounts you have with Merrill or its Affiliates or third parties. You should be aware that as a result of these transactions, a higher than normal cash allocation may result for a period of time. In addition, this type of transactional activity may adversely affect Account performance and may increase the volatility of its results. For Accounts with a PAS Style Manager Strategy, any requests to realize gains or losses with the Account must be made to the PAS Manager as the PAS Manager has full investment and trading authority respecting activity in the Account. Special Risk and Limitations associated with Tax Efficient Management Offerings. We make available to eligible Accounts: (1)TEM Overlay Services provided by MAA and (2) Direct Indexing/TEM strategies offered by Style Managers and PAS Managers (both, Tax Efficient Management Offering). There are risks and limitations associated with a Tax Efficient Management Offering and these limitations may result in tax-inefficient trades and wash sales. A Tax Efficient Management Offering is designed to effect tax efficient management under U.S. tax rules and regulations. You should consult your tax and/ or legal advisor prior to enrolling in any Tax Efficient Management Offering, as well as on an ongoing basis, to determine whether the wash sale rules, the straddle rules, or other special tax rules could apply to your trading activity. Generally, under the wash sale rules, if you sell a security for a loss and you repurchase the same (or a substantially identical) security either 30 days before or 30 days after the date of sale, the loss is disallowed. In addition, other tax treatment rules, such as the straddle rules, may disallow losses. There is little authority governing whether an ETF or mutual fund replacement security is “substantially identical” to another ETF or mutual fund security for purposes of the wash sale rules. As such, no assurances can be provided that if we or a Style Manager choose an ETF or mutual fund security as a replacement security to the sold security, the replacement ETF or mutual fund security will not be deemed “substantially identical” for purposes of the wash sale rules. A Tax Efficient Management Offering applies on a per-Account basis only and only to the Account that has selected the particular Tax Efficient Management Offering. Please note, however, that the wash sale rules apply to securities transactions in not only that Account but also to securities transactions in all other accounts held by you, your spouse and certain entities controlled by you and your spouse. The accounts covered under the wash sale rules include all taxable accounts and retirement accounts held at Merrill or an Affiliate that are brokerage accounts and/or accounts enrolled in investment advisory programs, and all securities accounts of any type held with third parties in each case, held by you, your spouse and certain entities controlled by you and your spouse (securities accounts). A particular Tax Efficient Management Offering will not take into account trading activity in any of these other securities accounts. If an Account that has selected a Tax Efficient Management Offering is part of a Portfolio Group, the Tax Efficient Management Offering will only apply to activities occurring in that Account and not to the activities occurring in the other Accounts that are part of the Portfolio Group. The sale of a security for a loss in an Account enrolled in a Tax Efficient Management Offering will not generate a loss for tax purposes if the security or position was part of a wash sale or straddle as a result of trading activity or securities in any other of your securities accounts. In addition, the purchase of a replacement security in an Account enrolled in a Tax Efficient Management Offering may give rise to a wash sale with respect to a security or position in any of your securities accounts (including those of your spouse and certain of your spouse’s controlled entities). Similarly, other trades executed in any securities account may also result in a wash sale in the Account enrolled in a Tax Efficient Management Offering. If you have elected to participate in the Automatic Contribution Service, Automatic Withdrawal Service, or Rebalancing Service offered in the Program for certain Program Accounts, the transactions that occur as a result of a Tax Efficient Management Offering may result in wash sales, even in the Account that has selected a Tax Efficient Management Offering. In applying or selecting a Tax Efficient Management Offering to an Account that includes selling securities and investing in Style Manager Strategy-aligned replacements, the performance of any replacement security selected will not be the same as that of the security sold and, in fact, the replacement security Investment Advisory Program Brochure | 36 IAPB-032025 may perform worse than the security sold. Any tax-related benefits that result from a Tax Efficient Management Offering may be negated or outweighed by investment losses and/or missed gains (realized and unrealized) that also may result. An Account that enrolls in a Tax Efficient Management Offering will generally trade more frequently than an account which has not selected a Tax Efficient Management Offering. There are implicit trading opportunity costs associated with the additional turnover which may affect the returns on your Account. Selecting a Tax Efficient Management Offering may not be appropriate for your financial situation. If you are taxed at lower aggregate marginal income tax rates, you may be less likely to benefit from the Tax Efficient Management Offering than would an investor taxed at higher aggregate marginal income tax rates. Because you may use capital losses only to offset certain amounts of capital gains that you might have, and possibly, to a limited extent, ordinary income, if you have net capital losses in excess of the applicable threshold, you may not realize as many immediate tax benefits through the application of a Tax Efficient Management Offering to your Account. When selling a security that is held in two or more tax lots, certain overlay services may seek to minimize the capital gains tax consequences of the sale and in doing so may consider the holding periods (long-term or short-term) of the securities sold. It is your obligation to monitor transactions across all of your accounts to identify any wash sales or straddles and you are responsible for all tax liabilities attributable to the disallowance of any losses pursuant to the wash sale rules or of any deferral under the straddle rules. Merrill and MAA cannot provide any assurances that losses will not be disallowed pursuant to the wash sale rules or deferred under the straddle rules. If you elect to enroll in a Tax Efficient Management Offering, you should consider receiving trade-by-trade confirmations (rather than receiving trade confirmations on a periodic basis), monitoring those confirmations and, to the extent any security is sold for a loss, refraining from acquiring the same (or a substantially identical) security in your Account or any of your securities accounts. Despite this, it is possible that you may still be subject to the wash sale or straddle rules in any given tax year. ITEM 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Client and Financial Advisor Eligibility Merrill requires that all clients who wish to enroll in the Program enter into the Agreement, which sets forth the services that Merrill and/or MAA will provide to the client. The Agreement sets forth the terms and conditions that govern the handling of the client’s Account or Accounts and the investment advisory relationship between the client and Merrill. A separate account is required for each Program Strategy selected by the client. For the Premium Access Strategy type, the client must also enter into the PAS Manager/Client Contract directly with the PAS Manager that will manage the client’s assets in the Account, giving the PAS Manager trading authority over the Account. The PAS Manager/Client Contract with the PAS Manager will govern the terms of the client’s investment advisory relationship with the PAS Manager. Merrill and, where applicable, the PAS Manager may each decline to accept a particular client or account in the applicable Program at any time and for any reason at their sole discretion. Clients generally eligible to participate in the Program include individuals, trusts, estates, charitable organizations, banks, insurance companies, thrift institutions, pension and profit sharing plans, corporations and virtually all other types of business as defined by us. Not all Merrill account types are eligible for enrollment in the Program. Certain Program Strategy types where the Advisor has investment Authority and certain investment products, including certain Alternative Investment Funds, may only be made available to clients of qualified Advisors. See “Item 4 Investment Strategy Services Available— Defined Strategy as a Program Strategy Type” and “—Personalized Strategy with Advisor Discretion as a Program Strategy Type” and “Item 6 Portfolio Manager Selection and Evaluation—Advisory Services Provided by Merrill, its Advisors and Certain Affiliates.” Not all types of investors are eligible for each Program Strategy. See “Item 4 Investment Strategy Services Available—Premium Access Strategy as a Program Strategy Type.” Certain investment products and solutions and services are only available for eligible Accounts and eligible investors. MFSAs can only offer the Program Strategy type of Managed Strategy and not any of the other Program Strategy types. Within Managed Strategy, they are only eligible to offer certain of the Style Manager Strategies that are available in the Program. Program Minimums There is generally no minimum asset requirement to participate in the Program; however, the PAS Style Manager Strategies, certain Style Manager Strategies and TEM Overlay Services require minimum investment amounts as reflected in the applicable Profile or other disclosure documents. Retirement Accounts Retirement Accounts subject to ERISA that elect to delegate voting authority to the Proxy Delegation Vendor may require additional documentation to elect the ISS SRI Guidelines or the ISS Catholic Guidelines as their voting policy. The sub-accounting service or distribution fees received from the mutual fund or a fund service provider or its Affiliate relating to mutual fund or other securities holdings in a Retirement Account will be credited to the Retirement Account on a periodic basis. To the extent required by law, a Retirement Account that invests in any Related Style Manager Strategy or a Related Fund will not be charged or will be credited, as the case may be, on a periodic basis with certain fees or other compensation associated with the Related Style Manager Strategy or Related Fund in the Retirement Account. If you invest through your Retirement Account in Alternative Investment Funds, you will purchase shares or units that do not provide for fee sharing with, or payment of placement or selling agent fees to, Merrill or its Affiliates. Certain Alternative Investment Funds (or their sponsors or managers) or one or more portfolio companies in which an Alternative Investment Fund holds an interest may use our services or those of our Affiliates in the ordinary course of business. In such case, we or one of our Affiliates will receive compensation from the Alternative Investment Fund, a portfolio company or their respective managers (none of which are our Affiliates). If your Retirement Account receives an in-kind distribution (that is, a distribution that is not made in cash) from the Alternative Investment Fund, you are responsible for ensuring that your Retirement Account may accept and hold the distributed asset and that no prohibited transaction under ERISA or Section 4975 of the Code will result. Merrill will not monitor the ability of Retirement Accounts to receive in-kind distributions from Alternative Investment Funds and will not be acting as a fiduciary under ERISA or Section 4975 of the Code with respect to an in-kind distribution made to your Retirement Account. You should consult with your tax advisors concerning receipt of in kind distributions. Investment Advisory Program Brochure | 37 IAPB-032025 ITEM 6. PORTFOLIO MANAGER SELECTION AND EVALUATION Selection and Review of Investment Strategies and Funds Available in the Program The Program offers you access to Style Manager Strategies and, if the client meets eligibility requirements, PAS Style Manager Strategies fund investments, like mutual funds, money market funds, ETFs, unit investment trusts, closed-end funds and Alternative Investment Funds, Annuities and other security types, in each case, that we decide in our discretion to make available in the Program. The determinations to include these types of investment solutions in, or to remove them from, the Program is made by us based on a variety of factors, including client needs, investment styles available in the marketplace, platform capacity, client demand and the outcome of certain reviews that are conducted by or under Merrill’s auspices, including through the CIO. We perform, through our product teams’ internal business processes, initial and periodic reviews. In addition to these business processes, we have in place an investment review, referred to as the “CIO Review Process,” conducted by or under the auspices of personnel of the CIO of investment solutions that are being considered for inclusion in the Program. The CIO Review Process consists of proprietary processes conducted by the CIO and those processes and reviews provided by third-party reviewers that we have engaged for this purpose. The third-party reviewer processes and reviews are generally consistent with the review processes that the CIO deploys but they are not identical. We, through the CIO, have reviewed such third-party reviewers’ processes and believe they are reasonable and appropriate in light of the objectives of the Program. The CIO Review Process covers Style Manager Strategies, PAS Style Manager Strategies and limited aspects of variable annuities that are made available in the Program. It also covers mutual funds, money market funds, ETFs, closed-end funds and Alternative Investment Funds (together, CIO-reviewed Funds). Please note that, at various points in time, particular Style Manager Strategies, PAS Style Manager Strategies, variable annuities and individual CIO-reviewed Fund securities may not be covered under the CIO Review Process. While substantially all of these investment products available under the Program have been reviewed for the administrative and operational requirements of our platform, not all products available in the Program are subject to the CIO Review Process. P O R T F O L I O M A N A G E R I Once we identify a need for a particular investment management style or strategy, a quantitative and qualitative due diligence process is employed, including but not limited to, the organizational structure and stability of the investment manager or Fund manager or sponsor, adherence to investment style, including sustainability or ESG attributes, where relevant, evaluation of risk and volatility, investment professional and strategy resources, investment philosophy and process, portfolio construction, performance, and operating and administrative capability. Based on these factors and using the information collected, the CIO Review Process involves quantitative and qualitative analytical methods, some of which may be subjective. Generally no single factor will be determinative. I Our reviews may involve in-person visits, telephone conference calls, reviews of performance, and updates of disclosures and documents relating to the particular investment solution. We may also conduct periodic analysis of composite performance data; however, we do not perform audits of Style Managers, PAS Managers, product sponsors and fund sponsors or Annuity Issuers or of their investment strategies to verify past performance information provided to us. There is no assurance that the CIO Review Process or our internal reviews will identify the best performing Style Manager Strategies, PAS Style Manager Strategies, variable annuities or Funds. S E L E C T O N & E V A L U A T O N We will periodically evaluate factors related to the investment management of the Style Manager Strategies, PAS Style Manager Strategies, variable annuities and CIO-reviewed Fund investments that we deem appropriate. In addition, we may initiate reviews based on various factors determined by us and/or the CIO to be appropriate, including the level of assets invested in client accounts at Merrill or an Affiliate, the number or percentage of Merrill or Affiliate clients and the asset class involved, among other factors. If we identify concerns that we find significant or important, we may choose not to accept any new investments. A drift or variation of the style of management of a particular Style Manager Strategy, PAS Style Manager Strategy or CIO- reviewed Fund from the stated style does not require a removal from our Program offering. Merrill retains the decision-making authority to add or remove a Style Manager Strategy, PAS Style Manager Strategy, Fund or an Annuity from the Program, regardless of, or in light of the results of, any review conducted, including through the CIO Review Process. Our product teams’ internal business review and the CIO Review Process form the basis for Merrill determining whether to make ETFs and other exchange traded products (exchange traded products) and closed-end funds available for solicitation and use in the Program. In addition, the CIO Review Process determines whether exchange traded products will be included in a Style Manager Strategy constructed and implemented by the CIO. The CIO Review Process and conclusions from that process do not rely on or otherwise use the research reports and ratings related to certain exchange-traded products and closed-end funds of the BofA Global Research Group (Research Ratings) as an input or factor. The CIO, BofA Global Research and other business units of BofA Corp. apply different methodologies in their review of exchange traded products and closed-end funds and may arrive at different or inconsistent conclusions. We make available model-based Style Manager Strategies from MAA based on BofA Global Research Group investment models or lists that include exchange traded products that are covered by these Research Ratings. It is possible that certain of the exchange traded products included in the Style Manager Strategies based on the BofA Global Research-based models or lists may not have been reviewed under the CIO Review Process and such review is not required. As a result of the CIO Review Process, internal business reviews or otherwise, Merrill may determine to take certain actions, including not making Style Manager Strategies, PAS Style Manager Strategies, CIO Reviewed Funds, Alternative Investment Funds or variable annuities or their manager/sponsors or issuers available in the Program. Note that Style Managers, PAS Managers, Annuity Issuers, product sponsors and Fund managers include as part of their strategies’ investment portfolios individual equity and fixed income securities, investment strategies and Funds based on their own review and portfolio management processes and determinations. These individual securities, including Fund securities, may not be covered, and are not required to be subject to, the CIO Review Process. Our review, including through the CIO Review Process, of Style Manager Strategies, PAS Style Manager Strategies, Funds and variable annuities does not substitute for your ongoing monitoring of your Portfolio and the performance of your investments. Investment Advisory Program Brochure | 38 IAPB-032025  Available Information Regarding Style Manager Strategies, PAS Style Manager Strategies and Funds We make available guidance to our Advisors and MFSAs through regular or ad hoc internal publications, including those from the CIO, that reflect our internal opinions and views with respect to a Style Manager Strategy, PAS Style Manager Strategy or CIO-reviewed Fund. Financial advisors are not obligated in all circumstances to take action with respect to any such determination and have the ability to decide not to use or follow this additional guidance and to make independent recommendations. For Style Manager Strategies and PAS Style Manager Strategies, we receive strategy descriptions and performance information from the Style Manager, PAS Manager and MAA for use in the Profiles. Each such Manager may use different methodologies to select and aggregate accounts for performance reporting purposes as well as different calculation approaches for composite performance results. We make no claim that the Profile performance information has been calculated according to any industry standards. MAA’s implementation of investment advice from a Style Manager could result in performance that is materially different from the results that the Style Manager would achieve if it managed your Account directly. Account performance also may differ for a variety of other reasons, including differences in the types, availability and diversity of securities that can be purchased, regulatory restrictions on the purchase of certain securities, economies of scale and other factors applicable to investments in large accounts, gains or losses caused by currency transactions and other considerations. For a Discretionary Style Manager Strategy and PAS Style Manager Strategy, the Profiles will contain performance information of the strategy provided by the Style Manager or the PAS Manager as it is implementing its investment decisions directly. By offering a Style Manager Strategy or a PAS Style Manager Strategy in the Program, we are of the view, after considering certain information, including information and representations provided by the Style Manager or the PAS Manager, that the Strategy’s past performance is reasonably representative of the investment style as it will be implemented in the Program and is sufficiently relevant for consideration by a potential or existing client. Please note that any past performance shown on the Profile is not indicative of future results and your investment performance will differ from the information presented in the Profile. For an eligible Account, you will be provided with documents (which are available at mymerrill.com/ADV/materials) that contain descriptions of the TEM Overlay Services. You should carefully read these materials and understand the relevant approaches of the TEM Overlay Services and the risks and limitations. Strategy Construction Style Manager Strategies and PAS Style Manager Strategies are generally organized according to a shared characteristic such as asset class or investment style. The Style Manager (whether a third-party investment manager or Merrill, MAA or their Affiliates) and the PAS Manager will construct the particular investment strategy and select the securities, including, in certain cases, Funds and other types of investment strategies. They also set the allocations or allocation ranges. For certain Style Manager Strategies, the Strategy’s portfolio incorporates the Style Manager’s tactical asset allocation over a strategic allocation. Please refer to the Profile for additional information about the Style Manager Strategy or the PAS Style Manager Strategy itself, including further details with respect to the strategy description, portfolio construction and due diligence. The Style Manager Strategies that are available in the Program include those that are constructed, implemented and managed by Merrill or one of its Affiliates and where Merrill or its Affiliate acts as the Style Manager. These Style Manager Strategies include those constructed by the CIO and those implemented by MAA based on BofA Global Research investment models or lists. The CIO Style Manager Strategies are Style Manager Strategies constructed by the CIO. It selects the constituent mutual funds, money market funds and exchange traded products for the particular Style Manager Strategy and, when doing so, selects only those subject to the CIO Review Process and those that are considered to have sufficient assets under management and to meet minimum trading volume parameters. In addition, it considers and evaluates their share price or net asset value, along with the corresponding allocation weighting, in light of the CIO Style Manager Strategy’s investment minimum. The CIO also determines the allocations or allocation ranges. The CIO develops the strategic asset allocations for the CIO Style Manager Strategies based on its long-term expected return, risk and correlation assumptions for each asset class (capital market assumptions), its view of the appropriate long term allocation guidelines to follow in light of market conditions, expected trends and, as applicable, corresponding tactical asset allocation adjustments. The tactical asset allocation adjustments are applied to those long-term asset allocations based on the CIO’s near-term market, economic, and asset class expectations. These tactical adjustments overweight or underweight specific asset classes, incorporating its investment views on how market dynamics, phases of the economic or business cycle, and particular investment themes may affect the CIO Style Manager Strategies. In order to determine tactical asset allocations, the CIO utilizes internal as well as third-party research and data at both the macro and micro levels. Once the CIO Style Manager Strategies are constructed, the CIO regularly monitors and reviews them and makes adjustments based on asset allocation changes. The individual securities are also periodically reviewed to ensure they continue to meet the criteria for inclusion. The CIO Style Manager Strategies are also subject to internal governance and oversight processes on a periodic basis, which may include a review of performance against expectations as well as any applicable investment or regulatory restrictions. The offering of Related Style Manager Strategies and Related PAS Style Manager Strategies is subject to internal governance processes and applicable legal requirements. The Program does not currently offer any Related Funds. However, to the extent any Related Funds become available, we may determine to include them in a Style Manager Strategy constructed by Merrill or one of our Affiliates or a third-party Style Manager Strategy. The conflicts of interest and other considerations arising from the use of Style Manager Strategies constructed, implemented and managed by Merrill or any of its Affiliates are discussed in “Compensation, Conflicts of Interest and Material Relationships” in Item 9. The investment strategies constructed and implemented by an Advisor in an Account enrolled in the Personalized Strategy with Advisor Discretion or the Defined Strategy are not subject to the same level of review that is applicable to Style Managers. Advisory Services Provided by Merrill, its Advisors and Certain Affiliates Merrill, acting primarily through your Advisor, will generally act as the portfolio manager for an Account where you select the Custom Managed Strategy with Advisor Discretion, a Defined Strategy or a Personalized Strategy with Advisor Discretion for your Account. To qualify to offer investment advisory services through the Program Strategy types of Personalized Strategy with Advisor Discretion and Defined Strategy, Advisors must meet eligibility Investment Advisory Program Brochure | 39 IAPB-032025 requirements which include length of experience in the securities industry, having an acceptable sales practice record, completion of business certification and training requirements, having a minimum level of client assets in Merrill accounts and management approval. To attain a senior designation and therefore be entitled to additional flexibility under Program guidelines respecting their client’s account activity, Advisors must achieve a specified level of client assets in discretionary assets; however, they are not required to maintain a certain discretionary assets level in order to retain their senior status. For an Account that selects either a Managed Strategy or a Custom Managed Strategy, MAA will generally act as the portfolio manager. If you choose a Related Style Manager Strategy, the Related Style Manager will generally act as a portfolio manager, as described in the applicable Profile. Merrill and MAA act as both the wrap fee program sponsor and as the portfolio manager in respect of certain Style Manager Strategies, as described in this Brochure. One of our Affiliates may also act as a PAS Manager. We both also act as the portfolio manager in other wrap fee programs sponsored by us. Merrill receives the entire Merrill Lynch Fee as described in this Brochure. As explained in “Item 4 The Program Fee and Other Charges,” the Style Manager Fees and PAS Manager Fee are separate charges from (and in addition to) the Merrill Lynch Fee component of the Program Fee. We do not retain any portion of the Style Manager Fee or PAS Manager Fee unless Merrill or its Affiliate serves as the Style Manager or the PAS Manager and charges a Manager Fee. Offering Style Manager Strategies and PAS Style Manager Strategies constructed by Merrill or by one of our Affiliates where a Manager Fee is charged is subject to our internal policies and any applicable legal requirements. We also act as an investment adviser in our other investment advisory programs, like MGI, MGI with Advisor, MEAA, SPA and MAS, which provide investment advisory and management services that, in certain ways, are similar to the Program Services but are not the same. Additional information about such other programs is available in the “About Us and the Program” and in “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Performance-Based Fees The Program does not charge performance-based fees. Certain mutual funds and Alternative Investment Funds available in the Program, however, may be subject to performance-based fees or varying fund expense charges that are imposed by the manager, adviser or other party that are based on performance of the mutual fund or Alternative Investment Fund. I Methods of Analysis The implementation and management of any Portfolio will be dependent upon your Advisor’s or MFSA’s investment expertise, philosophy and process. We make available various resources, including securities research and guidance prepared by BofA Global Research, investment guidance and management research and publications from the CIO covering macroeconomic and market events and specific Style Manager Strategies, PAS Style Manager Strategies and CIO-reviewed Funds, information and assistance from other Merrill internal specialists and support teams and information from selected third-party research providers and other resources. They have access to Merrill’s asset allocation guidance and proprietary model portfolios, including those constructed and managed by the CIO. Any use of such guidance and proprietary model portfolios does not assure or guarantee that investment performance will necessarily be profitable or consistent with the proprietary model portfolio. C E R T A N I N V E S T M E N T We and your Advisor or MFSA, as the case may be, can use various securities analysis methods, including fundamental, technical, quantitative and economic analyses, and can reference primary source materials, including company management contacts, company releases, financial and trade publications, corporate rating services, annual reports and filings with governmental agencies and research reports and market commentary issued by investment firms that are not affiliated with us. The method of analysis used for a Portfolio varies among and depends on the individual practice and investing philosophy of the Advisor or MFSA. There is no assurance that a particular Advisor or MFSA will use any of the methods of analysis identified above. R I S K S Investment Strategies and Risk of Loss Set forth below is a summary description of material risks related to the Program Services provided in the Program and investment strategies and products that have significant or unusual risks. The information provided below is meant to summarize certain risks and is not inclusive of each and every potential risk associated with each investment type or applicable to a particular Account. Therefore, you should not rely solely on the descriptions provided below and are urged to speak with your Advisor or MFSA and ask questions regarding risk factors applicable to a particular investment strategy or product, read all product-specific risk disclosures and determine whether a particular investment strategy or type of security is suitable for your account in light of your specific circumstances, investment objectives and financial situation. Target Asset Allocation and Monitoring. Any target asset allocations (including your Target Asset Allocation) or benchmarks, as applicable, referred to in connection with your Portfolio are not intended to be an assurance or guarantee of the performance of any investments in the Portfolio or of the Portfolio itself. There is no assurance that the performance results of any benchmark or index used in connection with a Style Manager Strategy or PAS Style Manager Strategy, including those shown in a Profile, can be attained. Market movements and other factors (including withdrawals from an Account) may result in significant differences between the performance of any Style Manager Strategy or PAS Style Manager Strategy and any Target Asset Allocation for your Portfolio. Lack of Diversification. We typically recommend that clients diversify their investments across multiple asset classes, issuers, sectors and industries to reduce the additional investment risk frequently associated with concentrated investments. The Equity-Focused, Fixed Income-Focused and Alternative Investment-Focused Target Asset Allocation options limit the Portfolio to exposure in a specific asset class and limit the diversification benefits offered in other available Target Asset Allocations. You should understand that concentrated portfolios, including Portfolios with a concentration in one asset class, typically result in increased risk and volatility and decreased diversification, which could result in losses. Multi-Client Account Portfolio Groups. All participants in a multi-client Portfolio Group will have access to information about the Accounts included in the multi-client Portfolio Group. The management of the Accounts that are included may be affected by the multi-client Portfolio Group’s Target Asset Allocation, as well as by the addition and removal of Accounts by other clients participating in the multi-client Portfolio Group. The fees and other costs in your Account that is included in a multi-client Portfolio Group may be more or less than if your Account were not in such a Portfolio Group. If you have agreed to a multi-client Portfolio Group, the members of the Portfolio Group will receive Program Reports that include information about other of your accounts included in the report. Unsolicited Trading. Effecting unsolicited trades may limit your financial advisor’s ability to make recommendations in accordance with your Target Asset Allocation. If you choose to invest assets in a manner that differs materially from our investment recommendations, you may assume additional risks that Investment Advisory Program Brochure | 40 IAPB-032025  result from your decisions. We have no obligation to monitor securities that you include in your Account on an unsolicited basis. If you effect trades in securities that we do not cover for research purposes or about which BofA Global Research has a contrary recommendation, this will be at your own risk. Engaging in Margin and Securities-Based Lending with your Account. As disclosed in your brokerage account agreement, if you use margin to purchase securities, the collateral for the margin debit will be the assets in your Accounts and other accounts at Merrill. The costs, risks and other features and conditions of margin are more fully described in our margin Agreement and disclosures. We can take certain actions if the value of the collateral supporting the margin debit declines in order to maintain the required equity in the account, such as issuing a margin call or selling securities or other assets maintained at Merrill. We can increase our “house” maintenance margin requirements at any time and we are not required to provide you with advance written notice. You are not entitled to choose which securities or other assets are to be liquidated or sold to meet margin calls and you are not entitled to an extension of time on a margin call. If a margin call cannot be fully satisfied from assets in your Account or other assets at Merrill, you will remain liable for the outstanding debt. Overall, margin increases the risk of losses in declining markets that negatively affect the value of securities bought on margin. You assume full responsibility for using margin to buy securities and may discontinue the use of margin at any time. If you invest using margin, you assume additional risk, including the fact that your losses may exceed the amount you have in your Account. Certain of your Account assets may be “pledged” or used as collateral, if we consent, in connection with loans obtained through certain Affiliated Lending Programs and unaffiliated loan programs. Risks to your Portfolio will be heightened in the event you pledge your Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. The lender has the right to protect its own commercial interests and to take actions that adversely affect the management of your Account and related performance. Regardless of whether the lender is us, an Affiliate or a third-party lender, the lender’s lien is senior to any rights we may have on the assets in the Account. As such, the lender has the right to sell securities in the Account that serve as collateral, if needed. You may not be provided with prior notice of a liquidation of securities or transfer of interests in your pledged Account and neither may Merrill or its Affiliates. Furthermore, neither you nor we are entitled to choose the securities which are to be liquidated or transferred by the lender. Role of Your Financial Advisor in the Program. The view of your financial advisor is an important factor as to which services, securities, Funds, Style Manager Strategies and/or PAS Style Manager Strategies are recommended to you or purchased for your Account. If your financial advisor is designated as an MFSA, they may only recommend to you certain Style Manager Strategies approved for them to offer and/or recommend to you. If you work with an Advisor and have selected a Defined Strategy, Personalized Strategy with Advisor Discretion and/or Custom Managed Strategy with Advisor Discretion for your Portfolio, your Advisor has discretion and Authority with respect to the investments in the Account or Portfolio. The performance of the Portfolio will be dependent in part on your Advisor’s ability to develop and implement an investment strategy. For a Portfolio with a Defined Strategy, your Advisor has the discretion to manage the assets in a manner that is different from the description provided in the Defined Strategy Profile without your consent. Certain Advisors manage the same securities across different clients’ Accounts and in Accounts that have selected different Program Strategy types for their Accounts. Clients can have different execution experiences depending on the nature of the Program Strategy they have for their Account. Clients should understand that, because of timing and the need to obtain client authorization, to the extent an Advisor has clients in a Program Strategy type where they have the investment Authority and intends to buy or sell a security for clients with an Account where the client has the Authority at or about the same time, the Advisor can generally execute the transaction for the discretionary accounts before executing it for non-discretionary investment accounts. This could have a negative effect on the performance of accounts where the client retains the investment Authority. Information and Cybersecurity Risks. With the increased use of technologies to conduct business, like all companies, Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks and accordingly. BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, Style Managers and PAS Managers, the Funds and Fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents suffered by BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents and well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that we or our service providers, will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. The focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. Investment Advisory Program Brochure | 41 IAPB-032025 We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory, and operational reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. General Risks Associated with Investments Available in the Program. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed and the value of your assets will fluctuate due to market conditions and other factors. Investments made and the actions taken respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi- governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Portfolios that consist of equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. You should review the offering materials and other disclosure available for each relevant investment security or transaction, including any prospectuses and other offering material produced by issuers and sponsors of investment products, to get an appreciation of its associated risks and fees. You are assuming the risks involved with investing in securities and other investment products, and you could lose all or a portion of the amount you hold in the Program. For a discussion of conflicts of interest with the use of certain investments and securities, please review the information in this section and in “Item 9 Compensation, Conflicts of Interest and Material Relationships.” Use of Style Manager Strategies and PAS Style Manager Strategies. By deciding to allow a Style Manager to give investment directions to Merrill and/or by deciding to allow a Discretionary Manager or a PAS Manager to make investment and trading decisions with respect to the investment strategy for your Account, you assume the risks associated with such investment manager’s investment decisions. If any such Manager effects trades in securities that we do not follow or for which we have a contrary recommendation, you assume the risk associated with this activity. If the investment manager assembles a concentrated position in the Account, you assume the risk of a substantial loss in value to the entire Account if there is a decline in the concentrated position or industry sector. Other risks of holding concentrated positions include substantial loss in the Account based upon the loss in value of a single security or industry sector and the impact that a large, concentrated position will have on the manager’s ability to diversify the Account. Similarly, if the investment manager chooses to make use of margin to effect transactions in an Account, you assume the risk associated with margin transactions, including the risk that losses in the value of an asset purchased on margin are magnified as a result of the use of borrowed money. If an investment manager or an Advisor with Discretion uses option strategies as part of their respective investment strategy, including writing uncovered options or combination or straddle options, you assume additional risk. These risks include being exposed to potentially significant losses. If you are in a Style Manager Strategy or a PAS Style Manager Strategy for your Account, you acknowledge that the Style Manager or PAS Manager may sell all or a portion of the securities in your Account, either initially or while in the Style Manager Strategy or the PAS Style Manager Strategy. You are responsible for all tax liabilities arising from these transactions. We and your financial advisor will not offer tax advice to you on these or other issues. The Style Manager Strategies that are constructed, implemented and managed by Merrill, MAA or one of its Affiliates and a Defined Strategy that is managed by your Advisor are not subject to the same level of review that is applicable to third-party managers. ESG-themed Strategies or Funds. There are an increasing number of products and services that purport to offer environmental, social, and governance (ESG) or sustainable investing strategies (ESG Strategies). The variability and imprecision of industry ESG definitions and terms can create confusion. Investment managers and product sponsors have designed their own approach to ESG investing and how they use ESG-related terms for their investment products. Merrill and MAA generally do not undertake a review of these approaches (including, where applicable, any ESG-related investment policy or process followed by the manager) other than as part of the CIO Review Process. You should review the offering materials and Profiles to gain an understanding of how these managers and product sponsors describe their investment approach. ESG Strategies, including ESG-related Funds, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by a Style Manager or fund manager, will align with your ESG-related beliefs or values. In addition, investments identified as Investment Advisory Program Brochure | 42 IAPB-032025 demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s ESG or sustainability-related practices and the Style Manager or Fund manager’s assessment of such practices could change over time. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities and, as a result, investment performance could suffer. On the other hand, category restrictions that aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category may not exclude all companies with any tie or revenue derived from such restricted category and require assumptions, opinions and the subjective judgment of the data provider that might not reflect your ESG-related views or values. If you hold an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event. Category restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that client restrictions would not have any practical effect on an account comprised primarily of Fund investments. When evaluating investments for an ESG Strategy, a Style Manager or Fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment of an investment’s ESG or sustainable attributes. Neither Merrill nor MAA guarantees or validates any third-party data, ratings, screenings or processes. Moreover, the screenings and processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in a Portfolio holding investments in companies that derive revenue from the restricted category. ETFs. ETFs are subject to risks relating to market trading that include the potential lack of an active market for ETF shares and disruptions in the creation and redemption process. Although ETF shares are listed on a national securities exchange, it is possible that an active trading market may not develop or be maintained, particularly during times of severe market disruption. If ETF shares need to be sold when trading markets are not properly functioning, they may be sold at a significant discount to their net asset value (NAV), or it may not be possible to sell them in the secondary market. Market and other disruptions also make it difficult for the ETF to accurately price its investments, thereby potentially affecting the ETF’s price and performance. Similarly, an exchange or other markets may issue trading halts on specific securities or derivatives, which will affect the ability of the ETF to buy or sell certain securities or derivatives. In such circumstances, the ETF may be unable to rebalance its portfolio or accurately price its investments and may incur substantial trading losses. An ETF’s prospectus contains important information including disclosures about risks, fees and expenses. You should review the prospectus and other disclosures available for each ETF relevant to your Account to get an appreciation of its associated risks and fees. Alternative Investments. There are risks associated with investments in Alternative Investments, which includes Alternative Investment Funds and in NTFs. Alternative Investments are in general speculative and illiquid investments that are subject to a high degree of risk. Alternative Investment Funds are only available to certain clients who meet applicable eligibility and suitability requirements and in circumstances approved by us. The offering materials for Alternative Investment Funds contain material information relevant to making a decision to subscribe to the Alternative Investment Fund including its investment strategy, liquidity terms, fees and expenses, risks and conflicts of interest, as well as about the investment manager, fund operations and processes and how redemption requests are processed, including how proration of redemption requests may be applied for certain Alternative Investment Funds. NTFs are classified as Alternative Investments by us because their principal investment strategies utilize alternative investment strategies (including short selling, leverage and derivatives as principal investment strategies) or provide for alternative asset exposure as the means to meet their investment objectives. They may not have the same type of non-market returns as Alternative Investment Funds since they have a relatively liquid and accessible structure with daily pricing and liquidity, are subject to a more structured regulatory regime and offer lower initial and subsequent investment minimums. Annuities. The following Annuities are available in the Program: (1) variable annuities (offering a range of investment options, called subaccounts, across different asset classes); (2) variable index annuities (offering a choice of index strategies and providing certain protection against downside market risk and limited participation in index gains without directly investing in the market or an index); and (3) fixed indexed annuities (offering a choice of index strategies and providing protection against downside market risk combined with limited participation in gains tied to a particular index without directly investing in the markets or an index). Annuities are long-term investments primarily designed for retirement purposes and can offer tax-deferred accumulation with options for downside protection, death benefits and lifetime income. Variable annuities and variable indexed annuities have market risk because the contract value fluctuates based on the investment performance of the subaccounts selected or the index selected. Because the value of a variable annuity and a variable indexed annuity is tied to the performance of the investment options chosen, it is subject to investment risk. The value of your Annuity will vary and could decline to less than the value of the premiums you have paid. You must pay the Annuity fees, charges and other expenses regardless of how the Annuity performs. Optional guaranteed benefits, which can normally only be elected at the time your Annuity contract is issued, could restrict your investment options and in some cases cannot be reversed. You’ll pay additional charges for optional benefits and guarantees, whether or not you use the benefits. If you want to take back the money you’ve paid in premiums under an Annuity contract, your withdrawal may be subject to surrender charges. These charges are described in the Annuity contract and prospectus/statement of understanding. In addition, your contract with the Annuity Issuer may include specific guarantees and payment commitments. Those are obligations of the insurer and are not guaranteed by Merrill or its Affiliates. If the insurer goes out of business, or if it lacks the funds to meet its obligations, including optional guaranteed benefits, you may not receive all of the promised income. Brokered CDs. Rates paid on brokered CDs may be lower or higher than the rates available directly through the bank that is issuing the brokered CD or through a Merrill brokerage transaction. You are responsible for monitoring the total amount of brokered CDs and other bank deposits that you hold with any one bank for FDIC insurance limits. VRDOs. VRDOs are variable rate demand obligations issued by municipalities or other municipal entities that carry an interest rate that resets periodically and that allows an investor to “put” or “tender” the VRDO to the issuer at the full face value of the VRDO plus accrued interest. The issuer engages a remarketing agent that is responsible for setting the VRDO’s interest rate and for reselling VRDOs that have been tendered for purchase by their holders. For VRDOs available at Merrill, BofAS acts as the remarketing agent and earns fees associated with this activity from the issuer. VRDOs also often have a contractual source of liquidity in the form of a letter of credit or stand-by purchase agreement from a financial institution; for certain VRDOs, our Bank Investment Advisory Program Brochure | 43 IAPB-032025 Affiliates may provide such contractual liquidity enhancement. Risks include interest rate risk; the inability of the remarketing agent to find purchasers for tendered securities; the inability to obtain an appropriate replacement liquidity provider to support the issuer’s repurchase obligation at an acceptable price where needed; the risk of issuer default; and the credit risk of liquidity providers affecting the pricing levels of VRDOs. Market-Linked Investments. MLIs are typically unsecured debt securities of the companies that issue them, which may include, from time to time, an Affiliate of Merrill. Your return on MLIs, including the amount you receive at maturity, if any, will depend on the performance of an underlying market measure, which may include stocks, indices, currencies, commodities or interest rates. The issuing companies of the MLIs are financial institutions and other entities that are subject to due diligence reviews by us and/or our Affiliate. MLIs are only available to clients who meet applicable eligibility requirements. The prospectus for an MLI contains material information relevant to making a decision to purchase the MLI, including its economic terms, risks and conflicts of interest. An investment in MLIs involves particular risks. MLIs are not conventional debt securities, typically do not bear any interest, and are not insured by the FDIC or secured by any collateral. Any payment on MLIs will be subject to the credit risk of the issuing company. Neither the issuing company, Merrill or its Affiliates, nor any unaffiliated third-party broker dealer is obligated to make a market for, or to repurchase, any MLI. Precious Metals. The prices of Precious Metals are volatile and influenced by a wide range of economic, political, market-related and other factors. In addition, investing in Precious Metals is subject to all the risks of holding physical assets (including, without limitation, loss, theft, inaccessibility and corruption), which are generally not relevant to most financial instruments. Purchases and sales of Precious Metals through the third-party provider and the holding of Precious Metals at approved vaults will carry additional risks such as counterparty and custody risks. Uncovered Options, Uncovered Call Writing, Short Selling and Options Overlay Strategies. If you write uncovered options or take action to sell stock short, you will be exposed to potentially significant losses. For a call option, if the value of the underlying instrument increases above the exercise price, you can incur large and unlimited losses until the option expires or other option contract remedies are pursued. For a put option, you bear the risk of loss if the value of the underlying instrument declines below the exercise price. If you write combination or straddle options (where a put and a call option are written on the same underlying instrument), the potential risk of loss is unlimited. If a secondary market in options were to become unavailable, you could not engage in a closing transaction and you would remain obligated until expiration or assignment. If you do not meet the margin payment requirements described in your option account agreement, we may liquidate stock or options positions in your Account, with little or no prior notice to you. We reserve the right to not approve any Account to engage in uncovered options transactions or short sales. You assume full responsibility for writing uncovered options and selling stock short, including the possibility of incurring unlimited losses, and may discontinue writing options and short selling at any time. Options overlay strategies may be adversely affected by market behavior or unexpected events. Like with any strategy, no assurances can be given that options overlay strategies will accomplish their objectives. Tailored Investment Advice Under the Program, you set a Target Asset Allocation for your Account or Portfolio Group based on certain factors provided by you. You can also select one or more Program Strategies for each of your Accounts. You also may request that we impose Reasonable Investment Restrictions on an Account. Depending upon the Program Strategy you select, your financial advisor will help you select, or will select for you, investments consistent with your Target Asset Allocation, and other information you provide to us. If you have an investment policy statement or other investment guidelines (IPS), it is your responsibility to communicate your investment approach and preferences to your financial advisor. However, we do not have any responsibility to review, monitor or adhere to any IPS relating to your Account. Adherence to your IPS is solely your responsibility. To the extent the terms of such IPS conflict with an investment or Strategy you select under the Program, by signing the Agreement, you have agreed that the terms of such IPS were amended to incorporate by reference such investment or Strategy. Voting Client Securities You have the right to vote proxies for securities held in your Account or to select a third-party agent to vote on your behalf as further described in “Item 4 Proxy Voting.” In the event that proxy voting authority is granted to the Proxy Delegation Vendor and the Proxy Delegation Vendor declines to exercise its proxy voting authority, the proxy voting authority will revert directly to you. You may not delegate to us, and we do not accept or assume from you, proxy voting authority for any securities in your Account. ITEM 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS As part of the enrollment process, we elicit information about your financial circumstances, investment objectives, risk tolerance, time horizon and other information relating to your Accounts and Portfolios. We provide this information to Style Managers as necessary and pursuant to the Agreement. We do not generally provide this information to Funds. If you select a PAS Style Manager Strategy for your Account, you must also provide information about your financial circumstances, investment objectives, risk tolerance, time horizon and other information relating to your Account to the PAS Manager. In managing your Portfolio, we rely on information you provide and it is your responsibility to notify promptly your Advisor or MFSA, as the case maybe, of any updates to such information. In the Agreement, you represent to us that you have provided us and will provide us with information that is accurate and complete. Failure to do so could affect the suitability of the Program Services being provided to you. We are not required to verify the accuracy of the information. ITEM 8. CLIENT CONTACT WITH PORTFOLIO MANAGERS MAA has agreed to make one or more of its advisory or investment personnel reasonably available for consultation with you and your financial advisor regarding a Style Manager Strategy if you request. Upon request, Discretionary Managers periodically will make one or more of their advisory or investment personnel reasonably available for consultation with MAA, your financial advisor and you for a joint consultation regarding their respective Style Manager Strategy, composition and performance of a Strategy, and the factors underlying the selection of the securities. If you select a PAS Style Manager Strategy for your Account, your PAS Manager/Client Contract will provide for the level of client contact available to you with the PAS Manager and its investment or advisory personnel. Investment Advisory Program Brochure | 44 IAPB-032025 ITEM 9. ADDITIONAL INFORMATION Disciplinary Information The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill Lynch’s Form ADV at adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the MLBD Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease- and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a mark-up or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self- reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’ remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. Other Financial Industry Activities and Affiliations Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through BofAS, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. MAA, an indirect wholly-owned subsidiary of BofA Corp., is a registered investment adviser that provides investment advisory services to clients that enroll in the Program and other investment advisory programs, including MGI, MGI with Advisor and MEAA. As registered investment advisers, MLPF&S and MAA complete Form ADVs which they publicly file with the SEC (available at adviserinfo.sec.gov). For purposes of Form ADV, certain MLPF&S and/or MAA management persons are registered as registered representatives or associated persons of MLPF&S. In the future, certain MLPF&S and MAA personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of MLPF&S to the extent necessary or appropriate to perform their job responsibilities. BofA Corp. through its subsidiaries and Affiliates, including us, provides broker dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include: (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning, asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, Investment Advisory Program Brochure | 45 IAPB-032025 consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales; and (10) providing research including, global equity strategy and economics, global fixed income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act and information can be found in its publicly available filings with the SEC. Conflicts of Interest and Information Walls Merrill, MAA and their parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within the BofA Corp. organization possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., BofAS, Merrill and MAA evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. Code of Ethics Each of Merrill and MAA has adopted an Investment Adviser Code of Ethics (Code of Ethics) covering its personnel who are involved in the operation and offering of investment advisory services under the various investment advisory programs for which they are a registered investment adviser. Each Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that each of Merrill and MAA follows in conducting its respective business with integrity and professionalism. Each Code of Ethics covers requirements relating to employees complying with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. Covered personnel must certify to the receipt of the Code of Ethics. The Merrill Investment Adviser Code of Ethics is available at mymerrill.com/ADV/ materials or we will provide a copy of each Code of Ethics to you upon request. Merrill and MAA have each imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions, as well as those of all our employees. Our requirements impose certain responsibilities on financial advisors and their trading. They are permitted to participate in block trades along with their clients and/or other Program clients. Compensation, Conflicts of Interest and Material Relationships Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel I Merrill Benefits. Merrill earns revenue from the Merrill Lynch Fee paid to us under the Program for our and our financial advisors’ providing Program Services, as well as from commissions, mark-ups and mark-downs, up-front sales charges and other sales charges or fees (Sales Charges) paid in connection with brokerage transactions. Merrill also earns revenue from other fees and payments you may make and from what it receives from Affiliates and from third-party investment managers, fund managers (including for Alternative Investments), product distributors and sponsors, insurance companies and other product providers (Third-Party Firms) related to transactions in your Account. Merrill may also receive revenue from Third-Party Firms depending on the investment products in which you invest, which is not part of financial advisor compensation. C O M P E N S A T O N A N D C O N F L I C T S O F I N T E R E S T The amount of revenue we receive and compensation your financial advisor earns varies depending on the type of financial advisor you work with (i.e., an Advisor or an MFSA), the type of account relationship you have with us, whether your account is enrolled in the Program or is a brokerage account and investment products in which you invest and the services you use. The revenue we receive from your enrollment in the Program may also be more or less than the revenue that would be received if you had instead participated in other of our investment advisory programs or if you had engaged in the investment activities in a brokerage account. The more assets there are in your Account, the more you will pay in fees, creating a financial incentive for us and your financial advisor to recommend that you increase the assets in your Account. In the Program, we make more revenue based on the level of assets in the Account as well as the level of the Merrill Lynch Fee Rate that you agree to or are charged. There is a conflict of interest when your Advisor recommends an account or program type, a security transaction or investment strategy where it is expected that Merrill will earn greater revenue over another account or program type, security transaction or investment strategy and therefore will earn more compensation. Advisor Compensation and Awards. The financial advisor compensation structure results in conflicts of interest between clients and financial advisors. Financial advisors earn compensation based on the revenue that Merrill earns from the Merrill Lynch Fee paid by you in the Program and other revenue derived from certain, but not all, of the other fees and costs you incur that are not covered by the Merrill Lynch Fee. They also earn compensation based on the revenue that Merrill earns from Sales Charges related to securities transactions in any brokerage account you may have as well as from the revenue derived from the referrals to Affiliates (including referrals to an Affiliate for banking products or services). You could pay higher fees in a brokerage account than from one enrolled in the Program depending on the level of trade activity, products invested in and other factors, which incentivizes your Advisor to recommend a brokerage account. By contrast, if the trading activity in your brokerage account is limited, your Advisor has a financial incentive to recommend that you enroll in the Program because we and your Advisor could earn greater compensation from the annual asset-based fee. For more information about these conflicts, please review the section “Account and Program Choice.” As Merrill revenue increases, the financial advisors’ compensation will increase or will be positively impacted. This means that a financial advisor will have a financial interest in recommending transactions that generate higher amounts of revenue for Merrill and compensation for them, rather than those transactions that generate lower amounts of revenue. They also have the incentive to charge the maximum Merrill Lynch Fee Rate rather than agreeing to a lesser fee rate or offering a discount or waiver of Sales Charges for brokerage transactions where they have the discretion to do so. Investment Advisory Program Brochure | 46 IAPB-032025  We pay Advisors a salary and incentive compensation that is based on the revenues Merrill receives for making available and/or providing Program Services as well as for the brokerage services provided to clients with brokerage accounts. In general, an Advisor is credited in the form of “production credits” with a portion of the Merrill Lynch Fee paid and, for brokerage accounts, the Sales Charges received from securities transactions. In addition, Advisors also receive production credits based on clients’ use of margin lending, in respect of cash swept to Bank Affiliates and for referrals of clients to BANA and other Merrill Affiliates for banking, lending and other financial services, including trade execution. The calculation of production credits generated takes into account the Merrill Lynch Fee charge you pay for the Program Services, the Sales Charges received for the investment products purchased or sold in any brokerage account and other factors which may change from time to time. Because different investment products and services have varying Sales Charges, there are different associated production credits related to brokerage transactions in those products. Merrill compensates your Advisor on an ongoing basis derived from the Merrill Lynch Fee Rate that applies to your Account. The Merrill Lynch Fee Rate is negotiable and when considering whether to offer or agree to charge a lower Merrill Lynch Fee Rate, an Advisor typically will consider a number of factors, including the type and size of your Account, the breadth of our relationship with you, your engagement with the Advisor, the Program Strategy type you selected for your Account, competitive considerations and how Merrill compensates the Advisor. Because the amount of compensation paid to your Advisor is based on the Merrill Lynch Fee Rate for your Account, your Advisor has a financial interest in that rate. In general, Advisors receive “production credits” toward their compensation formula based on the amount of the Merrill Lynch Fee that you pay for your Account. Merrill’s policies result in Advisors receiving fewer production credits (by 10% or more) if the weighted average Merrill Lynch Fee Rates for a client’s Accounts and for the Accounts that are part of the Household is lower than the rate levels for specific wealth asset tiers that Merrill establishes. Merrill and Advisors have a conflict of interest based on this structure because the Advisor is incentivized not to offer a Merrill Lynch Rate below such rate levels since that would reduce their compensation. In addition, as part of Merrill’s practice management guidance, Merrill provides statistical information about the Merrill Lynch Fee Rates negotiated by Advisors and their clients. This information can encourage Advisors to not agree to a lower Merrill Lynch Fee Rate. In the Program, an Advisor’s financial incentive to obtain the highest Merrill Lynch Fee Rate in the fee discussions with you can influence the recommendations for an Account related to Program Strategy type and as to Style Manager Strategies and PAS Style Manager Strategies (both of which can have their own separate Manager Fee). The higher the Merrill Lynch Fee Rate you agree to, the more your Advisor earns in production credits. The more overall production credits that an Advisor generates, the higher the Advisor’s incentive compensation. This creates a conflict of interest for the Advisor to recommend a Program Strategy type, a Style Manager Strategy and/or a PAS Style Manager Strategy that results in more earned production credits. Certain of our Program Strategy types will result in your only paying a Merrill Lynch Fee while the Program Strategy types where you select a Style Manager Strategy or PAS Style Manager Strategy could result in your also paying a Manager Fee as part of your Program Fee. Recommending a Program Strategy type, a Style Manager Strategy and/or a PAS Style Manager Strategy where the Program Fee for the Account consists solely of the Merrill Lynch Fee or includes a low Manager Fee presents the Advisor with an opportunity to negotiate a higher Merrill Lynch Fee Rate than might otherwise be the case. This opportunity provides the Advisor with an incentive to recommend Program Strategy types with only a Merrill Lynch Fee or to include a Style Manager Strategy or a PAS Style Manager Strategy with no or a lower Manager Fee. The ability to negotiate a Merrill Lynch Fee Rate benefits Merrill as well as the Advisor since Merrill retains a certain percentage of the Merrill Lynch Fee. Advisors are eligible to receive a compensation award, payable over a defined period of time, from an incentive program that is currently based on meeting growth targets from the prior year in new households and in assets and liabilities. The growth in assets and liabilities component of the award is based on the movement of client assets into accounts enrolled in the Program and other of our investment advisory programs; investment activity in specified investment products (e.g., money market funds, Alternative Investments, 529 Plan accounts, annuities and/or life insurance); the opening of new BANA trust accounts; the establishment of 401(k) Plan accounts; and clients’ participation in banking and lending services (i.e., brokerage sweep deposit accounts and brokerage sweep money market funds, checking and savings accounts, the Preferred Deposit product available in brokerage accounts, loans, mortgages and margin lending) offered by Merrill, BANA and our other Bank Affiliates. Advisors do not receive additional compensation as a result of advisory client assets held in the Cash Sweep Program. An Advisor is subject to a reduction in their incentive compensation grid if they fail to achieve growth for two consecutive years in the assets and liabilities component of the award. Merrill considers and approves its compensation program from year to year and its compensation criteria can change that will impact compensation paid to financial advisors. Having a compensation award based on meeting criteria based on client investment activity and engaging with Merrill or Affiliate financial and banking-related services presents a conflict of interest between the Advisor and you because it could lead to such activity being promoted by your Advisor to qualify for the compensation award or to avoid the reduction in their incentive compensation. Advisor Recruitment Payments. Advisors who join Merrill from other firms generally receive payments in connection with that move. These payments may take various forms, including salary guarantees, upfront bonuses or loans and various forms of compensation contingent on continued employment. The amount paid to Advisors under these arrangements generally is based to a large extent on the size of the business at their prior firm. In addition, as part of the recruiting arrangements, they are eligible for future bonus payments based on assets that transfer, including from their prior firm, which creates a conflict of interest since they have an incentive to recommend a transfer of the assets to us. The future bonus payments are conditioned on the total assets in accounts that they service at Merrill. These bonuses are in addition to the incentive compensation to which they are otherwise entitled as Advisors. MFSA Compensation and Awards. We compensate MFSAs differently than we do Advisors. MFSAs receive a base salary and incentive compensation based on production credits attributable to their clients’ enrollment in the Program and, for brokerage accounts, any investment activity in such accounts. Separately, MFSAs are also eligible to receive referral fees under our defined referral programs. Upon meeting certain training, experience and client growth metrics (known as “performance goals”), they are eligible for promotion to the status of an Advisor and will be compensated and authorized to offer brokerage investment products and services and the full range of Program Services and investment solutions as is the case with any Advisor. The promotion criteria creates a conflict of interest for MFSAs to recommend the above products and services to qualify for promotion. Rollover Recommendations and Compensation. Advisors and MFSAs have a financial incentive to recommend rolling over assets (a rollover) from an employer-sponsored retirement plan (such as a 401(k) plan) or a retirement account at another firm into an Individual Retirement Account (IRA). This is because transactions in the rollover IRA will generate either investment advisory fees if that account is enrolled in the Program, Sales Charges if a brokerage account, and other compensation that benefits Merrill and the financial advisor. While MFSAs recommending a rollover do not receive compensation based on the amount of assets transferred, they have financial incentive to recommend a rollover because the subsequent or related enrollment into the Program will increase the number of accounts serviced by them and help them achieve certain performance goals. Investment Advisory Program Brochure | 47 IAPB-032025 Referral Program and Compensation. Our financial advisors may recommend that you utilize the banking products and lending services of BANA or purchase products or services of our Affiliates. In addition, they may refer clients to BANA, BofAS and other Affiliates for financial services that they provide, including transaction execution and investment banking services and products (including banking products). They may introduce fund and other investment product distributors, sponsors, service providers or their affiliates to other services that we, BofA Corp. and our Affiliates provide. Similarly, employees of BANA, BofAS and other Affiliates may refer clients to us for brokerage and investment advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. If a financial advisor refers a client to BANA or other Bank Affiliates to establish a bank account directly with the bank, Merrill receives a payment directly from each Bank Affiliate based on the daily deposit balance held by the Bank Affiliate. The amount of the payment made to Merrill varies from time to time and varies based on the Bank Affiliate. We may waive all or part of this payment. Our referral payment program results in a conflict of interest because Merrill and our financial advisors are incentivized to introduce products or financial, banking and lending services that provide us or our Affiliates additional compensation and/or the financial advisor with associated production credits. Field Management and Merrill Management Compensation. Elements of our field management compensation are based on revenues to Merrill and based on the financial advisors whom they manage meeting strategic goals set for the year, including the growth in assets and liabilities component of the award as described in the subsection “Advisor Compensation and Awards.” Management personnel of Merrill and other employees of Merrill, MAA and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is an incentive for our field management team to encourage Advisors and MFSAs to recommend products and services that result in more revenue to Merrill, BANA and other Bank Affiliates and to meet their strategic growth compensation targets under the financial advisor compensation plan. There is a financial incentive for Merrill management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. We address the compensation conflicts described in this “Compensation and Benefits to Merrill, Financial Advisors and Merrill Management Personnel” section and in other sections of the Brochure, in a variety of ways, including the disclosure of the conflicts in this Brochure, by requiring clients to affirm their interest for products in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients prior to or at time of sale. Moreover, our Advisors and MFSAs are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. We engage in oversight and supervision of particular account type relationships and specific investment product choices and we provide account and product disclosures. We maintain policies and procedures and supervisory and review processes that are reasonably designed to ensure that financial advisors meet the standard of conduct applicable to each client and that compensation plans and referral compensation and criteria have been designed and implemented to mitigate any incentive or conflict to favor any one security type or investment product or service. Our field management compensation criteria and our Merrill management compensation criteria have each been designed and implemented to mitigate incentives or conflicts to favor any one security or account type or investment, banking or lending product or service. Account and Program Choice Merrill can help fulfill your wealth management needs in our capacity as an investment adviser, as a broker-dealer, or as both. You have the ability to enroll accounts in the Program holding some or all of your investment assets and to have brokerage accounts for some or all of your assets. The various programs we offer and ways to interact with Merrill are outlined in the Form CRS, this Brochure and in the Summary of Programs and Services. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. There are differences among the programs and account relationships. You may be able to obtain the same or similar Program Services or types of investments you obtain in the Program through a brokerage account or other investment advisory programs and services offered by Merrill. These may be available at lower or higher fees than the Program Fee you pay. You may also be able to obtain some or all of the Program Services from other firms and at fees that may be lower or higher than the Program Fee we charge. A recommendation of the type of account relationship creates a conflict of interest for us and your financial advisor. The amount of compensation we and our Advisors receive depends on the type of account and relationship you choose. In the Program, you will pay the Program Fee at the rate you agree with your Advisor or as required under the Program. The Program Services provided include ongoing investment advice and guidance for your Portfolio, access to investment strategies and ongoing monitoring as described in this Brochure, as well as the services of trade execution, clearance and settlement of transactions and custody of assets. In the Program, the amount of compensation paid to us and to your Advisor depends on the level of assets in your Account and the Merrill Lynch Fee Rate applicable to your Account, as well as certain indirect compensation outlined in this Brochure. In a brokerage account, you will pay per trade Sales Charges to purchase and sell securities and a portion of those charges and fees will be paid to your Advisor. In a brokerage account, the amount of revenues we receive and the compensation that our Advisor receives depends on the level of trading activity in the Account, the applicable Sales Charges and the associated production credits as well as other indirect compensation. You could pay higher fees in a brokerage account than from an account enrolled in the Program depending on the Sales Charges, frequency of trading and the investment products for investment and other factors. By contrast, if the trading activity in your brokerage account is limited, your Advisor has a financial incentive or conflict of interest to recommend that you enroll in the Program because we and your Advisor could earn greater compensation from the Program’s annual asset-based fee. Your Advisor has a financial incentive to recommend that you terminate your Account or move mutual fund shares, AI Advisory Units or Annuities from your Account to a brokerage account if there is higher compensation that the Advisor would receive from holding such positions in a brokerage account. Moreover, an investor who holds a more expensive share class of a mutual fund or an Alternative Investment Fund will pay higher fees over time—and earn lower investment returns—than an investor who holds a less expensive share class of the security. Certain security types and investment strategies are available to you outside of the Program for more or less than you would pay in the Program. We offer other investment advisory programs that offer certain of the Style Manager Strategies that are the same as or similar to those available in the Program. There are important differences between this Program and our other available investment advisory programs in terms of the services, structure and the applicable fees. Depending on the Merrill Lynch Fee Rate you pay for Program Services, you may obtain these Style Manager Strategies for a lower cost than you pay in the Program but you will receive different services from the Program Services you receive or have access to, including (1) having direct access to and advice and guidance from your dedicated Advisor or your MFSA whom you have personally selected and chosen to work with in connection with your investment activity; (2) the investment options available; and (3) and the fee rates you pay. See “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Investment Advisory Program Brochure | 48 IAPB-032025 When you compare the account types and investment advisory programs and their relative costs with what is available in the Program, you should consider the various factors outlined in “Item 4 Ability to Obtain Certain Services Separately and for Different Fees.” Certain of these factors relate to your preferences regarding the relationship, whether you are seeking ongoing monitoring provided for in the Program, the types of investment services you are interested in, how you want to pay for your investing activity, the Merrill Lynch Fee Rate you agree to with your Advisor, how much trading activity you expect to take place in your Account and the types of investment solutions you are interested in investing in. We address these conflicts through the disclosure in this Brochure and the Agreement, by providing clients with upfront information about our available programs and through Program enrollment confirmations in light of your investment objectives, preferences and financial circumstances. In addition, we have certain internal requirements, guidelines, policies and procedures that review for whether a particular program selection is appropriate for the client and to address actual or perceived conflicts of interest. Moreover, our Advisors and MFSAs are required to recommend investment advisory programs, investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. Affiliated Investments of a Style Manager or a PAS Manager There are certain Style Manager Strategies that do not charge a Style Manager Fee. As a general matter, for such Strategies, the Style Managers intend to allocate a significant percentage of their portfolio to investment strategies and Funds for which they and/or their Affiliates serve as investment manager and as to which they receive fees (Style Manager-Related Investments). These compensation arrangements create a conflict of interest for the Style Manager relating to the Style Manager’s selection of investments (including from among the Style Manager-Related Investments) for the Strategy and the receipt of potentially higher compensation based on the selection. The Style Manager has an incentive to select Style Manager-Related Investments for the Strategy (including Style Manager-Related Investments with higher expenses) over other investments with lower expenses. This is because the fees that the Style Manager and/or its Affiliates receive for client account assets in the Style Manager-Related Investments are their compensation with respect to the Strategy. This selection could result less favorable performance for the Style Manager Strategy than otherwise would be the case if the Style Manager had not allocated to a Style Manager-Related Investment. In addition, certain Style Manager Strategies and PAS Style Manager Strategies include Manager-Related Funds. The use of Manager-Related Funds creates a conflict of interest for the Style Manager relating to the Style Manager’s or PAS Manager’s selection of Funds for the investment strategy and the receipt of potentially higher compensation or benefit based on the selection. The Style Manager or PAS Manager has an incentive to select Manager-Related Funds over other Funds with lower expenses because the fees received for client Account assets in the Manager-Related Funds are their compensation. We address these conflicts through disclosure in this Brochure and the Strategy Profile and by selecting investment products, Style Manager Strategies and Funds based on the investment merits of the particular investment products. Style Managers and PAS Managers utilizing Style Manager-Related Investments and/or Manager-Related Funds have an obligation under their fiduciary duties to select investments that are based on the investment merits of the particular investment products. As to the use of Manager-Related Funds, we obtain the agreement of the manager that any fees or expenses with respect to a Manager-Related Investment, other than certain costs incurred within such product and reflected in its returns, will be borne by the manager. In addition, where a Style Manager or PAS Manager uses a Manager-Related Fund that is charged fund management fees by the manager or its Affiliates, Merrill will work with the manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Style Manager or PAS Manager Fee. For more information about these conflicts, please review the Style Manager or PAS Manager’s Form ADV, which can be accessed at mymerrill.com/ADV/materials. Offering of Investments or Programs Managed by Us or Our Affiliates and Use of a Related Strategy in Your Account We or our Affiliates offer certain Related Style Manager Strategies and Related PAS Style Manager Strategies for which a Manager Fee is charged. Except as to TMA and Retirement Accounts, we or the Related Entity retain the Manager Fee attributable to the portion of assets in your Account attributable to the Related Style Manager Strategy or Related PAS Style Manager Strategy. We also retain the Merrill Lynch Fee. Your Advisor or MFSA can recommend a Related Style Manager Strategy or a Related PAS Style Manager Strategy with a Manager Fee for your Account. Furthermore, your Advisor can also recommend that you include this type of Strategy in a Custom Managed Strategy for your Account. An MFSA can recommend a Related Style Manager Strategy with a Manager Fee. In addition, in constructing a CIO Style Manager Strategy, the CIO as the Style Manager may include in its strategy model or recommendations to MAA a Related Style Manager Strategy with a Style Manager Fee. Likewise, a Merrill Affiliate in constructing a PAS Style Manager Strategy can include a Related Style Manager Strategy with a Style Manager Fee in the PAS Style Manager Strategy it constructs. We do not currently offer any Related Funds; however, we may include a Related Fund as an investment product available in the Program in the future. If a Related Fund is offered as an eligible investment in the Program, the Related Entity could receive compensation for providing such investment strategies or investment advisory, administrative or other services. A conflict of interest exists when we or your Advisor or MFSA selects or assists you in the selection of a Related Style Manager Strategy that charges a Manager Fee. We address this conflict through disclosure in this Brochure. We also determine the compensation paid to our financial advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our financial advisors do not have an incentive to recommend certain Style Manager Strategies or PAS Style Manager Strategies over others because they do not receive additional compensation from the presence of a Manager Fee for a Style Manager or PAS Style Manager Strategy. Variable Compensation by Product and Service Not every investment solution is available in the Program. We select the investment types and investment solutions that are available in the Program and that are available in a brokerage account based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and consistency of the execution of their strategy within the respective arrangement. The revenues we receive from a securities transaction vary based on the type of security or investment product and its terms. For certain securities or investment products, Third-Party Firms make payments to us as compensation for various services and support. These payments also vary depending on the type of security or investment product. While financial advisors do not receive this compensation, the variable nature of third-party payments create a conflict of interest because we may earn greater revenues from the sale of one type of security or investment product over another. Not all securities and investment products make payments to us or our Affiliates. Investment Advisory Program Brochure | 49 IAPB-032025 The variable nature of third-party payments creates a conflict of interest because it provides an incentive to recommend products for which Merrill receives third-party payments or is more highly compensated by the product provider over those where we do not receive such payments or higher compensation. We address this conflict through the disclosure in this Brochure and by selecting investment products, Style Manager Strategies, PAS Style Manager Strategies and Funds based on the investment merits of the particular investment products and not based on the compensation we receive from Third- Party Firms. We also determine the compensation paid to our financial advisors for a Program Account on the same basis for all Program assets without regard to the amount of revenue we or our Affiliates receive. In addition, we select investment products and solutions that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. For additional information, please review the sections “Compensation Received by Us for Sub-accounting Services,” “Mutual Fund Arrangements and Compensation,” “Certain Alternative Investment Fund Arrangements and Compensation,” “Cash Sweep Program Compensation Received by Us and Our Affiliates” and “Other Compensation Received by Us and Our Affiliates” below. Compensation Received by Us for Sub-accounting Services We only make available mutual funds, including money market funds, and Offshore Funds, and share classes that retain and pay us to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (sub-accounting services). Under agreements with each of these types of mutual funds (or their respective principal underwriter or other agent), we provide daily sub- accounting services to the holders of these types of mutual funds maintaining shares in an Account as well as in other Merrill securities accounts and receive the agreed-upon sub-accounting services fee. This cost is either borne by the mutual fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by type of mutual funds, the mutual fund itself and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. Due to applicable regulation, we do not retain compensation for sub-accounting services for funds held in Retirement Accounts or TMA accounts. For U.S. mutual funds, depending on the specific arrangements, the sub- accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market mutual funds, the sub-accounting services asset-based fee is generally 0.005% per annum. Money market funds available to TMAs and certain retirement accounts as an automatic cash sweep option also include a 0.40% asset-based administration fee per annum that is paid to Merrill. Merrill rebates the amount of the asset- based administration fee it receives from the fund manager to clients with this sweep option. The amount of such rebate may be less than this 0.40% fee in certain rate environments where the fund manager waives or reduces the amount of such fee in order to avoid a negative return on the money market fund. For Offshore Funds, we and our Affiliates perform similar distribution, marketing, shareholder servicing, sub-accounting and related services for which the Offshore Fund’s distributor or other service provider pays asset- based compensation in the form of a bundled fee of up to 0.75% per annum for no-load shares and up to 0.80% per annum for load-waived front load shares of offshore mutual funds and up to 0.115% per annum for offshore money market funds. We have a conflict of interest in selecting certain mutual fund products (or share classes) for inclusion as part of our product offering available to you. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of our product menu but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting services fees that we charge will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the sub-accounting services fees varies among mutual funds and, in certain instances, between share classes of individual mutual funds. This results in a conflict of interest because it creates an incentive for us to recommend that you invest in mutual funds and share classes that pay higher fees. We receive higher sub-accounting payments from mutual fund families that have higher assets levels held in our clients’ accounts because the service fee calculation can be based off of the level of the asset holdings. Additionally, there is a benefit to us because the aggregate amount of the sub-accounting fees exceeds the costs to provide these services. We address these conflicts of interest in the following ways. We disclose the nature of our sub-accounting service arrangements. We also determine the compensation paid to our financial advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our financial advisors do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we and our Affiliates select mutual funds that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based primarily on the CIO Review Process and business reviews. Mutual Funds Arrangements and Compensation Your assets are generally invested in the lowest cost mutual fund share class eligible for the Program. The Program-eligible share classes vary depending on the mutual fund, its roster of share classes and our agreements with the mutual funds. In general, the share classes that are eligible for the Program allow for the payment to us of the sub-accounting services fee and do not have annual asset-based fees like Rule 12b-1 fees (although there are some mutual funds available in the Program that have such fees due to legacy positions that are pending conversion or exchange to an eligible share class). Accordingly, you should not assume that you will be invested in the share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. In addition, the share class of money market funds available as part of the cash sweep option for certain types of accounts will not necessarily be the lowest cost share class available from the money market fund. It is generally in your best interest to purchase lower-fee share classes because your returns are not reduced by additional fees and expenses. For clients in the Program, our financial advisors do not have an incentive to recommend or select share classes that have higher expense ratios because their compensation is not affected by the share class selected. From time to time a mutual fund may authorize us to make available to clients participating in the Program a class of shares with a lower fee structure that we believe is more beneficial to you than the class of shares previously made available in the Program. Where such exchange is available, under the authority provided to us under the Agreement, we will effectuate such an exchange to the other class of shares of the same mutual fund with the lower fee structure as promptly as practicable. For additional information on mutual funds, money market funds and Offshore Funds, you can review our disclosure documents Mutual Fund Investing at Merrill Lynch and Offshore Mutual Fund Investing at Merrill Lynch, accessible at ml.com/funds and available from your financial advisor upon request. Investment Advisory Program Brochure | 50 IAPB-032025 Certain Alternative Investment Fund Arrangements and Compensation Merrill and its Affiliates have negotiated fee sharing arrangements with managers of certain Alternative Investment Funds available through the Program and also in brokerage accounts. Pursuant to these arrangements, except as restricted by law or regulation, we receive additional compensation (Additional AI Compensation) for our efforts related to distribution of interests in the Alternative Investment Funds. Any Additional AI Compensation that we or our Affiliates receive in connection with your investments in an Alternative Investment Fund will be in addition to the Program Fee. We offer and recommend Alternative Investment Funds where we receive on-going fees from the fund and/or the fund administrator, manager or their Affiliates. For Alternative Investment Funds that are feeder funds which are available for purchase only by clients of Merrill or its Affiliates (feeder funds), the administrator of such feeder funds pays us selling agent compensation in the amount of up to 0.85% per annum of the net asset value of units or shares of such feeder funds, which is paid out of the administrator’s administration fee. In addition, the administrator of certain hedge feeder funds receives from the underlying manager payments of retrocessions equal to a percentage of the management fees paid by the feeder fund to the underlying manager. Such retrocessions generally equal an amount of up to 1.00% of the value of the feeder fund’s investment in the underlying fund and are paid to us as selling agent compensation. For Alternative Investment Funds that are not feeder funds, we generally receive a payment from the fund’s manager or its Affiliates of up to 1.00% of the total amount invested or committed to be invested in the fund by Merrill clients. Retirement Accounts investing in Alternative Investment Funds do so through AI Advisory Units which do not provide for fee sharing with or the payment of placement or selling agent fees to Merrill or its Affiliates. Merrill also receives additional compensation from certain hedge fund and private equity fund managers available to brokerage as well as Program- enrolled accounts in the form of one time up-front payments or periodic flat fee payments (which generally do not exceed $350,000). Certain Alternative Investment Funds pay and/or reimburse their investment advisors or managers for organizational and offering costs incurred prior to the commencement of their operations and certain ongoing expenses, including due diligence expenses of participating broker-dealers, such as Merrill, supported by detailed and itemized invoices. The investment advisor or manager of the Alternative Investment Fund or the Fund itself has agreed to pay (or reimburse) Merrill for reasonable bona fide due diligence expenses that it incurs in connection with the offering. Among other things, our receipt of Additional AI Compensation and other payments/reimbursements as described in this Brochure (1) offsets or reduces the expenses associated with onboarding Alternative Investment Funds to our platform and (2) defrays costs incurred in connection with, and compensates us for, our efforts related to, the distribution of interests in these funds. These arrangements, which vary among the Alternative Investment Funds on our platform, give rise to a conflict of interest in determining which Alternative Investment Funds to make available to our clients and recommending investments in certain Alternative Investment Funds over others. Certain Alternative Investment Funds that may otherwise meet our criteria may not be selected due to an unwillingness by the Alternative Investment Funds, their managers or Affiliates to pay sufficient compensation to Merrill, thereby limiting the available universe of Alternative Investment Funds which we offer to you. The presence of this compensation also may cause us to forego opportunities to negotiate more favorable terms for client investments in the Alternative Investment Funds. You will find additional information about conflicts related to Alternative Investment Funds, including the exact percentage and method of calculation of distribution fees, retrocessions and other compensation that we receive, in the relevant offering documents and subscription documents. Under the Precious Metals Program available to you in the Program, Merrill shares in certain fees charged by the program provider which creates certain conflicts of interest. The program provider has agreed to share an amount equal to 0.05% of the service fee with us as compensation for ongoing sub- accounting, reconciliation, transaction and related services. Such relationships and fee-sharing result in a conflict of interest in Merrill’s retaining the program provider and/or recommending investments in Precious Metals. The presence of these compensation arrangements creates an incentive for us to recommend the Precious Metals Program to our Program clients over other alternative means of investing in Precious Metals. We address the conflicts of interests associated with our receipt of the Additional AI Compensation and other payments/reimbursements described in this section by calculating the compensation paid to our Advisors on the same basis for all Program assets and without regard to the amount of any Additional AI Compensation Merrill or our Affiliates receive in connection with the Investments. Additionally, we and our Affiliates select the Alternative Investment Funds and managers that are available on our brokerage and advisory platforms and offered through the Program based primarily on the CIO Review Process. We have adopted various policies and procedures reasonably designed to prevent the receipt of the Additional AI Compensation and our other business arrangements from affecting the nature of the advice we provide. Cash Sweep Program Compensation Received by Us and Our Affiliates Merrill benefits financially when you hold cash balances in the bank deposit accounts affiliated with the Cash Sweep Program. Merrill receives payments from our Bank Affiliates on a per account basis for each account that sweeps to one of our Bank Affiliates relating to offering and supporting the Cash Sweep Program. The fees we receive from the Bank Affiliates is one of many factors that affect the interest rate paid by the Bank Affiliates on your swept cash balances under the Cash Sweep Program. For Accounts that are eligible for and that elect a money market fund as its cash sweep option, we receive compensation for providing infrastructure, marketing support, sub-accounting or other services. If you choose the “No Sweep” option, we also benefit from the custody or use of uninvested cash balances also known as free credit balances in Merrill accounts, subject to restrictions imposed by Rule 15c3-3 under Exchange Act. For the ISA cash sweep option available to certain account types, we receive a fee directly from each Participating Bank based on the daily deposit balance held by the Participating Banks. The amount of the fee varies from time to time and by Participating Bank. For referrals made by a financial advisor resulting in a bank deposit account with a Bank Affiliate, we are entitled to receive a fee directly from each Bank Affiliate based on the daily deposit balance, which fee can be waived in whole or in part. For Program Accounts, Advisors are compensated based on the Merrill Lynch Fee charged on the Account which is based on the agreed-upon Merrill Lynch Fee Rate and the value of the assets in the Account, including cash balances and cash alternatives swept under the Cash Sweep Program. This creates a conflict of interest and an incentive for your Advisor to recommend that you hold your securities investments and cash assets in your Account so that it would be included in the fee calculation. In addition, Merrill Advisors and MFSAs receive increased compensation based on achieving a number of strategic objectives, including, among other activities, the growth in their clients’ participation in banking services and Lending Programs offered by Merrill, BANA and our other Bank Affiliates, like the brokerage account bank sweep deposits and brokerage account sweep money market funds, checking and savings accounts, the Preferred Deposit product available in brokerage accounts, loans, mortgages and margin lending. Advisors do not receive additional compensation as a result of advisory client assets held in the Cash Sweep Program. Investment Advisory Program Brochure | 51 IAPB-032025 The Bank Affiliates benefit financially from the Cash Sweep Program. Through the Cash Sweep Program, they receive a stable, cost-effective source of funding. They use the cash funds deposited in the bank deposits to fund their current and future lending, investment and other business activities. The participation of the Bank Affiliates in the Cash Sweep Program increases their respective deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” they earn on the deposits—the difference between the interest paid on the bank deposits and other amounts paid to Merrill related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in your Account (which could be as a result of a recommendation from your Advisor, us or a Related Style Manager) that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more our Bank Affiliates benefit. Cash balances swept to a bank deposit account of our Bank Affiliates under the Cash Sweep Program will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts is periodically set and reset by the Bank Affiliates in their discretion. Interest rates for the MLBD Program and RASP are tiered based upon your relationship with Merrill and Accounts that enroll in the Program and in specified Merrill investment advisory programs receive the highest tier rate available under these programs. There is no interest rate tiering offered under the IBVRD Facility. The interest rate under this Facility will likely be lower than the highest rate available under the MLBD Program or RASP. In any event, the interest rate you earn in the bank deposit account affiliated with the Cash Sweep Program will likely be lower than yields on certain money market funds and other cash alternatives. Merrill receives compensation for administrative and other services from the money market funds available as an automatic sweep option for certain Retirement Accounts which we do not retain under applicable regulation. We rebate the compensation received from the fund managers of the sweep money market funds to clients of these Retirement Accounts. We address the conflicts of interests associated with the Cash Sweep Program and the deposit accounts in a variety of ways, including through disclosure in this Brochure, by requiring clients to affirm their interest for the Cash Sweep Program options in signed agreements, oversight and supervision of particular account type relationships and specific investment product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to your participation in the Cash Sweep Program. Merrill financial advisors do not receive any additional compensation for assets held in the Cash Sweep Program as opposed to another cash alternative product. We have adopted various policies and procedures reasonably designed to prevent the cash sweep arrangement compensation and other business arrangements from affecting the nature of the advice we and our financial advisors provide. Other Compensation Received by Us and Our Affiliates Separate and apart from the Program, Merrill, through its financial advisors, may suggest or recommend that you use the Merrill brokerage account and our execution and custody or other services for other of your investment activity or use the services of our Affiliates. Similarly, our financial advisors may suggest or recommend that you purchase our products or those of our Affiliates. Where you use or purchase our or our Affiliate’s products and services, we and our Affiliates will receive fees and compensation. There are conflicts of interest when Merrill, BofA Corp., BANA or an Affiliate act as an issuer, placement agent, underwriter, dealer selling group member or structurer or otherwise have a financial interest in a new issue offering of securities or other investments. Due to the compensation we and our Affiliates receive, there is a financial incentive to recommend these transactions to you. We address the conflicts of interest presented by these Affiliated transactions described below by calculating the compensation paid to our Advisors without regard to the amount of the compensation that we or our Affiliates receive from those transactions. In addition, we have adopted various policies and procedures reasonably designed to prevent the receipt of compensation by Merrill and its Affiliates and other business arrangements from affecting the nature of the advice we provide. New Issue Offerings. In the Program, certain eligible accounts can purchase certain types of securities including equities, debt and preferred securities, MLIs and closed-end funds, made available in new issue offerings. BofA Corp., BANA or one of our Affiliates may be an issuer of a security offered in a new issue offering. When we and/or BofAS participate in a new issue offering or are otherwise been engaged by the issuer as an underwriter, selling group member, placement agent or selling agent,, we and/or BofAS is compensated. For new issue closed-end fund offerings, in addition to underwriting compensation, the closed-end fund investment manager can pay Merrill a structuring fee that ranges from 0.50% to 2.00% of the new issue proceeds for advice relating to the structure, design and organization of the fund, as well as for services related to the sale and distribution of fund shares. You may be responsible for paying these fees for certain closed-end funds, in which case the amount and structure of such payments will be disclosed to you in the prospectus for the offering. Merrill can also receive additional compensation from certain investment managers for services the investment manager can request from us, such as after-market support services or information pertaining to industry trends. Merrill offers new issue brokered CDs of third-party banking institutions that are sourced from BofAS, our Affiliate. and from third-party broker-dealers. For distribution efforts relating to offerings of new issue brokered CDs, participating broker-dealers, including BofAS, are paid a placement fee negotiated with the CD-issuing bank that amounts to an annualized rate of between 0.02% to 0.30% of the principal amount of the brokered CD for each offering depending on tenor. For brokered CDs sourced from BofAS, the full placement fee is remitted by BofAS to us and the placement fee is then rebated in full to the Account. In such offering, neither BofAS nor Merrill retains any placement fee from the CD-issuing bank. As compensation to BofAS for its services in sourcing new issue brokered CDs to be made available for purchase in Program Accounts, Merrill pays BofAS an intercompany service fee. The issuers of new issue MLIs can be a third-party financial institutions or an Affiliate. The issuer is subject to due diligence reviews by Merrill and/or its Affiliate. For new issue offerings, BofAS acts as an underwriter and/or Merrill acts as a selling group member. Merrill and/or BofAS are compensated for these roles. In addition, the public offering price (which is the price you pay) for an MLI can include compensation to BofAS or Merrill for structuring the MLI. It can also include an estimated profit credited to our Affiliate from hedging arrangements by the issuer of the MLI, which reduces the economic terms of the MLI to you. The presence of these compensation arrangements associated with MLIs creates an incentive for an Advisor to recommend MLIs over other securities. Principal Trading and Agency Cross Transactions. Where permitted by regulation, Merrill may execute certain transactions on a principal basis through its Affiliates including BofAS. Transactions that are considered principal transactions include our new issue offerings where we or our Affiliates act as an underwriter, selling group member or placement agent. We may execute secondary transactions in fixed income securities on a principal basis where we or our Affiliates act as a dealer or as a remarketing agent. In addition, our Affiliates can act in a principal capacity under certain circumstances when we Investment Advisory Program Brochure | 52 IAPB-032025 execute transactions for your Account. In a trade executed in a principal capacity, our Affiliate acts as your trade counterparty and it can act as a market maker or remarketing agent for, or have a proprietary position in, the securities that are the subject of the transaction. We and our Affiliates receive compensation in connection with principal transactions, including mark-ups, mark-downs, dealer spreads, underwriting discounts, selling concessions, a remarketing fee and other compensation. We and our Affiliates can profit from transacting as your counterparty or having proprietary positions in the subject securities. Moreover, we have an incentive to recommend a transaction in a security that our Affiliate maintains in inventory that is otherwise difficult to sell. When executing sales of municipal securities in secondary market transactions, BofAS may seek bid prices from third-party dealers in a process known as a Bid Wanted in Competition (BWIC) and, if the third- party dealer has the highest bid price, BofAS charges a markdown in the form of a dealer spread for its services for acting as an intermediary in facilitating the transaction. It may itself submit bid prices for municipal securities in BWICs and also has the right to submit its bid last and match or improve upon the prices submitted by third-party dealers, consistent with obligations to provide best execution and fair and reasonable prices. If BofAS is the winning bidder, it will not charge the customer a dealer spread. In determining the winning bid for a municipal securities transaction, BofAS compares its own price (if it submitted a bid) against all prices received from third parties in BWICs on a net basis (i.e., by subtracting its expected dealer spread from third-party bid prices only). There may be situations where the third-party dealer submitted a bid in the BWIC that was higher than BofAS’ bid, but the third-party dealer did not win the BWIC because the BofAS’ dealer spread was deducted from their bid price in calculating the highest bid. These situations give rise to a conflict of interest because BofAS can profit if and when it resells the securities from its inventory. Other than transactions in a Retirement Account, Merrill may engage in agency cross transactions when it acts as agent for both buyer and seller in a transaction. If this type of trading execution occurs, since Merrill generally receives compensation from each party to an agency cross transaction, there is a conflict of interest between our obligations to you and to the other party to the transaction. Foreign Exchange. We may execute transactions in foreign currency (such as foreign currency conversions and wires) through our Affiliate. In addition to the fees we charge, the exchange rate for your transaction includes compensation to our Affiliate in the form of a dealer spread if the transaction is executed with our Affiliate. The fees that you pay to Merrill and our Affiliate for a foreign exchange transaction will be included in the price of the transaction. Other than for incoming wires, a portion of the fee you pay to Merrill is paid to your Advisor as compensation. VRDOs. For the VRDOs available for purchase at Merrill, generally BofAS acts as the remarketing agent and earns fees associated with this activity from the issuers, a portion of which is paid to Merrill. In addition, for certain VRDOs, one of our Bank Affiliates provides a letter of credit or other contractual source of liquidity enhancement to the issuer to cover its payment obligations under the terms of the of the VRDO. BofAS and, if applicable, our Bank Affiliate, receive fees for these services. The presence of these fee arrangements with issuers creates an incentive for Advisors to recommend VRDOs over other fixed income securities where no such fees are paid to us or our Affiliates. Annuities. During 2025, Merrill plans to use a set of digital tools provided by a third-party vendor to assist your Advisor in making annuity product recommendations (the Marketplace research tool), fulfilling training requirements and servicing Annuities post sale. Merrill will pay the external vendor for its use of the digital tools. Insurance companies that agree to participate in the third party vendor’s platform will make payments directly to the vendor based on Merrill sales of those insurance companies’ Annuities. These payments will reduce, eliminate, or even exceed Merrill’s contractual cost for the digital tools which will create a conflict of interest, insofar as sales of participating insurance companies’ Annuities benefit Merrill more than sales of non-participating insurance companies. Merrill will not directly receive these payments nor will Merrill require insurance companies to participate and make these payments. The Annuity products of insurance companies that choose not to participate and make payments to the third-party vendor will not be made available within the Marketplace research tool. The availability of the participating insurance companies within the Marketplace research tool and the indirect financial benefits to Merrill from sales of Annuities of participating insurance companies will create a conflict of interest for Advisors to recommend Annuities from participating insurance companies over those of non-participating insurance companies that are otherwise available on our platform. The Annuities documentation you receive when purchasing an Annuity will contain a list of participating insurance companies. Third-Party Firm Business Relationships and Support Business Relationships. We and our Affiliates have business relationships with Third-Party Firms. We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for funds and product vehicles managed or sponsored by them (i.e., mutual funds, closed-end funds, UITs, ETFs, hedge funds, non-traded real estate funds, private equity funds and portfolio companies in which private equity funds hold an interest). We also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to us or our Affiliates by a Third-Party Firm is additional compensation to us for services we and our Affiliates provide. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our financial advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our financial advisors do not have an incentive to recommend certain investment products, including Style Manager Strategies, PAS Style Manager Strategies and Funds, over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, we select Style Manager Strategies, PAS Style Manager Strategies and Funds that are available through the Program and other of our investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our financial advisors provide. Participation and Sponsorship by Third-Party Firms for Merrill Conferences, Manager Meetings and Charitable Events. Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (Conferences) for invited Merrill financial professionals. These financial professionals include financial advisors and members of their team, employees who work for a Merrill branch, market or division to support the Investment Advisory Program Brochure | 53 IAPB-032025 financial advisors (Field Management Employees) and employees who cover product, the CIO and home office support functions (Non-Field Employees). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third-Party Firms participate (Client Events). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending financial advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with a number of Conferences and Client Events in the amount of approximately $21 million. Certain Third-Party Firms periodically host or participate in meetings (Manager Meetings) where they provide certain financial advisors, Field Management Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending financial advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of charitable events and causes that we requested or initiated with the Third-Party Manager in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives for financial advisors to recommend products of participating Third-Party Firms. They give those financial advisors participating in Conferences, Client Meetings, Manager Meetings and charitable events with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for Field Management Employees to approve those recommendations and for non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our financial advisors to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Management Employees to approve their financial advisors’ recommendations of products and services of those participating Third-Party Firms. Furthermore, we do not incentivize Non-Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. Third-Party Firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs of Conference and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. Third-Party Firm Office Access and Gifts and Entertainment. Representatives of Third-Party Firms will, from time to time, meet and work with our financial advisors, Field Management Employees and Non-Field Employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third-Party Firms from providing or paying for, and our financial advisors, Field Employees and Non-Field Employees from receiving, gifts and entertainment (including meals) other than as permitted by and subject to the limits established under Merrill internal policies. In general, our financial advisors, Field Management Employees and Non-Field Employees may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. O U R I N T E R E S T I I Permitting Third-Party Firm representatives access to our financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. It can also create incentives for Field Management Employees to approve recommendations of a financial advisor, where required. Furthermore, providing gifts and entertainment to Non-Field Employees creates incentives to approve the investment products of the Third-Party Firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. I Participation or Interest in Client Transactions and Conflicts of Interest There are various ways that we can be viewed as participating or having an interest in client transactions. These situations and any conflicts of interest arising from such activities, execution approach or other capabilities we offer in the Program are discussed in this section and throughout this Brochure. N C E R T A N T R A N S A C T O N S Cash Balances and Cash Sweep Program The Sweep Program Guide for Merrill Clients provides information on the fees that Merrill receives from the Bank Affiliates for each account, including Program Accounts that sweeps to the MLBD Program, the RASP and the ISA Program. These fees are up to $100 per year for each account received from the Bank Affiliates and a fee of up to 2% per annum of the daily balances from the ISA banks. This compensation is subject to change from time to time, and Merrill may waive all or part of it. For TMA and certain eligible retirement accounts that have selected the money market fund automatic sweep option, the available sweep money market funds include a 0.40% asset-based administration fee per annum that is paid to Merrill. Merrill rebates the amount of the asset-based administration fee it receives to these clients. The amount of such rebate may be less than this 0.40% fee in certain rate environments where the fund manager waives or reduces the amount of such fee in order to avoid a negative return on the money market fund. Merrill may benefit from the possession or use of cash balances, also known as free credit balances, in your accounts, subject to restrictions imposed by Rule 15c3-3 under the Exchange Act. See “Compensation, Conflicts of Interest and Material Relationships—Cash Sweep Program Compensation Received by Us and Our Affiliates.” Investment Advisory Program Brochure | 54 IAPB-032025  Principal Trade Execution As a broker-dealer and a registered investment adviser, we execute certain transactions in your Account, where permitted by applicable law, on a principal basis. Transactions that we conduct on a principal basis include all new issue equity and debt securities offerings (including offerings of MLI) where we or our Affiliates act as an underwriter, selling group member or placement agent, secondary transactions in fixed income securities, and, where permitted by regulation, transactions involving fractional shares or lots. In addition, our Affiliates can act in a principal capacity under certain circumstances when we execute transactions for your Account. In a trade executed in a principal capacity, our Affiliate acts as your trade counterparty and it can act as a market maker or remarketing agent for, or have a proprietary position in, the securities that are the subject of the transaction. See “Compensation, Conflicts of Interest and Material Relationships—Other Compensation Received by Us and Our Affiliates-Principal Trading and Agency Cross Transactions.” When, under regulation, your consent is required for principal transactions to occur in your Account, we will only engage in principal transactions with you if you have signed the “Consent to Principal Transactions” form. By doing so, you will authorize and provide your initial written consent to allow us to execute transactions in your Personalized Strategy with Client Discretion Accounts on a principal basis as permitted by law. You have the right to refuse to provide this initial consent or may revoke this initial consent to principal transactions at any time, in writing, by requesting a revocation from your financial advisor. If you do not provide this consent, the inability to trade with us may limit the securities that are available to you and/or may limit your ability to sell securities that are held in the Account at competitive prices. It is important to note that when you have provided us with your consent to principal transactions, you still make all decisions concerning your Account, including whether we may effect a transaction as principal. When required, we will inform you (orally or otherwise) that we may execute a transaction on a principal basis and, at the time of the trade, you will have the opportunity to withhold your consent and may refuse to authorize your financial advisor to proceed with the transaction on a principal basis. Principal transactions may not be effected for Retirement Accounts except in accordance with applicable law. Internal Cross, Agency Cross and Other Cross Transactions In certain cases, if you make an unsolicited request to sell a security, we may, after agreeing on a price with the selling client, recommend the purchase of that security by another client or brokerage customer and execute both sale and purchase transactions simultaneously. Such a transaction involves conflicts of interest similar to those for principal transactions. In addition, this type of transaction involves a risk that the financial advisor has an incentive to recommend inappropriate trades in order to generate additional income or compensation or to unfairly favor one client over another. We address these additional conflicts by requiring that the initial sale be unsolicited, that the sale price be agreed upon before recommending the purchase by another client, following procedures intended to ensure that execution of the sale transaction is not unreasonably delayed, and by reducing the normal spread that Merrill would charge on the sale and purchase transactions. We may, at times, have the opportunity to act as agent for both buyer and seller in a transaction for your Account. This is called an agency cross transaction. Since we generally will receive compensation from each party to an agency cross transaction, there is a conflict between our responsibilities and loyalties to you and to the other party to the transaction. Any compensation we receive will be in addition to the Program Fee. The Agreement generally gives us permission to engage in agency- cross transactions for your Account, except where prohibited by law. You may revoke your consent to any agency-cross transaction at any time by notifying us in writing. At times, we may consider a security being sold by one investment advisory client to be appropriate for purchase by another investment advisory client account. In such cases, we may arrange to transfer or “cross” the security directly between the affected accounts. Any cross transactions in your Account would be effected in accordance with applicable law and your Agreement. Cross transactions generally will be effected at an independently determined market price and will not result in any additional compensation to us. Treatment and Allocation of Equity Initial Public Offerings Equity initial public offerings (excluding direct listing offerings) are not available to be purchased in the Program. We allocate investment opportunities in equity initial public offerings among eligible brokerage accounts in a manner we determine appropriate. Given the limited availability and size of these offerings and available allocations, there is a very limited opportunity for our brokerage clients to invest in such offerings and, if they do, clients generally will receive smaller allocations than they requested. Accordingly, clients should not have any expectation that they will have access to initial public offerings or that they will receive an allocation to any particular offering. There will be instances where certain accounts receive an allocation while other accounts (including similarly situated accounts) do not, and preferential allocations will be given to certain clients based on a number of different factors. In addition, financial advisors have the ability to choose not to offer participation in equity initial public offerings for any clients or they may offer participation to only a small group of clients. Order Flow, Order Routing and Rebates We do not receive payment for order flow from liquidity providers to which we route our customer orders in equity securities. We directly or indirectly (through our Affiliate) receive rebates from, and pay fees to, certain registered securities exchanges for providing or taking liquidity on those exchanges according to those exchanges’ published fee schedules filed with the SEC. In some cases, the rebates received by us from an exchange over a period of time will exceed the fees paid to the exchange. We directly or indirectly (through our Affiliate) also participate in the options order flow programs sponsored by options exchanges such as the NYSE American Options, NYSE Arca Options, and the Cboe options and Nasdaq options exchanges. These exchange- sponsored programs offer payments for listed option orders that are directed to such options markets. The rebates and payments from these third parties vary depending on the order and the exchange to which orders are directed and create a conflict of interest because we are incentivized to recommend transactions that provide us with greater rebates or payments from these exchanges. Participation in Affiliate Lending Programs and Margin There are conflicts of interest when we recommend that you use a loan secured by your Account assets as collateral. These conflicts exist with a margin loan from Merrill or with any of our Affiliate Lending Programs that may be available to you from an Affiliate lender. Specifically, in the case of a margin loan, we receive interest payments on the margin loan, and your Advisor receives compensation in the form of production credits based on a percentage of the loan revenue Merrill receives on the margin loans. Likewise, in the case of a loan from an Affiliate, including but not limited to the Loan Management Account® product (LMA® account), the Affiliate lender intends to derive a profit as lender based on interest and/or fees, if any, charged on the loan. Your Advisor receives compensation in the form of production credits based on a percentage of the loan revenue of the Affiliate lender for such loan. They receive greater compensation the more you borrow under a margin or Affiliate Lending Program and receive greater compensation if you are charged a higher interest rate. Investment Advisory Program Brochure | 55 IAPB-032025 The lender, whether it be Merrill, an Affiliate or a third-party lender, has a lien on your Account assets that are used as collateral for the loan. The lender will act to protect itself as lender in connection with the loan, and this may be contrary to your interests and/or investment objectives. Having a lien on your Account in connection with an Affiliate loan also creates a conflict of interest with respect to the recommendations we make to you. For example, your Advisor may recommend that you allocate your investments to your Account that has an Affiliate lender’s lien rather than to another Account without such lien or that you purchase a less risky investment in order to minimize the risk of loss with respect to the Affiliate lender’s collateral. Furthermore, since our Advisors are compensated based on a percentage of the loan revenue, this means your Advisor has a financial interest in your continuing the borrowing under the Affiliate Lending Program rather than recommending a liquidation of assets held in the Account to meet your funding needs, thus lowering the level of assets held in the Program and reducing the compensation earned. Please refer to the section “Investment Strategies and Risk of Loss” for additional information. Certain Program Strategies and investment strategies can involve the use of margin. Merrill will receive revenue in connection with any assets purchased in an Account on margin or other extensions of credit by us, which is in addition to, and does not reduce, the Program Fee. The additional economic benefit to us from the use of margin creates a conflict of interest. Provision of Diversified Financial Services BofA Corp. is a diversified financial services company that generally provides, through us and our Affiliates, a wide range of services to retail and institutional clients for which it receives compensation. As a result, we, BofA Corp. and our Affiliates can be expected to pursue additional business opportunities with the entities whose investments we and our financial advisors recommend or make available to you. Consistent with industry regulations, the services that we and our Affiliates provide include banking and lending services, sponsorship of deferred compensation and retirement plans, recordkeeping services, investment banking, securities research, institutional trading and prime brokerage services, custody services, investment advisory services, licensing arrangements involving indices, and effecting portfolio securities transactions for clients. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships is publicly available in Regulation NMS Rule 606 reports we file with the SEC. Activity by Merrill, Affiliates and Personnel As part of a global financial services firm, Merrill will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by Merrill or any of its Affiliates, it or its Affiliates’ roles in connection with other clients and in the capital markets, its internal policies, and/or potential reputational risk. As a result, client accounts managed by Merrill may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by BoA Corp. From time to time in the course of our and our Affiliates’ business dealings described in this Brochure, confidential information will be acquired that cannot be divulged or acted upon for advisory or other clients. See ”Conflicts of Interest and Information Walls” in this Item 9. We may give advice or take action with regard to certain clients, including clients in the Program, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken for certain securities, and for Fund managers, PAS Managers and Style Managers. In some instances, the actions taken by Affiliates for similar services and programs will conflict with the actions taken by us. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. In addition, potential conflicts of interest also exist when Merrill maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon Merrill or its Affiliates by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude the inclusion of particular securities or financial instruments in a client’s Portfolios where Merrill or its Advisors provide discretionary management services, even if the securities or financial instruments would otherwise meet the investment objectives of such portfolio. Merrill and its Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs by Merrill, its Affiliates and those of their clients that have granted discretion to Merrill, its Affiliates and/or Merrill Advisors (discretionary clients) to avoid potential restrictions on the ability of Merrill and its Affiliates to engage in principal trading and other transactions with such funds. Registered Funds identified by us for these limitations from time to time are referred to as “In-Scope Funds.” A portion of the aggregate ownership limit is attributed to our Affiliates. When Merrill and its Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to Merrill or its Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because Merrill’s and its Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest for Merrill in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. From time to time, a shareholder of BofA Corp. could acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Account, such as buying or selling securities issued by the shareholder or its Affiliates, will be limited. We and our Affiliates provide some or all of the same services offered in the Program through other financial firms, either with Affiliates or with firms that are unaffiliated. Certain of these services have fee rates that differ from that charged for the Program Services. We or one of our Affiliates have the right to hold a position in or enter into “proprietary” transactions in securities purchased or sold for clients, including clients participating in the Program. We or our Affiliates benefit from such securities positions or transactions. Our Affiliates and related business divisions, such as BANA, offer their own managed products or wrap programs that are similar to the Program or other Merrill programs and in some cases the same investment solutions are offered in the Program and in such other programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including as to recommendations and review determinations. This is due to, among other things, the differing nature of the Affiliate’s investment advisory services and differing processes and criteria upon which determinations are made. Investment Advisory Program Brochure | 56 IAPB-032025 The CIO releases information and analyses about CIO Covered Funds, Style Manager Strategies and PAS Style Manager Strategies covered under its CIO Review Process to Merrill, MAA, our Affiliates and financial advisors at the same time and BofA Global Research releases its research opinions and research reports to the public at the same time as Merrill, MAA and our Affiliates receive it. It is possible that our Affiliates and other investors act on that information before Merrill or MAA have had the chance to evaluate and act on those changes. Accounts that commence trading after the release of such information will be subject to price movements, particularly with large orders or where securities are thinly traded, that would cause them to receive prices that are less favorable than those obtained by Affiliates or other investors. We have entered into agreements with unaffiliated third-party investment managers that compensate us for referring clients with brokerage accounts to them. Any such referral is separate from the Program. A recommendation by your financial advisor for you to participate in such a separate third- party advisory arrangement creates a conflict of interest between you and us, including your financial advisor. The costs associated with the services provided by such firm, including any management fees paid to the unaffiliated third-party advisers or commissions paid to us in connection with the transactions are executed in an account outside the Program. We offer Style Manager Strategies and PAS Style Manager Strategies where Merrill, a Merrill Affiliate or a Related Entity construct or provide investment management and advisory services and charge a Manager Fee. If a Related Style Manager Strategy or Related PAS Style Manager Strategy is selected for your account where a Manager Fee is charged, we retain the Merrill Lynch Fee and the Related Entity will retain the Manager Fee attributable to the portion of assets in your Account attributable to the Related Style Manager Strategy (other than with respect to Retirement Accounts). Our employees, including Advisors and MFSAs, may refer clients to BANA, BofAS and other Affiliates for financial services that they provide, including transaction execution and investment banking services and products (including banking products). Similarly, employees of BANA, BofAS and other Affiliates may refer clients to us for brokerage and investment advisory services. These referrals may involve the payment of referral fees between us and BANA or its Affiliates. As permitted by applicable law, Advisors and MFSAs receive compensation for referring clients to our Affiliates, the amount of which varies by service and product and can be significant. Covered Entities under the Volcker Rule We may provide certain entity clients that qualify as “family wealth management vehicles,” or FWMV clients, with both the Program Services as well as lending services and engage, where permitted, in principal transactions. In doing so, we rely on the exception under the Volcker Rule implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Agreement. For certain entity clients that are deemed ”covered fund” clients under the Volcker Rule, we are not permitted to offer both Program Services and the availability of margin, lending or other extensions of credit from us or any of our Affiliates, including BANA, or engage in certain principal transactions. Certain other transactions between BANA or its Affiliates and the entity client will also be prohibited. Account Review and Reporting Periodic Reviews. An important part of the Program relationship involves providing you with the opportunity to engage in periodic reviews with your Advisor or a designated member of the team servicing your Portfolio or with your MFSA, as the case may be. These reviews provide updates on the progress of your Portfolio and other important information about your investments. A periodic review of your Account should typically occur on an annual basis; however, under our Program guidelines, both you and Merrill have the ability to extend or defer the timing of the review under certain circumstances and for certain periods of time. If you do not participate in a review within the timeframes we have established in our Program guidelines, we have the right to terminate an Account from the Program in our discretion. See “Item 4 Portfolio Reviews, Program Reports and Information.” Program Reports and Updates. We will periodically communicate to you important information about your Accounts and assets in the Program. The primary means through which we will communicate with you and memorialize in writing the important terms, conditions and information about your Portfolios, Accounts and Strategies is through a Program Report. You will receive your first Program Report from us after we accept your enrollment in the Program. We will provide a Program Report update or notice where you make certain important changes to the Program Services you elect, including where (1) Accounts are added to the Program; (2) a Portfolio Group is created or Accounts are added to or removed from an existing Portfolio Group; (3) a Program Strategy type for the Account is changed; (4) a Style Manager Strategy or a PAS Style Manager Strategy is changed; (5) the Target Asset Allocation for your Portfolio is changed; and (6) the Merrill Lynch Fee Rate for an Account is changed or a Manager Rate is changed, in each case, other than as a result of your qualifying for a different rate based on an applicable rate schedule. You should review each Program Report we send to you carefully to ensure that the information reflected therein is accurate and you should contact your Advisor or MFSA, as the case may be, if you believe any of the information is, or becomes, inaccurate. In addition to the Program Report, we will send you periodic updates that contain information about your Portfolios and Accounts, including trade confirmation information and account statements. We will also provide you with periodic performance reports to help you monitor and assess the performance of your Portfolios, Accounts and the Program Strategies you select. These reports contain information regarding investment return, risk and selected benchmark comparisons for your assets in each Strategy you select. select. If you have selected a PAS Style Manager Strategy, you may also receive reports concerning the Portfolio directly from the PAS Manager in accordance with the terms of the agreement separately entered into between you and the selected PAS Manager. Inclusion of other Accounts in the Program Report. The Program Report may include your single and jointly held accounts as well as accounts that you and other persons agree to be included in the Program Report. We reserve the right to change the format, content and nature of the presentation of information in the Program Report in our sole discretion. The Program Report or other Program communications, including those prepared or delivered in a digital or electronic format, may also include information about your accounts that are not subject to the Agreement, including, in our discretion, your brokerage accounts, other investment advisory program accounts and banking relationships and accounts held at other financial institutions. Their inclusion in a Program Report or other materials is provided for your information only and does not change the nature of our obligations to you under agreements related to those accounts and relationships. The Program Fee will not apply to these accounts or relationships, and we will not provide fiduciary advice and services with respect to the assets in such accounts solely by virtue of their inclusion in a Program Report or other materials we provide. Any such included accounts will continue to be subject to the terms and conditions of the applicable securities or other account agreements. Any advice that we may provide to you with respect to the assets in such accounts, including asset allocation advice, will be incidental to the services that we provide to you under the other applicable securities or other account agreements. Investment Advisory Program Brochure | 57 IAPB-032025 Referral Arrangements Our financial advisors are not permitted to give to you or accept from you any fee, kickback, or other thing of value, including a Merrill Lynch Fee Rate reduction, gifts, meals, or entertainment pursuant to any agreement or understanding, oral or otherwise, for receiving or referring business. We have entered into solicitation arrangements with certain third-party entities to refer prospective clients to us for the Program (Solicitors). Generally, the fees paid to Solicitors will be a percentage of the investment advisory fee ordinarily credited to your financial advisor for the applicable Account. We will pay this fee to the Solicitor from the date you establish an Account in the Program for as long as your Account remains enrolled in the Program and the agreement between us and the Solicitor is effective. If we terminate the agreement with the Solicitor for certain reasons, we continue to pay the Solicitor for a period of time after termination. We will not increase the fees you pay as a result of our payments to the Solicitor. Our employees may refer advisory clients to BANA, BofAS and our other Affiliates for products and services and, similarly, employees of BANA, BofAS and our other Affiliates may refer clients to us for brokerage and investment advisory services. See “Participation or Interest in Client Transactions and Conflicts of Interest—Activity by Merrill, Affiliates and Personnel.” We may enter into marketing arrangements with third parties who, for compensation, provide consulting or other services to us in connection with the marketing of our various advisory programs. Any such marketing arrangement will be governed by a written agreement between us and the applicable third-party and disclosed to you as required by law. Financial Information Not applicable because (1) Merrill is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act (2) Merrill and MAA do not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (3) there is no financial condition of which we are aware that is reasonably likely to impair Merrill or MAA’s ability to meet contractual commitments to its clients; and (4) Merrill or MAA each has not been the subject of a bankruptcy petition at any time during the past 10 years. Investment Advisory Program Brochure | 58 IAPB-032025 Glossary PAS Manager means an investment manager who provides discretionary managed strategies and related investment advisory and trading services under a dual contract arrangement. PAS Manager Fee means the fee charged by the PAS Manager for a PAS Style Manager Strategy. PAS Manager Rate means a specified flat rate or a rate determined by an agreed-upon fee rate schedule between you and a PAS Manager. PAS Style Manager Strategy means the investment strategies offered by a PAS Manager under a separate agreement entered into directly by the client with the PAS Manager. Program means the Merrill Lynch Investment Advisory Program. Program Fee means for each Account. the sum of (1) the Merrill Lynch Fee and (2 as applicable, the Style Manager Fee or PAS Manager Fee for the Style Manager Strategy or PAS Style Manager Strategy selected for your Account. Program Services means the range of investment advisory and financial services and investment solutions described in this Brochure that are available and/or provided under the Program. Program Report means a periodic communication sent to you that contains important terms, conditions and information about your Portfolios, Accounts and Strategies. Program Strategy means one or more investment styles or disciplines available in the Program, which include Managed Strategy, Custom Managed Strategy, Premium Access Strategy, Defined Strategy, Personalized Strategy with Advisor Discretion and Personalized Strategy with Client Discretion. RASP means the Retirement Asset Savings Program. Registered Fund means any Fund registered under the Investment Company Act of 1940. Related Entity means an Affiliate of Bank of America Corporation (BofA Corp.) or an entity in which BofA Corp. or an Affiliate has a material ownership interest. Related Style Manager Strategy and Related PAS Style Manager Strategy means any investment strategy sponsored, managed, or constructed by Merrill, MAA, any of our Affiliates or a Related Entity. Related Style Manager means any investment manager that is Merrill, MAA, an Affiliate of Merrill or a Related Entity. Retirement Account means an ERISA Plan, a U.S. tax-qualified plan of self- employed persons, a U.S. individual retirement account, or any other plan, arrangement or entity subject to Section 4975 of the Code. Rule 12b-1 fees means fees paid for the distribution of mutual funds pursuant to a plan made under Rule 12b-1 under the Investment Company Act of 1940. Style Manager means an investment manager of a Style Manager Strategy and which can be Merrill, its Affiliate, a Related Entity or a third-party manager, Style Manager Fee means the fee charged by a Style Manager for the investment in a Style Manager Strategy it constructs and/or manages. Style Manager Strategy means an investment strategy that is constructed and/or managed by a Style Manager that includes specific asset classes or asset types such as securities, Funds, and other Style Manager Strategies or a combination thereof. Target Asset Allocation means a recommended allocation of assets in a Portfolio across one or more asset classes in the following categories: (1) Conservative (where the primary focus is on Portfolio stability and preservation of capital with the achievement of low or negative investment returns in exchange for reduced risk of loss of principal and liquidity); (2) Moderately Conservative (where the primary focus is to achieve a modest level of Portfolio appreciation with minimal principal loss and volatility); (3) Moderate (where the primary emphasis is to strike a balance between Portfolio stability and Portfolio appreciation with the assumption of a moderate level of risk and level of volatility and principal loss); (4) Moderately Aggressive (where the primary emphasis is on achieving Portfolio appreciation over time with the assumption of a fair amount of risk, and high level of volatility and risk of principal loss; (5) Aggressive (where the primary emphasis is on achieving above-average Portfolio appreciation over time with the assumption of substantial risk and a significant level of Portfolio volatility); (6) Equity-Focused (where the primary focus is to hold equity securities with the assumption of a significant amount of Portfolio volatility and risk of principal loss); (7) Fixed Income-Focused (where the primary focus is to hold fixed income securities with the assumption of investment returns that are low or, in some years, negative, in exchange for reduced risk of principal loss) (8) Alternative Investment-Focused (where the primary focus is to hold Alternative Investments with the assumption by a client of a significant amount of Portfolio volatility and risk of principal loss; and (9) Custom (where the allocations are agreed with the client as applicable to their Portfolio. Third-Party Firms means third-party investment managers, fund managers (including for Alternative Investments), product distributors and sponsors, insurance companies and other product providers. Unaffiliated Trade Counterparty means a bank, broker or dealer other than Merrill or a Merrill Affiliate. Unrelated Custodian means a custodian other than Merrill or a Merrill Affiliate. Account means each of the securities accounts to which the Agreement applies and that are enrolled in the Program as set forth in the Program Report. Advisers Act means the Investment Advisers Act of 1940, as amended. Advisor means a Merrill financial advisor who offers the full complement of Program Services subject to meeting certain training and experience requirements. Affiliate means a company that is controlled by, in control of, or under common control with another company. Affiliated Custodian means a custodian that is an Affiliate of Merrill. AI Advisory Units means a class, tranche or series of interests, units or shares in an Alternative Investment Fund that is available for purchase by persons investing through an Account or interests in a separate Alternative Investment Fund that has been structured specifically for clients purchasing through an Account. Alternative Investment means an investment so designated by us from time to time in our sole discretion with risk and return characteristics not generally correlated with more traditional investments (i.e., equities, fixed income and cash). Alternative Investment Fund means a Fund (other than an NTF) that we designate as in the Alternative Investment asset category, including a hedge fund, private equity fund, managed futures fund, non-traded business development company, non-traded real estate fund, real asset fund, commodity pool, interval fund, and any other Fund that invests in alternative asset classes or other Funds that invest in whole or in part in any of the foregoing types of Funds. Annual asset-based fees with respect to mutual funds means any service fees or Rule 12b-1 fees paid to Merrill for the distribution of mutual funds pursuant to a plan made under Rule 12b-1 under the Investment Company Act of 1940. Annuity means an insurance product, including a variable annuity, a variable indexed annuity and a fixed income annuity, that through a legal contract with an Annuity Issuer can offer owners guaranteed lifetime income, tax-deferred accumulation potential and downside protection for owners or their beneficiaries. Authority means the authority to make certain investment and/or trading decisions relating to the assets in an Account. BANA means the Bank of America, N.A. BofA Corp. means Bank of America Corporation, the parent company of MLPF&S, MAA and other Affiliates. BofAS means BofA Securities, Inc., a Merrill Affiliate. Bank Affiliate means BANA or other banks that are affiliated with us. Cash Sweep Program means the program provided as part of your brokerage account agreement whereby cash balances in your Account are automatically swept into a cash sweep option available for your Account type. CIO means the Chief Investment Office of MLPF&S. For certain managed strategies, CIO refers to the Chief Investment Office of BANA. dealer spread charges means mark-ups, mark-downs and/or dealer spread charges imposed by an Unaffiliated Trade Counterparty or a trade counterparty that is an Affiliate. Direct Indexing/TEM strategy means a managed strategy offered by a Style Manager or a PAS Manager that incudes as part of its portfolio management approach investing in a selected market index and engaging in opportunistic selling of securities with a loss and investing proceeds in strategy-aligned replacement securities. Discretionary Manager means a Style Manager that has investment discretion and full or partial discretion to trade for your Account with us, our Affiliates or an Unaffiliated Trade Counterparty. FDIC means the Federal Deposit Insurance Corporation. financial advisor means an Advisor and an MFSA. Fund means a registered and unregistered investment company, including a mutual fund, ETF, money market fund, Offshore Fund, closed-end fund, Alternative Investment Fund, NTF and any other pooled investment vehicle. Household means you and/or certain eligible persons in your designated household at Merrill and its Affiliates as determined by us by us in accordance with our polices. Household value means the value of certain assets and liabilities determined by us in accordance with our policies that are held by you and/or your Household. Manager Fee means either the Style Manager Fee and/or the PAS Manager Fee. Manager-Related Fund means a Fund that is sponsored or advised by a Style Manager or PAS Manager (or their respective Affiliates). MLBD Program means the Merrill Lynch Bank Deposit Program. MFSA means a financial advisor with the designation of Merrill Financial Solutions Advisor who, under our internal polices, offers clients access to a subset of Style Manager Strategies. NTFs means non-traditional mutual funds and ETFs registered with the SEC that are classified as by us as Alternative Investments. Offshore Fund means a Fund that is not organized within the U.S., is not registered under the Investment Company Act of 1940 and the securities of which are not SEC-registered. L-03-25 Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. ©2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated. Printed in the U.S.A. Investment Advisory Program Brochure | 59 IAPB-032025

Merrill Personal Retirement Strategy BROCHURE Please retain for your records. Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 (800) 637-7455 (Main) (866) 731-3127 (Program) www.ml.com (Main) www.benefits.ml.com (Program) This Brochure provides information about the qualifications and business practices of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“Merrill” or “MLPF&S”) relating to Merrill Personal Retirement Strategy, an online investment advisory program. If you have any questions about the contents of this Brochure, please contact us at (866) 731-3127. Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Investment adviser registration does not imply a certain level of skill or training. Additional information about MLPF&S also is available on the SEC’s Website at www.adviserinfo.sec.gov/. The investment advisory services described in this Brochure are not insured by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency, are not a deposit or other obligation of or guaranteed by MLPF&S, Bank of America Corporation (“BofA Corp.”) or any of its Affiliates; and are subject to investment risks, including possible loss of principal. March 21, 2025 Workplace Benefits is the institutional retirement and benefits business of Bank of America Corporation (“BofA Corp.”) operating under the name “Bank of America.” Investment advisory and brokerage services are provided by wholly owned non-bank affiliates of BofA Corp., including Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as "MLPF&S" or "Merrill"), a dually registered broker-dealer and investment adviser and Member SIPC. Banking activities may be performed by wholly owned banking affiliates of BofA Corp., including Bank of America, N.A., Member FDIC. Investment products: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value  MATERIAL CHANGES On March 22, 2024, MLPF&S filed its last annual update for its Merrill Personal Retirement Strategy brochure (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS ANNUAL UPDATE • We updated the “Disciplinary Information” section to add as follows: “On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000.” • We updated the information relating to Third-Party Firms’ providing gifts and entertainment to our Financial Advisors, Field Management Employees and Non-Field Employees to provide that they may provide nominal gifts and occasional entertainment events, including dinners, subject to certain limits and conditions designed for regulatory requirements relating to the receipt of non- cash compensation and to state explicitly that we do not permit any gifts or entertainment conditioned on achieving a sales target. Please refer to CLIENT REFERRALS AND OTHER COMPENSATION - Third-Party Firm Office Access, Gifts, And Entertainment. MATERIAL CHANGES AND ENHANCED DISCLOSURES MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2024: October 18, 2024 Brochure Update Material Changes • We updated the “Disciplinary Information” section to add as follows: “On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third-party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000.” i  May 17, 2024 Brochure Update Material Changes and Enhancements • We enhanced the Goal Funding Status services available to you in the Program. With this enhancement you can receive a suggested contribution amount in the plan and a suggested contribution amount to financial accounts external to your Plan account that you have provided information about that you are using to fund your retirement goal, if you chose to include it in the analysis. We updated the Brochure to provide information on this capability and enhance the Conflicts of Interest and External Assets disclosures. Please refer to DETAILED DESCRIPTION OF SERVICES – Goal Funding Status Analysis, METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS – Investment Philosophy and CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING – Participation or Interest in Client Transactions and Conflicts of Interest. ii  TABLE OF CONTENTS MATERIAL CHANGES .......................................................................................................................................... I ADVISORY BUSINESS ......................................................................................................................................... 1 ABOUT US AND THE PROGRAM OUR SERVICES AS AN INVESTMENT ADVISER AND RELATIONSHIP WITH YOU UNDER THE PROGRAM DESCRIPTION OF PROGRAM SERVICES DETAILED DESCRIPTION OF SERVICES Goal Funding Status Analysis Retirement Income Planning Retirement Tax Illustration Asset Allocation Recommendation Merrill Managed Separation from Service from your Employer Investment and Trading Authority Termination of Program Services Electronic Accessibility Requirement Other Merrill Advisory Services Assets Under Management ............................................................................................................................ 1 ................ 1 ................................................................................................................. 2 ................................................................................................................... 2 ........................................................................................................................... 2 ............................................................................................................................ 3 ............................................................................................................................... 3 ................................................................................................................... 4 .............................................................................................................................................. 4 ................................................................................................... 5 ................................................................................................................... 6 ..................................................................................................................... 6 ................................................................................................................ 6 ........................................................................................................................ 6 .............................................................................................................................. 7 FEES AND COMPENSATION ............................................................................................................................... 7 MERRILL MANAGED FEES CALCULATION OF THE MERRILL MANAGED FEE Plan Sponsor: Participant: BILLING UPON TERMINATION OF MERRILL MANAGED PAYMENT OF MERRILL MANAGED FEE Plan Sponsors Participants OTHER FEES AND EXPENSES COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS SOURCES OF REVENUE ..................................................................................................................................... 7 ................................................................................................... 7 .................................................................................................................................................... 7 ....................................................................................................................................................... 8 ........................................................................................ 8 ................................................................................................................. 8 ................................................................................................................................................... 8 ...................................................................................................................................................... 8 ................................................................................................................................. 8 .......................................... 8 ......................................................................................................................................... 9 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................................................................... 9 TYPES OF CLIENTS ............................................................................................................................................. 9 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................................ 9 INVESTMENT PHILOSOPHY CHIEF INVESTMENT OFFICE’S GOVERNANCE KEY DATA SOURCES KEY ASSUMPTIONS Social Security Retirement Benefits Salary Growth Retirement Age Estimated Tax Inflation Assumptions IRS Limitations and Application of Penalties Contribution Rates Brokerage Account ...................................................................................................... ............................................................................................................................................ ............................................................................................................................................. ................................................................................................................ ................................................................................................................................................. ............................................................................................................................................... ................................................................................................................................................. ..................................................................................................................................... .................................................................................................. .......................................................................................................................................... ......................................................................................................................................... ................................................................................................................................... 9 10 10 11 11 11 11 12 12 12 12 12  External Assets Asset Class Index Proxy Restricted Assets RISK OF LOSS AND STRATEGY RISK General Risks Associated with Investments Strategy Risk ............................................................................................................................................... ...................................................................................................................................................... ..................................................................................................................................................... ............................................................................................................................................ ...................................................................................................................... ................................................................................................... ................................................................................................................................................... ............................................................................................................. 12 13 13 13 13 13 14 15 HYPOTHETICAL NATURE OF FORECASTS PERSONAL RETIREMENT STRATEGY AND MERRILL MANAGED ADVICE AND INVESTMENT RECOMMENDATIONS ............................................................................................................................................................................ 15 ............................................................. 15 CAPITAL MARKET ASSUMPTIONS AND STRATEGIC ASSET ALLOCATION ........................................... 16 EMPLOYER SECURITIY RESTRICTIONS AND OTHER FUND HOLDING RESTRICTIONS ........................................................................................................ 17 INFORMATION AND CYBERSECURITY RISKS DISCIPLINARY INFORMATION ......................................................................................................................... 18 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................................................................... 20 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ........... 21 CONFLICTS OF INTEREST AND INFORMATION WALLS CODE OF ETHICS PRIVACY/DATA PROTECTION PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS INVESTMENTS IN SECURITIES BY MERRILL AND OUR PERSONNEL ........................................................................................ ................................................................................................................................................. .............................................................................................................................. ................................................................................... ...................................................................... 21 21 21 22 24 BROKERAGE PRACTICES .................................................................................................................................. 24 REVIEW OF ACCOUNTS ................................................................................................................................... 25 CLIENT REFERRALS AND OTHER COMPENSATION ........................................................................................... 25 ....................................................................................................... 25 RELATIONSHIPS WITH THIRD-PARTY FIRMS PARTICIPATION AND SPONSORSHIP BY THIRD-PARTY FIRMS FOR MERRILL CONFERENCES, MANAGER MEETINGS AND CHARITABLE EVENTS THIRD-PARTY FIRM OFFICE ACCESS, GIFTS, AND ENTERTAINMENT PROVISION OF DIVERSIFIED FINANCIAL SERVICES BY US AND OUR AFFILIATES . ................................................................................................................ ................................................................... .................................................. 26 27 28 CUSTODY ........................................................................................................................................................ 28 INVESTMENT DISCRETION .............................................................................................................................. 28 VOTING CLIENT SECURITIES ............................................................................................................................ 28 FINANCIAL INFORMATION .............................................................................................................................. 28 GLOSSARY ....................................................................................................................................................... 28 All capitalized terms used in the Brochure are defined in the body of this Brochure and/or in the Glossary. i  ADVISORY BUSINESS ABOUT US AND THE PROGRAM Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or “Merrill”), an indirect wholly-owned subsidiary of Bank of America Corporation “BofA Corp.”), is a global financial services firm that offers a broad range of brokerage, investment advisory, retail and other services. Merrill is registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer and has been registered as an investment adviser since 1978. Investment advisory and brokerage services are separate and distinct and each is governed by different laws and separate contractual arrangements that we may have with you. Our relationship, legal duties and capacities to you under federal securities laws are subject to a number of important differences. It is important to understand the differences, particularly when determining which service or services to select. You can review a general description of these programs in the “Summary of Programs and Services” at ml.com/relationships. Merrill offers investment advisory services under the Merrill Personal Retirement Strategy program (“Personal Retirement Strategy” or the “Program”) as discussed in this Brochure. For purposes of this Brochure, the following terms have the following meanings: (i) “MLPF&S”, “we”, “our” or “us” refers to Merrill; (ii) “participant”, “their”, “you” or “your” refers to the Plan participant; (iii) “Plan” refers to the participant-directed defined contribution plan maintained by the Plan Sponsor, or as applicable, the designee or other named fiduciaries of the Plan Sponsor (“Plan Sponsor”) utilizing Merrill’s recordkeeping platform and enumerated in the Master Services Agreement between the Plan Sponsor and Merrill (the “Master Services Agreement”); and (iv) “Employer” refers to the employer of the participant. All capitalized terms are defined in the body of this Brochure and/or in the Glossary which can be found at the end of this Brochure. Personal Retirement Strategy is an online investment advisory program available to participants of Plans that also utilize Merrill for recordkeeping services. OUR SERVICES AS AN INVESTMENT ADVISER AND RELATIONSHIP WITH YOU UNDER THE PROGRAM Merrill provides services to Plan participants under the Program in its capacity as a registered investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”) and a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The fiduciary standards we follow are established under the Advisers Act and ERISA. In Personal Retirement Strategy, Merrill acknowledges and agrees to be an ERISA Fiduciary, to the extent that it renders investment advice within the meaning of section 3(21)(A)(ii) of ERISA. When providing discretionary services in this Program through Merrill Managed, Merrill acknowledges that it is acting as an investment manager within the meaning of Section 3(38) of ERISA. A Plan Sponsor must enter into an amendment to the Master Services Agreement to make Personal Retirement Strategy available to Plan participants (the “Plan Sponsor Amendment”). You must enter into an investment advisory agreement with us (or will be provided information regarding the terms of that agreement where a Plan Sponsor uses Merrill Managed (defined below) as a qualified default investment alternative) (the “Participant Advisory Agreement”) that describes our obligations to you under the Program and expressly acknowledges that we act as a fiduciary under the Program and, with respect to Merrill Managed, you appoint us as a discretionary investment manager within the meaning of Section 3(38) of ERISA. The scope of our investment advisory relationship is defined in the Participant Advisory 1  Agreement. Termination of your Participant Advisory Agreement will end that investment advisory fiduciary relationship. Under the Program, we are a fiduciary to the participant. Merrill has certain fiduciary obligations in providing services under the Program. As a fiduciary, we will act in your best interest and will endeavor to ensure that you are informed about and have access to material facts and information relating to services provided through the Program and described in this Brochure. The Brochure is a key element in meeting this disclosure obligation. This Brochure describes the advisory services that we provide, any fees that are charged for those services, our role and that of our personnel, our other business activities and financial industry affiliations and the economic and other benefits and arrangements we have that create conflicts of interest in certain situations. DESCRIPTION OF PROGRAM SERVICES The Program is designed to help you establish and pursue your retirement income goals by providing you with tools, investment guidance and advice and access to investment management services delivered through the Program’s interactive Website at www.benefits.ml.com (the “Program Website”) and as described in this Brochure (“Services”). Before accessing the Services, please read the description of our Services and the other information in this Brochure and contact us at (866) 731-3127 if you have any questions. Personal Retirement Strategy will utilize data received from the Plan Sponsor and from you, if provided, to provide Services. Data used will include, but is not limited to, the participant’s Plan account balance and contribution rate, salary, account balance(s) and anticipated savings outside of the Plan, retirement age, and desired retirement income. If the neither the participant nor the Plan Sponsor provides the required compensation and indicative data, Personal Retirement Strategy will not be able to provide you with advice and guidance, and you will not be able to enroll into Merrill Managed. The Program Website allows you to provide information about certain other assets held outside the Plan. We also ask you questions to gather information about you. We incorporate the personal and financial information you have provided into the guidance and advice we provide under the Program, as described in this Brochure. It is your responsibility to ensure that the information you provide to us is complete and accurate. When you provide accurate and complete information, we are better able to make appropriate recommendations in this Program. It is also your responsibility to notify us if any information you have provided to us is inaccurate, becomes inaccurate or is incomplete. The Program provides investment advice and guidance through the following: • Goal Funding Status Analysis • Retirement Income Planning • Retirement Tax Illustration • Asset Allocation Recommendation • Merrill Managed DETAILED DESCRIPTION OF SERVICES Goal Funding Status Analysis Merrill will provide information and tools to assist you in determining 1) an annual retirement income goal, 2) your progress to accumulate sufficient total assets to achieve that annual retirement income goal 2  (the “Goal Funding Status”), 3) a suggested contribution amount to your Plan account, 4) a suggested contribution amount to financial accounts external to your Plan account (External Accounts) that you have elected to provide information about that you are using to fund your retirement goal (such as IRA, Roth IRA, taxable brokerage accounts, and savings accounts) and 5) steps you can take that are designed to improve your Goal Funding Status. Personal Retirement Strategy will use a default retirement income goal of achieving 85% of your projected salary at your target retirement age and in each of your years in retirement (calculated based on your life expectancy or as provided by you). Your projected salary is your current salary adjusted for inflation. The Program Website provides you with the ability to customize the annual retirement income goal to either a different percentage of your projected salary or a target dollar amount, expressed in today’s dollars. Additionally, you’ll have the ability to see how changes to variables such as savings rate, retirement age, retirement income goal, household information, income and expenses in retirement, Social Security payments, additional accounts and more may affect your Goal Funding Status. Any suggestion to make a contribution to your Plan account and if provided, other financial accounts external to your Plan account, and general educational information for additional savings approaches are point in time recommendations designed to help you make your decisions for retirement based on the provided information at the time. The actual decisions you make related to the suggestion are not monitored or reviewed or updated on an ongoing basis. However, you can return at any time to engage with the goal funding analysis tool and receive additional point in time recommendations. Federal tax laws may limit the contribution rates in the Plan of some participants who are defined as “Highly Compensated Employees,” by the Internal Revenue Code. A majority of Plans utilizing Personal Retirement Strategy have implemented controls that will not allow Highly Compensated Employees to over contribute to the Plan. However, some Plans do not utilize these controls, which may cause Highly Compensated Employees to receive refunds of excess contributions. Participants defined as Highly Compensated Employees should adjust their contribution rate in the Plan to avoid such refunds. (see “Methods of Analysis, Investment Strategies and Risk of Loss” section below for further information, including information with respect to important assumptions and limitations used in this analysis). Retirement Income Planning Merrill will provide you with a suggested withdrawal strategy to help you prioritize the available accounts or other sources from which to take income in retirement. The withdrawal strategy can include both assets inside the Plan, and assets external to the Plan, such as IRA, Roth IRA, taxable brokerage accounts, and savings accounts. Income sources such as Social Security, pensions, and self-employment income can be added for inclusion in the strategy. The withdrawal strategy takes into consideration the various account types available to you to fund your retirement, and required minimum distributions. Through the Program Website, you can access educational materials and run hypothetical Social Security scenarios to assist you in managing your total savings throughout retirement. The withdrawal strategy is illustrative and informational based upon current tax code and Social Security tables (see “Methods of Analysis, Investment Strategies and Risk of Loss” section below for further information, including information with respect to important assumptions and limitations used as part of the planning). Retirement Tax Illustration Merrill will provide you with information on the potential tax impact on your future retirement savings. If your plan offers a Roth 401(k), the tool will provide insight into the impact of your choice between standard and Roth contributions by automatically updating and displaying the impact of your choice. If your Plan does not offer a Roth 401(k), the tool will provide insights on other account types which may offer tax benefits for consideration. (see “Methods of Analysis, Investment Strategies and Risk of Loss” 3  section below for further information, including information with respect to important assumptions and limitations used as part of the planning). Asset Allocation Recommendation Based upon data the Plan Sponsor provides Merrill in recordkeeping the Plan (your date of birth, salary, current contribution rate, and current Plan account balance and allocations) as well as any additional information that you provide, we will provide you with a recommended asset allocation for your Plan assets to help you meet your annual retirement income goal. If the Plan Sponsor does not provide salary information you will be required to provide your salary in order to receive the asset allocation recommendation. The asset allocation recommendation will consider your defined contribution account, any other accounts that you have identified to help fund your retirement goal, any restrictions you may impose on your Plan assets (or that may be imposed by the Employer), Plan assets that may be held in a self-directed brokerage account and other information we have from you or your Plan Sponsor. The asset allocation recommendation is based on the same goals-based asset allocation that is used in Merrill Managed (see “Methods of Analysis, Investment Strategies and Risk of Loss” section below for further information, including information with respect to important assumptions and limitations used as part of the recommendation). It is your responsibility to ensure that the information you provide to us is complete, up to date and accurate so that we will be better able to make appropriate asset allocation recommendations for you and your Plan assets. This asset allocation recommendation is a point-in-time recommendation designed to help you make your investment allocation decisions for your Plan assets. The actual investment decisions you make are not monitored or reviewed, and your Plan assets are not monitored, reviewed or updated on an ongoing basis. However, you can return at any time to receive an asset allocation recommendation. Merrill Managed Merrill Managed is a discretionary managed account service within Personal Retirement Strategy. In Merrill Managed, Merrill acts as a fiduciary investment adviser under the Advisers Act and an investment manager within the meaning of Section 3(38) of ERISA with respect to those Plan assets (other than any Restricted Assets as defined in the Glossary) included in Merrill Managed. Through Merrill Managed, we exercise discretion to construct a portfolio for your Plan account utilizing the Plan Sponsor’s Defined Contribution Plan investment menu, based on data from you (including information regarding any assets outside the Plan) and the Plan Sponsor and taking into account any restrictions you (or your Employer) may impose. Merrill Managed uses goals-based asset allocation to select the most efficient asset allocation to invest your Plan assets with a 75% probability of achieving your Goal Funding Status. Using certain information about you, the Merrill Managed goals-based asset allocation uses a probabilistic approach to invest your Plan assets in a manner that is appropriate to provide for future cash flows with the least amount of risk. This approach is designed for an investor with a medium risk tolerance who is willing and able to take some risk to achieve his or her goal. You will not have the ability to designate low or high-risk tolerance as an input to achieve your Goal Funding Status. However, if your Goal Funding Status is 100% or more, we will invest any of your excess Plan assets to an asset allocation that factors in risk tolerance based on your completed risk profile questionnaire or, if you have not completed this questionnaire, to an asset allocation with a medium risk tolerance. While enrolled in Merrill Managed, we provide investment management of your Plan assets (other than Restricted Assets as defined in the Glossary) by reviewing your investments approximately every 90 days based on the date of your birth. At this frequency, we will review your asset allocation and investments, additional or modified information your Plan Sponsor or you have provided and any other changes you 4  may have made that impact your Goal Funding Status, and we will reallocate your Plan assets and rebalance your Plan account as appropriate to help meet your annual retirement income goal. Should there be other factors that impact the rebalance, rebalancing will occur once those factors are resolved. For more information, please see the “Review of Accounts” section below. If you choose to enroll in Merrill Managed, you will have the option to restrict or limit the sale of certain securities or current holdings by excluding them from Merrill Managed as Restricted Assets. Your Plan Sponsor may also require certain employer securities to be excluded from Merrill Managed as Restricted Assets. The Restricted Assets will be taken into account for purposes of your overall asset allocation, however, they will not be included in the discretionary managed account portion of your Plan. If you or your Plan Sponsor choose to restrict the sale of certain holdings by excluding them from Merrill Managed as Restricted Assets, Merrill does not and will not act in a fiduciary capacity under ERISA or the Advisers Act (or otherwise) with respect to the decision to maintain those investments. Some Plans allow participants to maintain a self-directed brokerage account within the Plan. If your Plan allows this option, you will be responsible for managing any assets included in your self-directed brokerage account and these assets also will be considered Restricted Assets. Merrill does not and will not act in a fiduciary capacity under ERISA or the Advisers Act (or otherwise) with respect to Restricted Assets. Merrill Managed will consider these holdings as described in the “Methods of Analysis, Investment Strategies and Risk of Loss” section below in developing an appropriate asset allocation strategy for your other retirement Plan account assets. If you choose to provide us with a description of the assets you hold outside the Plan for consideration in reaching your retirement income goal (“External Assets”), Merrill Managed will take into account the dollar value and asset allocation of these assets in managing your Plan assets. Merrill does not and will not act in a fiduciary capacity under ERISA or the Advisers Act (or otherwise) under the Program with respect to any assets outside the Plan for which you provide information in utilizing Personal Retirement Strategy. You, as the participant, choose whether or not to enroll in Merrill Managed. Your Plan Sponsor may also use Merrill Managed as a default investment option. Participants who are enrolled in Merrill Managed can terminate Merrill Managed at any time. The Program incorporates only the personal and financial information you and the Plan Sponsor provide to us, and our advice and guidance and investment recommendations are limited to and based only on that information. We will not independently verify the information you provide through the Program Website or that your Plan Sponsor provides to us and we will not consider other information obtained in connection with another account or relationship with Merrill or its Affiliates other than as described in this Brochure. Personal Retirement Strategy will use relevant Plan participant data, including current annual compensation and other indicative data that is supplied directly by the Plan Sponsor to implement personalized investment recommendations for you. If the Plan Sponsor fails to provide the necessary compensation and indicative data, the participant will not be enrolled in Merrill Managed. Instead, the participant’s investments will be invested in a cash equivalent fund indefinitely until the data is received. Separation from Service from your Employer If you are: (1) enrolled in Merrill Managed, (2) subsequently separate from service from your Employer, and (3) have an account balance greater than $25.00, you will need to contact us promptly and update your personal profile information, current employment status, and annual income amount in order to continue to receive discretionary management through Merrill Managed. More specifically, if you have not updated your information by the fifth quarterly rebalance and do not continue to do so on an annual basis thereafter, your account balance will be reallocated into a diversified multi-asset portfolio and will no 5  longer be enrolled in Merrill Managed. Upon termination from Merrill Managed, your account will no longer be reallocated or rebalanced. If you are: (1) enrolled in Merrill Managed, (2) subsequently separate from service from your Employer, and (3) have an account balance less than $25.01, you will be placed into a diversified multi-asset portfolio and will no longer be enrolled in Merrill Managed. Upon termination from Merrill Managed, your account will no longer be reallocated or rebalanced. Investment and Trading Authority When you are enrolled in Merrill Managed, as set forth in the Participant Advisory Agreement, Merrill is granted investment and trading discretion with respect to your Plan assets. Through that discretion, we will have complete trading authority and may invest, reinvest, purchase, sell, exchange, convert and otherwise trade Plan assets included in Merrill Managed. This authority will remain in place until we have received and accepted instruction to terminate your participation in Merrill Managed. Termination of Program Services Merrill Managed may be terminated at any time by you, your Plan Sponsor or Merrill as described in the Plan Sponsor Amendment and the Participant Advisory Agreement. The services under the agreement(s) will continue until you terminate the Participant Advisory Agreement or the termination date set by your Plan Sponsor or Merrill, as applicable. A termination by a Plan Sponsor of Merrill recordkeeping services for a Plan covered by the Program, as applicable, will result in the termination of your access to Personal Retirement Strategy. Plan Sponsors are required to provide notification to Merrill of the decision to terminate recordkeeping services, in accordance with their Master Services Agreement. Electronic Accessibility Requirement Online: Personal Retirement Strategy is accessible through the Benefits OnLine Website, www.benefits.ml.com. The Program provides you with the services described in this brochure electronically through use of the Program Website. Through an online experience, you will be asked to provide us with certain information, which along with certain other information will provide the basis for our recommendation. You should carefully consider whether your participation in the Program is appropriate for your investment needs and goals. You must log in to the Program Website to access important documents and ensure your information is accurate and up to date. Service Representatives: You will also have access to a Retirement & Benefits Contact Center Representative (“Service Representative”) through a Merrill call center. These Service Representatives are able to provide information about Personal Retirement Strategy and assist with navigational support. Service Representatives will not provide any investment recommendations or advice regarding your Plan retirement assets or the appropriateness of Merrill Managed. Other Merrill Advisory Services In addition to the advisory services offered through Personal Retirement Strategy, Merrill offers a wide variety of advisory services. These include, but are not limited to, the following: Merrill Lynch Investment Advisory Program, Merrill Lynch Fiduciary Advisory Services Program, Merrill Lynch Institutional Investment Consulting Program, Merrill Guided Investing, Merrill Guided Investing with Advisor, Merrill Edge Advisory Account, Merrill Lynch Strategic Portfolio Advisor® Service, and Advice Access. We also offer impersonal investment advice (general advice not tailored to the specific needs of any individual) in the form of publications or research. More information about these programs and services is contained in the 6  applicable Merrill brochure (or MLPF&S Form ADV, Part 2A) and is available upon request or through the SEC’s Website at www.adviserinfo.sec.gov. Assets Under Management As of December 31, 2024, Merrill had assets under management of $1,511.09 billion, of which $388.43 billion was managed on a discretionary basis and $1,122.66 billion was managed on a non-discretionary basis. This amount does not include financial planning services. FEES AND COMPENSATION MERRILL MANAGED FEES An advisory fee is charged for Plan assets enrolled in the Merrill Managed service (“Merrill Managed Fee”). The maximum annual Merrill Managed Fee is .25% of the assets enrolled in Merrill Managed whether such fee is an asset-based fee or a fixed dollar amount. All Merrill Managed Fees are payable in arrears. The Merrill Managed Fee is not applicable to any Restricted Assets, as described in the Glossary, whether restricted by you, the Plan Sponsor or held in a self-directed brokerage account. The Merrill Managed Fee is negotiated between Merrill and the Plan Sponsor depending on a number of factors when they enter into the Plan Sponsor Amendment. The extent to which we negotiate the Merrill Managed Fee is solely within our discretion and may include such factors that are not limited to plan size, record keeping fees and breadth of client relationship. The Merrill Managed Fee may be paid by the Plan Sponsor or by you as determined by the Plan Sponsor. If the Plan Sponsor has elected to pay the Merrill Managed Fee, it may agree upon an asset-based fee or fixed dollar amount fee per participant enrolled in Merrill Managed. For Plan Sponsors, the Merrill Managed Fee will be charged on a calendar quarter basis in arrears. If the participant is paying the Merrill Managed Fee, fees will be asset-based, and will be calculated and charged at the same time the scheduled rebalancing occurs, which will be approximately every 90 days, based on the date of the participant’s date of birth. CALCULATION OF THE MERRILL MANAGED FEE Plan Sponsor: Asset-Based Fee: The fee is calculated using an average of the prior 3 month-end balances for the calendar quarter for assets that are not Restricted Assets and are enrolled in Merrill Managed. The Plan Sponsor shall be invoiced each calendar quarter in arrears in an amount equal to one-fourth of the annual Merrill Managed Fee multiplied by the average total amount of participant assets enrolled in Merrill Managed for the quarter. The average total amount of plan assets enrolled in Merrill Managed, for the quarter shall be calculated by taking the eligible Participant assets enrolled in Merrill Managed on the last business day of each calendar month, divided by three. Participants will need to be enrolled in Merrill Managed during at least one month in the quarter in order for a billing to occur for that quarter. In months where there are no assets, zero will be used for that month in the quarterly average. Fixed Dollar Amount Fee: Annual fixed dollar amount fees at the plan level are billed in quarterly calendar increments, in arrears. The Plan Sponsor shall be invoiced in an amount equal to one-fourth of the annual per participant Merrill Managed Fee for each participant enrolled in Merrill Managed on the last calendar day of the calendar quarter. The quarterly fee shall not exceed one-fourth of 0.25% multiplied by total participant plan assets enrolled in Merrill Managed. Participants will need to be enrolled in Merrill Managed in order for a billing to occur. 7  Participant: Asset-Based Fee: Fees shall be paid in arrears, and will be deducted from your Plan assets at approximately the same time as your scheduled rebalancing. Scheduled rebalancing occurs approximately every 90 days and is based on your date of birth. The Merrill Managed Fee is calculated on the business day prior to your scheduled rebalancing and shall be equal to one-fourth of the annual Merrill Managed Fee multiplied by your plan assets enrolled in Merrill Managed on the day the fee is calculated. Initial billing at your first scheduled rebalancing shall be based upon the number of days you have been enrolled in Merrill Managed. If you are not enrolled in Merrill Managed for at least 30 calendar days before your first scheduled rebalancing, the rebalancing of your account will be deferred until the next scheduled rebalancing and you will not be charged for the short period of less than 30 calendar days. If you have been enrolled in Merrill Managed for at least 30 days but less than 90 days before your first scheduled rebalancing, the amount of the Merrill Managed Fee will be pro-rated to reflect the number of days in the period you were enrolled. BILLING UPON TERMINATION OF MERRILL MANAGED Plan Sponsors and participants will not incur additional Merrill Managed Fees after terminating from Merrill Managed. The last full quarter a participant is enrolled in Merrill Managed will be their final billing. Any partial quarters before the termination date will not be billed. PAYMENT OF MERRILL MANAGED FEE Plan Sponsors For fee arrangements where the Plan Sponsor is paying the Merrill Managed Fee, Merrill will provide the Plan Sponsor with an invoice at the end of the calendar quarter for the amount due. Participants For fee arrangements where the Participant is responsible for paying the Merrill Managed Fee, the fee will be deducted from the Plan account at approximately the same time as the quarterly rebalance. If there is insufficient cash in the Plan account to cover the fee, a pro-rata sale of securities will occur during the quarterly rebalance to satisfy the remainder of the fee. OTHER FEES AND EXPENSES The Merrill Managed Fee only covers the Merrill Managed service described in this Brochure. The internal fees and expenses of the funds in the Plan menu used in the Program are not covered by the Merrill Managed Fee. COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS Apart from the services provided through Personal Retirement Strategy, you may also use other products or services available from or through us or our Affiliates, and in such case we or our Affiliate will earn additional compensation. Financial Advisors offering these services will receive compensation in connection with your use of those services. This creates a conflict of interest because we and our Financial Advisors have an incentive to recommend products and services based on the compensation received, rather than a client’s need. Where there is a difference in fees and commissions for some products or services, and the renumeration and profitability to us and our Financial Advisors resulting from transactions on behalf of, or management of, certain accounts is greater than the remuneration and profitability resulting from other advisory accounts, products or services, this creates a conflict of interest due to the financial incentives created. (See section entitled Participation or Interest in Client Transactions 8  and Personal Trading for more information about the receipt of compensation for the sale of securities and other investment products.) Financial Advisors do not receive compensation for Personal Retirement Strategy. We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways, including the disclosure of conflicts in this Brochure. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for each client based upon the client’s investment objectives, risk tolerance and financial situation and needs. In addition, we have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest – both those arising between and among client accounts as well as between accounts and our business. The investment advice delivered through Merrill Managed is based on the menu of investment options made available by a Plan Sponsor through its Plan. These investment options typically include various mutual funds. Plan participants may be able to purchase the same mutual funds for their non-Plan assets. However, they generally will not be able to purchase Plan investments through other brokers or financial institutions, unless permitted by the Plan. SOURCES OF REVENUE As a broker-dealer, Merrill offers a wide variety of securities and brokerage services. Our principal sources of income are derived from our business as a broker-dealer. Less than 1% of our revenue is expected to be generated from Merrill Managed fees on an annual basis. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Neither Merrill nor our employees receive performance-based fees for the services provided in Personal Retirement Strategy. TYPES OF CLIENTS Personal Retirement Strategy is an online investment advisory program available to participants of Plans that also utilize Merrill for recordkeeping services. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Personal Retirement Strategy uses models and investment processes proprietary to BofA Corp. These models and investment processes analyze current and historical returns, prevailing market and macroeconomic conditions, volatility, and cross-correlations and use goals-based asset allocation, among other techniques, to develop individualized recommendations. The approach also uses historic pricing data for mutual funds, individual securities and broad asset categories, as well as current market data and information. INVESTMENT PHILOSOPHY The Chief Investment Office (“CIO”) believes there are several key considerations that are essential for you to consider in order to ensure your investments remain properly aligned to your long-term financial strategy: • Staying disciplined with a goals-based strategy • Maintaining a diversified portfolio and adequate liquidity • Considering a defined portfolio rebalancing strategy CIO utilizes goals-based asset allocation to provide guidance to participants within Personal Retirement Strategy. The investment guidance and advice activities will focus on satisfying your objectives through a 9  dedicated investor-centric goals-based framework. Utilizing the goals-based investment framework, you are first given the opportunity to use a default annual retirement income goal of achieving 85% of your projected salary, or you can specify your retirement income goal in dollars or alternatively, a different percentage of projected salary. The investment strategy and asset allocation are then built on the understanding that your Goal Funding Status is the primary objective. Personal Retirement Strategy, using goals-based asset allocation, provides a customized asset allocation proposal and funding analysis to each participant. The key inputs to the approach are return, volatility, and correlation assumptions from CIO Capital Market Assumptions (“CMAs”), and the model allocations from the firm’s Strategic Asset Allocation (“SAA”). Goals based asset allocation is used in Personal Retirement Strategy for the following purposes: • Goal Funding Status Analysis: Determine the funding status relative to the stated goal and existing wealth. • Suggested Asset Allocation: Determine a target asset allocation for the stated Goal Funding Status. • Trade-offs Discussion: Highlight trade-offs when a shortfall exists (e.g., reduce spending, work longer, retire later) or how to best utilize and allocate any surplus. • Target Date Asset Allocation: An investing approach for an individual with a specific retirement date in mind. General account hierarchy guidelines are applied to a participant’s retirement income goal and financial situation to recommend potential additional contribution amounts towards specific account types with the most efficient combination of tax benefits and company matching/contribution benefits. Tax-advantaged accounts provide either tax-deferrals or tax-exemption benefits and employer matching/contributions increase participant savings. Tax-advantaged account types include a participant’s Plan account or other External Accounts as provided by the participant. Personal Retirement Strategy displays the impact of the recommendations in the Goal Funding Status Analysis. CHIEF INVESTMENT OFFICE’S GOVERNANCE CIO has a variety of governance and oversight structures. The Investment Strategy Committee (ISC) meets on a periodic basis and is comprised of senior members of CIO’s portfolio construction & analytics teams, thought leadership, and due diligence. On at least an annual basis, the firm’s CMAs and SAAs are - reviewed to account for changes in forward-looking returns, volatility, yield and correlation assumptions. BofA Corp.’s Model Risk Management group performs periodic evaluations of CMAs, SAAs, and the portfolio construction methodology used in the Personal Retirement Strategy program to ensure their alignment with BofA Corp.’s risk framework. KEY DATA SOURCES Personal Retirement Strategy updates and personalizes the recommendations and advice provided through Merrill Managed for you based on three key data sources: 1) information typically provided by the Plan Sponsor, 2) information from external data sources obtained by CIO, and 3) information provided by you. These same data sources are also used in the Program Services described in this Brochure. Information typically provided by the Plan Sponsor: Examples include: 1. a. Base Salary b. Current Plan contribution rate c. Applicable Plan provisions such as company match and/or profit sharing rules 10  d. Current Plan account balance e. Age f. Gender g. State of residence Information from external data sources used by CIO. Examples include: 2. a. Estimated Social Security retirement benefits b. Estimated Federal and state tax rates c. A salary growth and contribution rate assumption Information provided by you. Examples of information that influence the advice include: 3. a. Base salary if not provided by the Plan Sponsor b. Changes to your personal situation, such as the addition of a spouse or partner c. Information on other financial assets / accounts to be used to fund the retirement income goal and how they are invested d. Other sources of income such as pensions, supplemental employment income or life insurance payments KEY ASSUMPTIONS Personal Retirement Strategy makes assumptions about certain pieces of information that have a significant impact on the strategy created for you. In particular, these assumptions relate to inflation rates, retirement income goals, federal/state/capital gains/other taxes and your risk tolerance, Social Security amounts (if not yet retired), and salary growth. Social Security Retirement Benefits Personal Retirement Strategy can incorporate Social Security retirement benefits and if applicable, for a spouse/partner, using an estimate based on current salary or a number inputted from a Social Security Administration statement by the participant. Social Security retirement benefits are inflated using a simulated cost-of-living allowance designed to replicate the actual Social Security Administration (“SSA”) formulas and are applied at the maximum benefit age as defined by the SSA. Personal Retirement Strategy accounts for reductions in payments while working in retirement, increases in benefits for the spousal rule and increased benefits for the surviving spouse rule. The program assumes you complete all applications required to collect the maximum benefit. Personal Retirement Strategy defaults to the age at which you will receive full benefits from the SSA, but you can adjust the benefit amount and start age if desired. However, the start age must be between 62 and 70. Salary Growth To estimate future salary, Personal Retirement Strategy uses an inflation assumption of 2.3% that is updated annually as part of the CMA updates. Retirement Age Personal Retirement Strategy defaults to the Social Security Full Retirement Age (FRA). Full Retirement Age is 66 if you were born between 1943 and 1954. The full retirement age increases gradually if you were born from 1955 to 1960 until it reaches 67. For anyone born 1960 or later, full benefits are payable at age 67. You have the option to change this to a different retirement age. 11  Estimated Tax We assume that you include the cost of any taxes you incur for your goal and we do not make any additional assumptions to account for or adjust for the deduction of any taxes in the Goal Funding Status Analysis. We do not consider the impact of income taxes on your ability to fund your retirement income goal. Assuming you plan to use the investments and income included in Goal Funding Status Analysis as the source of funds for tax payments, it is recommended that you enter your retirement income goal as an amount that reflects the cost of the goal, plus any taxes related to achieving your goal that you expect to incur. Some common taxes to consider including in the total cost of your goal are income, sales, and capital gains taxes. When establishing your retirement income goal, we recommend you enter your annual pre-tax income that reflects the amount you earn before any federal, state, or local taxes (not your take home pay). This will ensure the analysis for your retirement income goal includes the cost of taxes. Entering your retirement income goal as an “after-taxes” or take-home value will under estimate the cost to fund your goal and this would lead to the Goal Funding Status Analysis overestimating the funding percentage of your goal. Inflation Assumptions When projecting the growth of various income sources and expenses, Personal Retirement Strategy uses an inflation rate of 2.3%. This inflation rate is updated annually as part of the review of CMAs and SAAs. IRS Limitations and Application of Penalties Calculations that are provided in Personal Retirement Strategy incorporate all IRS contribution limits, eligibility requirements, and withdrawal penalties. Contribution Rates Personal Retirement Strategy assumes that you continue with your current Plan contribution rates. Annual contributions to external accounts are entered by you, and it is your responsibility to update these contributions. Brokerage Account Some Plans allow participants to maintain a brokerage account within the Plan. If your Plan allows this option, you will be responsible for managing and monitoring those assets. Personal Retirement Strategy does not manage brokerage account assets; however, if you provide Personal Retirement Strategy with detailed information on the holdings within the brokerage account, the methodology will consider these holdings in developing an appropriate asset allocation strategy for your other retirement Plan account assets (or in managing your Plan assets that are enrolled in Merrill Managed). If you do not provide detailed information, our methodology will assume that the balance in the self-directed brokerage account is invested in a moderate risk oriented multi-asset portfolio. External Assets Personal Retirement Strategy allows the option for you, at your election, to provide us with information regarding assets not held in your Plan account (“External Assets”) for consideration in developing an appropriate asset allocation strategy for your Plan assets and suggested contribution strategy by account type. Not all external assets are appropriate for consideration by Personal Retirement Strategy. Please see the Program Website for additional information. If you choose to include External Assets for consideration in helping reach your retirement income goal, Merrill will provide advice based on the information you make available regarding the dollar value and asset allocation of these External Assets. Aligning External Assets to your retirement income goal may produce a different Asset Allocation Recommendation than if those External Assets had not been so aligned. We are not an investment 12  adviser with respect to External Assets and therefore we will not advise you on investments or allocation for External Assets. Goal Funding Status analysis is limited to suggestions to contribute more to any particular account type for which you have elected to provide information. It is your responsibility to decide whether or not to act on any suggestion provided. All External Asset investment and allocation decisions remain your responsibility. If you provide us with External Asset information, we recommend you provide us with either the symbol or asset class of the External Assets, which can be entered on the Retirement Settings along with the dollar value of any External Assets. Any symbols or asset classes you provide us on External Assets will be used to determine the asset class (equity, fixed income, or cash) and will inform the forward-looking return assumptions. If you do not provide us with the symbol or asset class of the External Assets, we will assume that the asset allocation of the External Assets is the same as your Asset Allocation Recommendation. If the External Assets are not allocated in accordance with the Asset Allocation Recommendation, the actual performance of those assets will differ materially from our projections, and the resulting Goal Funding Status Analysis will not be accurate. The forward-looking return assumptions for the asset classes used are based on the Index proxies as listed below: Asset Class Index Proxy Equity Standard & Poor's 500 Total Return Fixed Income Intercontinental Exchange BofA US Broad Market Bond Index Cash Ibbotson Associates SBBI US 30 Day T-Bill Total Keeping the External Asset information you provide for External accounts up to date is your responsibility and details can be reviewed anytime on the Program Website. It is important for you initially and on an ongoing basis to classify the External Assets in External accounts into the appropriate asset class. If this information is not accurate and complete, the Asset Allocation Recommendation and, if utilized, the Merrill Managed asset allocation will be compromised. Please see the Program Website for additional information. Restricted Assets Any assets you choose to restrict from being sold in Merrill Managed will have a forward-looking return assumption in line with the asset allocation of the Restricted Assets. The forward-looking return assumptions for Restricted Assets will align with the Asset Class and Index Proxy listed above. Self- directed brokerage accounts are considered Restricted Assets. For more information on self-directed brokerage accounts, please see above. RISK OF LOSS AND STRATEGY RISK General Risks Associated with Investments All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed and the value of your assets will fluctuate due to market conditions and other factors. Investments made and the actions taken respecting your Program assets will be subject to various economic, geopolitical, and market conditions, such as changes in 13  interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Portfolios that consist of equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. You should review the offering materials and other disclosure available for each relevant investment security or transaction, including any prospectuses and other offering material produced by issuers and sponsors of investment products, to get an appreciation of its associated risks and fees. You are assuming the risks involved with investing in securities and other investment products, and you could lose all or a portion of the amount you hold in the Program. For a discussion of conflicts of interest with the use of certain investments and securities, please review the information in this section and in “Compensation, Conflicts of Interest and Material Relationships.” Strategy Risk Investments in securities involve market risk, risk of loss, and other risks, and will not always be profitable. We do not guarantee that the intended objectives of our recommendations will result in achieving your retirement income goal. We cannot guarantee that negative returns can or will be avoided in any of our recommendations. We do not represent or guarantee that our investment recommendations can or will predict future results, will successfully identify market highs or lows, or will result in a profit or protect clients from loss. An investment’s future performance may differ substantially from its historical performance, which is no indication of future performance. A security’s investment 14  return and an investor’s principal value will fluctuate so that, when redeemed, an investor’s shares may be worth more or less than their original cost. We are unable to predict or forecast market fluctuations or other uncertainties that may affect the value of any investment. The Personal Retirement Strategy investment approach is intended to provide you with an asset allocation that is diversified across various asset classes and appropriate based on your facts and circumstances. Asset allocation and diversification are investment strategies which spread assets across various investment types for long-term investing. However, as with all investment strategies, these strategies do not ensure a profit and do not guarantee against losses. Capital Market Assumptions represent a range of forward-looking scenarios for asset class returns which involve known and unknown risks, uncertainties, and other factors which may cause the actual results to differ materially and/or substantially from any future results, performance, or achievements expressed or implied by those projections for any reason. Past performance does not guarantee future results. Income projections used in Personal Retirement Strategy are based on hypothetical performance data and do not represent actual or guaranteed results. Projections may vary over time and with each use of our service. HYPOTHETICAL NATURE OF FORECASTS Personal Retirement Strategy uses a probabilistic approach to estimate your Goal Funding Status. For all participants, the retirement goal in Personal Retirement Strategy is set to be “Important” (75% probability of success, corresponding to medium risk tolerance). You should carefully review the explanation of the methodology used, including key assumptions and limitations, which is provided herein. It is important to note that projections or other information shown in Personal Retirement Strategy regarding the likelihood of various investment outcomes are hypothetical in nature, do not reflect actual investment results and are not guarantees of future results. The projections or other information may vary with each use and over time. PERSONAL RETIREMENT STRATEGY AND MERRILL MANAGED ADVICE AND INVESTMENT RECOMMENDATIONS There are several key investment and planning methodologies behind the personalized recommendations provided by Personal Retirement Strategy and Merrill Managed. CAPITAL MARKET ASSUMPTIONS AND STRATEGIC ASSET ALLOCATION The methodology used for each asset class takes into account current valuations as well as historical relationships among asset classes. These Capital Market Assumptions are then used as an input in the development of long-term asset allocation guidelines (referred to as “Strategic Asset Allocations”), which are the foundation for each participant portfolio. Funds and Market Index Data CIO seeks to construct participant portfolios that are reasonably aligned with the outputs of goals-based asset allocation in Merrill Managed. For each Plan enrolled in Merrill Managed, Plan level portfolios are constructed based on the Plan Sponsor menu of investment choices. Inputs to portfolio construction are: • Plan Sponsor menu of investments (Funds) • • CIO SAA guidance 15  Portfolio construction relies on certain assumptions, including the existence of adequate exposure to funds in Equity, Fixed Income and Money Market / Stable Value categories within the Plan Sponsor’s investment choices. Personalized portfolios are then constructed for the participants utilizing Personal Retirement Strategy and enrolled in the Merrill Managed discretionary investment management service. The objective is to first narrow down the list of Funds within the Plan Sponsor’s investment choices using a proprietary investment selection approach and then to construct a portfolio of Funds that aims to minimize the portfolio’s weighted-average expense ratio and also ensures that the portfolio’s asset allocation to equities, fixed income, and cash is reasonably aligned to your individualized goals based asset allocation output. EMPLOYER SECURITIY RESTRICTIONS AND OTHER FUND HOLDING RESTRICTIONS Any restrictions on employer securities or other fund holding restrictions will impact the Asset Allocation Recommendation in Personal Retirement Strategy that will be used by the Personal Retirement Strategy program. The portfolio models will be based on the menu of investment options selected by each Plan Sponsor. These investment options typically include various mutual funds, but may include Collective Investment Funds (“CIFs”), Money Market, and Stable Value funds. Information about the risks associated with each mutual fund is available in the relevant prospectus or other disclosure document for each mutual fund. Merrill does not recommend specific investments for the Plan’s investment menu through Personal Retirement Strategy. Mutual Funds Mutual funds are sold by prospectus. To determine whether a particular investment is an appropriate investment, carefully consider the important information on the investment objectives, risks, charges and expenses. Please read the prospectus carefully before investing. Mutual funds charge various fees and expenses, which will reduce the actual returns of your investments. Collective Investment Funds CIFs are not available for direct investment by individual shareholders. Unlike a mutual fund, an investor gains access to a collective investment fund through a retirement plan, such as a 401(k) Plan. Additionally, regulation of mutual funds and CIFs varies. For instance, the mutual fund industry is regulated by the SEC, and mutual funds are subject to the Investment Company Act and the rules adopted thereunder, which provide important protections to fund shareholders. For example, mutual funds are sold by prospectus, are subject to limitations on leverage and extensive regulatory reporting requirements, and are governed by independent boards of trustees. In contrast, CIFs are not regulated by the SEC or subject to the Investment Company Act; instead, their investment managers and the CIFs are subject to less stringent guidelines and are overseen by the U.S. Office of the Comptroller of the Currency or by a state banking authority. Stable Value Funds The objective of most stable value funds is to provide safety of principal and an investment return that is generally higher than a money market return, while providing you the ability to withdraw your assets for ordinary transactions at book rather than market value. However, the ability to withdraw stable value assets at book value has limitations based on the insurance contracts that wrap the underlying assets. In addition, most stable value funds require a hold period before assets can be withdrawn from the fund by the Plan Sponsor at book value and may refuse to honor book value withdrawals after communications from a Plan Sponsor or Plan fiduciaries that it determines caused your withdrawals. Additionally, the Plan is often restricted from offering investment alternatives that are viewed as competitive with the stable 16  value offering. Finally, stable value funds are subject to counterparty risk of the insurers that provide the fund's book value liquidity. Money Market Funds Money market funds invest in government and treasury securities (“Government Money Market Funds”), as well as money market funds that invest in corporate commercial paper (“Prime Money Market Funds”). A Government Money Market Fund seeks to preserve the value of your investment at $1.00 per share. However, there is no guaranty it will do so. The sponsors of these funds have no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to these funds at any time. A Prime Money Market Fund does not seek to maintain a stable per share net asset value, and the securities held by the fund are subject to the risk that issuers and/or counterparties will fail to make payments when due or default completely. You could lose money by investing in a Prime Money Market Fund. Because the share price of these funds will fluctuate, when you sell your shares they may be worth more or less than what you originally paid for them. All money market funds may impose a fee upon the sale of shares or may temporarily suspend a participant’s ability to sell shares if a fund’s liquidity falls below required minimums because of market conditions or other factors. Neither Government Money Market Funds nor Prime Money Market Funds are insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Money market funds are sold by prospectus. Please read the prospectus carefully before you invest. INFORMATION AND CYBERSECURITY RISKS With the increased use of technologies to conduct business, all companies including Merrill, its parent BofA Corp, their Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. We and they are targets of an increasing number of cybersecurity threats and cyberattacks. Accordingly, BofA Corp. and Merrill devote considerable resources to the establishment and maintenance of process for assessing, identifying and managing cybersecurity risk. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, the Funds and Fund managers and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. We, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents suffered by BofA Corp. and its Affiliates, including Merrill, and its third-party service providers. While we and our third-party providers have experienced cybersecurity incidents as well as adverse impacts from such incidents (and expect to continue to experience such incidents resulting in adverse impacts with increased 17  frequency and severity due to the evolving threat environment), there can be no assurance that we or our service providers, will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. Our focus on information security includes cybersecurity incidents perpetrated against us, our customers, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including artificial intelligence (AI) and machine learning. We, like all companies, are subject to related litigation or government enforcement with regard to compliance with U.S. and global laws, rules and regulations that could subject us to fines, judgments and/or settlements and involve reputational losses. We continue to adjust our business and operations, disclosure and policies, processes, procedures and controls, including with regard to risk management and data management in an effort to comply with laws, rules and regulations, as well as evolving expectations, guidance and interpretation by regulatory authorities and self-regulatory organizations. Further, we expect to become subject to future laws, rules and regulations beyond those currently proposed, adopted or contemplated in the U.S. or abroad, as well as evolving interpretations of existing and future laws, rules and regulations, which may include policies and rulemaking related to emerging technologies, such as the development and use of AI and machine learning, cybersecurity and data. The cumulative effect of all of the current and possible future legislation and regulations, as well as related interpretations, on our litigation and regulatory exposure, businesses, operations and profitability remains uncertain and necessitates that we make certain assumptions with respect to the scope and requirements of existing, prospective and proposed laws, rules and regulations in our business planning and strategies. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. While we continually update our policies, programs, processes and practices and implement emerging technologies, such as automation, AI, machine learning and robotics, our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and our ability to manage current and emerging risk, produce accurate financial and/or nonfinancial, regulatory, operational and ESG reporting, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, and to manage changing business needs, strategic decision-making, resolution strategy and operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. DISCIPLINARY INFORMATION The following is a summary of certain adverse legal and disciplinary events and regulatory settlements that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of Merrill Lynch’s Form ADV at adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank 18  Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the third party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and- desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a markup or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self- reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. (approximately 1,500) were invested On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’s remedial acts promptly undertaken and cooperation afforded the SEC staff. 19  MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Merrill, an indirect wholly owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through its Affiliate, BofA Securities, Inc. (“BofAS”), it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. Merrill also acts as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system, and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As a registered investment adviser, Merrill completes a Form ADV which it publicly files with the SEC (available at www.adviserinfo.sec.gov). For purposes of Form ADV Part 2, certain Merrill management persons are registered as registered representatives or associated persons of Merrill. In the future, certain Merrill personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of Merrill to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, including us, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning; asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; (7) proprietary trading of securities, derivatives and loans; (8) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (9) insurance and annuities sales and (10) providing research including global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act and additional information about BofA Corp. can be found in publicly available filings with the SEC. From time to time, a shareholder of BofA Corp. may acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within your Plan assets, such as buying or selling securities issued by the shareholder or its Affiliates, may be limited. We address these conflicts through disclosure in this Brochure. Moreover, our Financial Advisors are required to recommend investment advisory programs, investment products and securities that are suitable for clients based upon their investment objectives, risk tolerance and financial situation and needs. In addition, we have established a variety of restrictions, procedures and disclosures designed to 20  address actual and potential conflicts of interest – both those arising between and among client’s accounts as well as between client accounts and our business. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CONFLICTS OF INTEREST AND INFORMATION WALLS Merrill and its parent company, BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time while mitigating any conflicts arising from such a situation. For example, information walls prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within the BofA Corp. organization possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which provides guidelines for the business practices and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., BofAS, and Merrill evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide you with full and clear disclosure or to take action to avoid or manage the conflict. CODE OF ETHICS We have adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering our personnel who are involved in the operation and offering of investment advisory services. The Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that we follow in conducting our business with integrity and professionalism. The Code of Ethics covers: • Requirements relating to employees complying with all applicable securities and related laws and regulations • Reporting and/or clearance of employee personal trading • Prevention of misuse of material nonpublic information, and • The obligation to report possible violations of the Code of Ethics to management or other appropriate personnel Covered personnel must certify to the receipt of the Code of Ethics. We will provide a copy of the Code of Ethics to any Plan Sponsor or Plan participant upon request. We also have imposed policy restrictions on all personnel regarding transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, we have special policies requiring that certain personnel obtain specific approval of securities transactions and have implemented procedures for monitoring these transactions, as well as those of all our employees. PRIVACY/DATA PROTECTION We will not disclose to the Plan Sponsor any “personal information” obtained directly from any Plan 21  participant. Personal information includes any information that can specifically identify an individual, such as name, address, Social Security number, etc. Personal information does not include information about any Plan participant that the Employer already knows or is entitled to know in connection with the administration of the Plan. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through its Affiliate BofAS, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. We also act as a broker and/or dealer in the purchase and sale of mutual funds, money market instruments, government securities, high-yield bonds, municipal securities, financial futures contracts and options. We operate the firm’s U.S. retail branch system, and also provide financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services and custodial services. As a result of our Affiliates’ involvement in multiple business activities, we recognize that actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization, including that our employees may have interests unrelated to the interests of Personal Retirement Strategy participants (see further discussion below). This discussion does not seek to identify all actual or potential conflicts. Information about certain additional conflicts is described throughout this Brochure and in many of the contracts and offering documents that govern the specific products and services we offer. Investment options made available to participants through a Plan may include mutual funds or products from which Merrill or its Affiliates receive fees or compensation in addition to the fees for this service described above. This additional revenue can be in the form of sub-accounting or processing fees (fees for transaction and account processing functions), service fees, and/or distribution fees. We only make available mutual funds, money market funds (each, a “fund”) and share classes of funds that retain and pay us to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under agreements with each of these funds (or their respective principal underwriter or other agent), we provide daily sub-accounting services (either directly or through a subsidiary) to the holders of these funds maintaining shares in an account as well as in other Merrill securities accounts and receive the agreed-upon sub-accounting services fee. This cost is either borne by the fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of the compensation vary by fund types, fund and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. We have a conflict of interest in selecting certain fund products (or share classes) for inclusion as part of our product offering available to you. Certain mutual funds or share classes that would otherwise meet our criteria for inclusion as part of our product menu but whose principal underwriters, agents or sponsors do not agree to pay a fee that we determine is appropriate for its services will not be selected, thereby limiting the available universe of funds (and share classes) available to you. In addition, the amount of the fees paid to us for these services varies among funds and, in certain instances, between share classes of individual funds. This results in a conflict of interest because it creates an incentive for us to recommend that you invest in funds and share classes that pay higher fees. We will receive higher sub-accounting fee 22  payments from fund families that have higher fund assets held in our client’s accounts because the service fee calculation is based off of the level of the asset holdings. Additionally, we benefit financially because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. We address these conflicts of interest in the following ways, which include disclosing the nature of our sub- accounting service arrangements. We also determine the compensation paid to our personnel on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our personnel do not have an incentive to recommend certain funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, we and our Affiliates select funds that are available and offered through the Program as well as in our brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Personal Retirement Strategy, from time to time, will recommend changes to Plan participants’ account holdings and any implementation of these recommendations will result in transactions in participants’ accounts. To the extent that such implementation involves products that result in payments to us or our Affiliates we or our Affiliates benefit. Similarly, investment options made available to participants may change. To the extent that we provide Plan Sponsors with information or recommendations about existing or substitute investments, we may provide information regarding mutual funds and other investments, from which Merrill or our Affiliates receive these additional forms of revenue. As a broker-dealer effecting transactions as part of the program, we or an Affiliate may act as agent or as principal for our own account, as permitted by applicable law. Similarly, we or an Affiliate may, in transactions involving such clients' securities, act as agent while also representing another client on the other side of the transaction. In addition, we or our Affiliates may have a position in, or enter purchase or sale orders for, securities recommended to clients in the normal course of our business as a broker- dealer. We and/or our Affiliates may profit from these positions or transactions in securities. We, through our Financial Advisors, may suggest or recommend that participants use Merrill securities accounts, execution and custody or other services, or such services of an Affiliate in connection with their non-Plan assets. Similarly, Financial Advisors, who also handle participants’ securities accounts, may suggest or recommend that participants purchase our products or products of an Affiliate. Where Merrill’s or our Affiliate’s services are used or products are purchased by participants for their non-Plan assets, we and our Affiliates will receive fees and compensation. Financial Advisors may, as permitted by applicable law, receive compensation (the amount of which varies) in connection with these products and services. Compensation received in connection with participants’ purchase or sale of stocks, bonds, mutual funds, other securities or insurance products through us or our Affiliates may include commissions, spreads, markups and markdowns, and distribution or other fees. We also benefit from the possession or use of any free credit balances in participants’ accounts, subject to the restrictions imposed by Rule 15c3-3 under the Exchange Act. With respect to participants’ non-Plan assets, we, acting in our broker-dealer capacity, may recommend that participants invest in a variety of limited partnerships, investment vehicles such as hedge funds and other investment funds, for which certain of our Affiliates act as general partners. The investments of the limited partnerships and other entities may vary but include, without limitation, real estate, futures, hedge funds and other alternative investments. While using Personal Retirement Strategy, suggestions, recommendations or options may lead a participant to enroll in Merrill Managed, contribute more to their 401(k) Plan account already enrolled in Merrill Managed, or deposit funds into a Bank of America, N.A. HSA, or other new or existing account with 23  Merrill or one of our Affiliates. To the extent these actions result in payments of direct or indirect revenue to us or our Affiliates, we or our Affiliates will benefit. INVESTMENTS IN SECURITIES BY MERRILL AND OUR PERSONNEL Merrill provides a variety of advisory and brokerage services to others and these services may involve Merrill recommending a transaction in securities that are investment options selected by the Plan Sponsor. From time to time in the course of those duties, confidential information may be acquired that cannot be divulged or acted upon for advisory or other clients. Similarly, recommendations made in other services or programs may be contrary to the recommendations to participants using these services. For example, Merrill may recommend that an investment advisory client in another program buy shares of a particular mutual fund and at the same time replace those shares with shares of other investment options in a participant’s account. We and our Affiliates have investment banking or other relationships with certain publicly traded companies; these relationships, from time to time, compel us to forego trading in the securities of these companies. In the course of investment banking and other activities, our Affiliates acquire confidential or material nonpublic information that prevents us or our Affiliates, for a period of time, from purchasing or selling particular securities for your account. We and our Affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. In addition, potential conflicts of interest also exist when Merrill maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon Merrill or its Affiliates by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude the inclusion of particular securities or financial instruments in a client’s Portfolios where Merrill or its Advisors provide discretionary management services, even if the securities or financial instruments would otherwise meet the investment objectives of such portfolio. Merrill and its Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs (“In-Scope Funds”) by Merrill, its Affiliates and those of their clients that have granted discretion to Merrill, its Affiliates and/or Merrill Advisors (“discretionary clients”) to avoid potential restrictions on the ability of Merrill and its Affiliates to engage in principal trading and other transactions with In-Scope Funds. A portion of the aggregate ownership limit is attributed to our Affiliates. When Merrill and its Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to Merrill or its Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because Merrill’s and its Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest for Merrill in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. We or one of our Affiliates may have a position in or enter into "proprietary" transactions in securities purchased or sold for clients. We or our Affiliates benefit from such securities positions or transactions. We address these conflicts through disclosure in this Brochure. BROKERAGE PRACTICES Transactions in connection with Personal Retirement Strategy are effected by Merrill or an Affiliate. The Plan Sponsor has authorized us as agent to use our (or an Affiliate’s) own execution services to purchase, 24  exchange and redeem fund shares and other investment options available under the Plan and to take any other necessary action relating to transactions in Plan participant accounts, including the completion and settlement of transactions. Mutual fund orders may be combined with other mutual fund purchases and sales across our platform for purposes of submitting consolidated purchase or redemption requests to the relevant transfer agent for each fund. We purchase and redeem all fund shares for the program account at net asset value without the imposition of any front-end or contingent deferred sales charges. REVIEW OF ACCOUNTS Plan participant accounts enrolled in Merrill Managed are reallocated or rebalanced approximately every 90 days to ensure Plan assets are aligned with your target asset allocation. Should there be other factors that impact the rebalance, rebalancing will occur once those factors are resolved. A reallocation refers to a change in the Asset Allocation Recommendation. A rebalance is a realignment to an existing Asset Allocation Recommendation. At this 90-day frequency, a reallocation of your Plan assets will occur when one or more of the following happen: • You or your Plan Sponsor modifies previously provided information that impacts your Goal Funding Status Information on External Assets is added or modified • • Updates to Capital Market Assumptions or Strategic Asset Allocation are made by the Chief Investment Office. • Updates to the Plan Sponsor investment menu We will contact you periodically, primarily through electronic means, to request that you review your information and ensure that it is up to date. We will send you periodic updates that contain information about your Account, including account statements which include a playback of your current Merrill Managed strategy, if applicable, and the information provided by you and your employer which is used to suggest an allocation for your 401(k). CLIENT REFERRALS AND OTHER COMPENSATION RELATIONSHIPS WITH THIRD-PARTY FIRMS Third-Party Firm Business Relationships. We and our Affiliates have business relationships with investment managers, including Style Managers, Fund managers, distributors and sponsors, and insurance companies and other product providers (“Third-Party Firms”). We make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to us or our Affiliates including effecting transactions in the ordinary course of business for Third-Party Firm. Any compensation paid to us or our Affiliates by the fund manager or sponsor or any of their Affiliates is additional compensation to us for services we and our Affiliates provide to them. In order to make investment products or services available on our platform, we incur certain technology and infrastructure costs. While we do not generally receive reimbursement for technology-related costs associated with the onboarding or maintenance of a platform, tool or service, we reserve the right to seek reimbursement from Third-Party Firms for particular projects. In the event that we receive support from 25  product issuers or sponsors for such costs, it creates a conflict with our ability to use strictly objective factors when selecting product sponsors to make available on our platform. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. We disclose the nature of our relationship in general with Third-Party Firms. We determine the compensation paid to our Financial Advisors on the same basis for all Program assets without regard to the amount of compensation we or our Affiliates receive. Our financial advisors do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. We have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice we and our Financial Advisors provide. PARTICIPATION AND SPONSORSHIP BY THIRD-PARTY FIRMS FOR MERRILL CONFERENCES, MANAGER MEETINGS AND CHARITABLE EVENTS. Certain Third-Party Firms periodically participate in Merrill-hosted internal training and education conferences (Conferences) for invited Merrill financial professionals. These financial professionals include Financial Advisors and members of their team, employees who work for a Merrill branch, market or division to support the Financial Advisors (Field Management Employees) and employees who cover product, the Chief Investment Office and home office support functions (Non-Field Employees). Merrill also holds client and prospect events (e.g., seminars, trade shows, booth events) where Third- Party Firms participate (Client Events). Merrill organizes the Conferences and Client Events and approves the attendees, speakers, agenda and meeting content and sponsors. Third Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities costs (including food and beverages), certain speaker costs and travel, lodging and continuing education costs for attending Financial Advisors and select employees facilitating the Conferences and/or Client Events. During 2024, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with a number of Conferences and Client Events in the amount of approximately $21 million. Certain Third-Party Firms periodically host or participate in meetings (Manager Meetings) where they provide certain Financial Advisors, Field Management Employees and Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel, accommodation and continuing education fees for the attending Financial Advisors, Field Management Employees and certain permitted Non-Field Employees (not including any CIO employee). In 2024, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was $3.1 million. Third-Party Firms also provided monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third- Party Firms in support of charitable events and causes that we requested or initiated with the Third- Party Manager in 2024 was approximately $260,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives for 26  Financial Advisors to recommend products of participating Third-Party Firms. They give those Financial Advisors participating in Conferences, Client Meetings, Manager Meetings and charitable events with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for Field Management Employees to approve those recommendations and for Non-Field Employees to select products of the Third-Party Firm for the Merrill platform. We address these conflicts in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill for, or pay the costs of, such events in order for their investment products to be made available on the Merrill platform. Neither we nor our Affiliates incentivize our Financial Advisors to recommend the products or services of a Third-Party Firm that makes such contributions over those that do not. We do not incentivize Field Management Employees to approve their Financial Advisor’s recommendations of products and services of those participating Third-Party Firms. Furthermore, we do not incentivize Non-Field Employees to approve particular products of a Third-Party Firm for the Merrill platform. Third-Party Firms are not permitted to condition their reimbursement or payment on any amount of sales of their products or services. Third-Party Firm reimbursements of costs for Conference and Client Events and the payment of Manager Meeting and charitable event costs must align to Merrill internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice we provide. THIRD-PARTY FIRM OFFICE ACCESS, GIFTS, AND ENTERTAINMENT Representatives of Third-Party Firms will, from time to time, meet and work with our Financial Advisors, Field Management Employees and Non-Field Employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. We have policies and procedures that limit Third-Party Firms from providing or paying for, and our Financial Advisors, Field Employees and Non-Field Employees, from receiving, gifts, and entertainment (including meals) other than as permitted by and subject to the limits established under Merrill internal policies. In general, our Financial Advisors, Field Management Employees and Non-Field Employees may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. We do not permit any gifts or entertainment conditioned on achieving a sales target. Permitting Third-Party Firm representatives access to our financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. It can also create incentives for Field Management Employees to approve recommendations of a Financial Advisor, where required. Furthermore, providing gifts and entertainment to Non-Field Employees creates incentives to approve the investment products of the Third- Party Firm for the Merrill platform. In addition to monetary limits, we have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice we provide. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. Merrill does not incentivize any of its financial professionals to recommend or select one investment product over another. We have policies, procedures and supervisory controls that have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. 27  PROVISION OF DIVERSIFIED FINANCIAL SERVICES BY US AND OUR AFFILIATES From time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for your Account. Additional information regarding these relationships is publicly available in Regulation NMS Rule 606 reports we file with the SEC. CUSTODY Plan assets for which Merrill serves as record-keeper generally are custodied with BANA as Trustee and held with Merrill; please refer to the applicable documentation for information regarding Merrill’s responsibilities as a custodian. However, Plan Sponsors can also enter into separate custody agreements to hold Plan participant funds and securities with other qualified custodians that are not affiliated with Merrill. Any such separate agreement with an unaffiliated custodian may contain authorizations for transferring assets held with that custodian that are broader than those granted to us in agreements in connection with the Personal Retirement Strategy services, and the unaffiliated custodian’s monitoring, if any, of assets held with it is governed by that separate agreement. It is important to note that our rights and authority to transfer Plan assets held with an unaffiliated custodian are limited to those set forth in agreements in connection with the Personal Retirement Strategy services, regardless of any separate agreements or arrangements a Plan Sponsor or Plan participant may have or enter into with any such custodian. We disclaim any broader rights that may be contained in that separate agreement. In our capacity as record-keeper and, as holder of assets (as applicable), Merrill provides Plan participants with written participant quarterly benefit statements. Plan participants should review their statements carefully. To the extent you receive account statements from other qualified custodians, please compare the account statements you receive from the qualified custodian with those you receive from us. INVESTMENT DISCRETION Plan participants may enroll in the discretionary investment management option of Personal Retirement Strategy, Merrill Managed. VOTING CLIENT SECURITIES Merrill does not accept authority to vote client securities held in the participant’s Plan accounts enrolled in Personal Retirement Strategy. Depending on the terms of the Plan Sponsor’s Plan document and its related trust, either the Plan fiduciary may vote proxies relating to securities in the participant’s Plan accounts or the proxies may be passed through to the Plan participant to vote the proxies. Merrill does not provide advice with respect to a particular proxy solicitation. Merrill will not render any advice or take any action with respect to securities or other property currently or formerly held in Plan accounts that become the subject of any legal proceedings, including bankruptcies and class actions. FINANCIAL INFORMATION Not applicable. GLOSSARY “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Affiliate” means a company that is controlled by, in control of, or under common control with another company. 28  “AWC” means a FINRA Letter of Acceptance, Waiver and Consent. “BofA Corp.” means Bank of America Corporation. “Benefits OnLine” means the internet website provided by Merrill to an Employer and their Plan participants as part of the record-keeping services Merrill provides to an Employer’s Plan. “Brochure” means the Merrill program brochure relating to Personal Retirement Strategy, as amended or updated from time to time. “CIO” means The Chief Investment Office. “CMAs” means The Chief Investment Office’s Capital Market Assumptions. “Code of Ethics” means Merrill’s Investment Adviser Code of Ethics. “CIFs” means Collective Investment Funds. “Employer” means the employer of the participant. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “External Assets” means accounts held outside the Plan by the participant. “Financial Advisor” means a Merrill Financial Advisor or other applicable financial professional. “FINRA” means the Financial Industry Regulatory Authority, Inc. “Goal Funding Status Analysis” means whether the participant is on target to accumulating sufficient total assets to achieve the annual retirement income goal. “Government Money Market Funds” means money market funds that invest in government and treasury securities. “Investment Company Act” means the Investment Company Act of 1940, as amended. “IRS” means the Internal Revenue Service. “Master Services Agreement” mean the agreement between Merrill and the Plan Sponsor. “Merrill,” “MLPF&S,” “we” or “us” means Merrill Lynch, Pierce, Fenner & Smith Incorporated. “Merrill Managed®” means the discretionary investment management feature of Personal Retirement Strategy. “Merrill Managed Fee” means the advisory fee is charged for participants enrolled in the Merrill Managed service. “Participant Advisory Agreement” means the agreement between Merrill and the participant. “Plan” means the defined contribution Plan sponsored by the participant’s employer. “Plan Sponsor Amendment” means the agreement between Merrill and the Plan Sponsor. “Prime Money Market Funds” means money market funds that invest in corporate commercial paper. “Reallocation” means the automatic placement of a participant’s account into a different portfolio model by Merrill Managed, if applicable, after review of the participant’s information and the specific investment allocation percentages that comprise the portfolio model. “Rebalancing” means the periodic rebalancing of the participant’s account by Merrill Managed to the participant’s current asset allocation to adjust for investment gains and losses across the asset classes. “Restricted Assets” means certain securities or holdings that a Plan Sponsor or participant has restricted or limited the sale of within the Merrill Managed service, and assets included in any self-directed brokerage account the participant maintains in the Plan. “SAA” means Strategic Asset Allocation. 29  “SEC” means the U.S. Securities and Exchange Commission. “Securities Act” means the Securities Act of 1933, as amended. “Service Representative” means a Retirement & Benefits Contact Center Representative at a designated Merrill call center to which Plan participants will have access. Unless otherwise noted, registered service marks and service marks are the property of BofA Corp. © 2025 Merrill Lynch, Pierce, Fenner & Smith Incorporated. Printed in the U.S.A. 30