MMA ASSET MANAGEMENT LLC

MMA Asset Management LLC Form ADV Part 2A 161 Washington Street, Suite 1200, Conshohocken, PA 19428 (877) 652-6712 WEBSITE: marshmma.com/us/solutions/asset-management.html March 27, 2025 Last Revised on March 30, 2024 This brochure provides information about the qualifications and business practices of MMA Asset Management LLC (the “Firm”). If you have any questions about the contents of this brochure, please contact us at 212-345-5000. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. You can find more information about MMA Asset Management LLC on the SEC’s to MMA Asset website at www.adviserinfo.sec.gov. References herein Management LLC as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training.  Item 2 Material Changes Within 120 days of the end of the Firm’s fiscal year, we will provide you with a summary of material changes, if any, describing only material changes to this Brochure since the last annual update. In addition, if material changes occur throughout the year, we will promptly furnish you with a summary of those changes. Any summary of material changes will also include instructions for you to obtain a complete copy of the Brochure at no charge if you wish. Since the last annual updating amendment dated March 30th, 2024 , the firm has not made any material changes to this brochure or its business practices. Full Brochure Available Clients wishing to receive a complete copy of our current Brochure can request a copy at no charge by contacting its investment adviser representative or the Compliance Department at: (212) 345-5000. Additional information about the Firm also is available on the SEC’s website at www.adviserinfo.sec.gov. MMA Asset Management LLC Firm Brochure - Retail Page 2 of 15  Item 3 Table of Contents 1. Cover Page .................................................................................................................................... cover 2. Material Changes ........................................................................................................................... 2 3. Table of Contents ........................................................................................................................... 3 4. Advisory Business .......................................................................................................................... 4 5. Fees and Compensation................................................................................................................. 7 6. Performance-Based Fees and Side-by-Side Management .............................................................. 10 7. Types of Clients ............................................................................................................................. 10 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 10 9. Disciplinary Information .................................................................................................................. 11 10. Other Financial Industry Activities and Affiliations ........................................................................... 12 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................... 12 12. Brokerage Practices ....................................................................................................................... 13 13. Review of Accounts ........................................................................................................................ 14 14. Client Referrals and Other Compensation ....................................................................................... 14 15. Custody .......................................................................................................................................... 14 16. Investment Discretion ..................................................................................................................... 15 17. Voting Client Securities .................................................................................................................. 15 18. Financial Information ...................................................................................................................... 15 MMA Asset Management LLC Firm Brochure - Retail Page 3 of 15  Item 4 The Firm’s Advisory Business MMA Asset Management LLC (the “Firm”) is a limited liability company with headquarters in Conshohocken, PA. The Firm is owned by Marsh & McLennan Agency LLC (“MMA”), which is an indirect wholly owned subsidiary of Marsh & McLennan Companies, Inc. (“MMC”). MMC is a public corporation listed on the New York, Chicago, and London stock exchanges (ticker symbol: MMC). MMC’s website address is www.marshmclennan.com . The Firm began conducting business in 2009 and became registered as an investment adviser firm in November 2010. Overview of Firm’s Advisory Services The Firm provides discretionary and/or non-discretionary investment advisory services to its clients on a fee basis. The Firm’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Firm’s management, generally between negotiable and 1.25%. The Firm's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning, and consulting services. If the client requires extraordinary planning and/or consultation services (to be determined at the sole discretion of the Firm), the Firm will determine whether to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. The Firm provides investment advisory and consulting services to employer-sponsored retirement plans, corporations, not- for-profit institutions, foundations, endowments, and charities. The Firm provides information in a separate disclosure brochure for its other advisory services. If clients would like more information on our other services and programs, clients should contact the Firm for a copy of the disclosure brochure that describes those services or programs or go to www.adviserinfo.sec.gov. Consulting and Financial Planning Services (Stand-alone) The Firm provides consulting and/or financial planning services (including investment and non- investment related matters) on a stand-alone separate fee basis. The Firm’s consulting and planning fees are negotiable; they are charged either on a fixed fee basis or on an hourly rate basis ranging from $ 250 to $ 750, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging the Firm to provide planning or consulting services, clients are required to enter into a Financial Planning and Related Services Agreement with the Firm setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to the Firm commencing services. If requested by the client, we recommend the services of other professionals for implementation purposes, including certain Firm’s representatives in their individual capacities as registered representatives of MMA Securities LLC (“MMAS”), a FINRA member broker-dealer and an affiliate of the Firm, and/or in their individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Firm. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Firm, shall be responsible for the quality and competency of the services provided. It remains the client’s responsibility to promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s previous recommendations and/or services. LPL Financial LLC Sponsored Advisory Programs Strategic Wealth Management (SWM) is a custodial account opened with LPL which is used by the Firm to manage client assets. IARs use the SWM platform to directly manage their client(s) assets on either a discretionary or non-discretionary basis using the investment advisory agreements of the Firm. When appropriate, certain IAR can provide advisory services through programs sponsored by LPL Financial, LLC (“LPL”). Below is a description of each LPL advisory program utilized by the Firm. Annualized fees for participation in LPL advisory programs vary up to a stated maximum of 3.00%. Regardless, the Firm has imposed a stated firm maximum as described in the Fees and Compensation section of this brochure for the use of any advisory programs – sponsored by LPL or otherwise available to the IAR. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs, and the potential conflicts of interest presented by the programs please see the LPL Form ADV Part 2A and the applicable LPL Financial client agreement. MMA Asset Management LLC Firm Brochure - Retail Page 4 of 15  Certain Funds (“SWM Eligible Funds”) in the Strategic Wealth Management (SWM) program contain 12b-1 fees. The list of available mutual funds in SWM is selected by LPL Financial, the program manager. In the SWM program, there are certain SWM Eligible Funds available for each fund family. In certain instances, the best available fund may be a share class containing a 12b-1 fee. The Firm does not receive or accept 12b-1 fees on advisory accounts; any 12b-1 fees generated through these funds will be retained by the custodian. Manager Access Select Program (MAS): MAS provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. We will assist client in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL Financial. The Portfolio Manager manages client’s assets on a discretionary basis. We will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP): OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, the client will authorize LPL Financial on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. We will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. The Firm will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL Financial will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL Financial will also have authority to rebalance the account. A minimum account value of $15,000 is required for OMP. Model Wealth Portfolios Program (MWP): MWP offers clients a professionally managed mutual fund asset allocation program. The IAR will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. We initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL Financials’ Research Department consistent with the client’s stated investment objective. LPL Financials’ Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL Financial act on a discretionary basis to purchase and sell mutual funds, including in certain circumstances exchange traded funds and to liquidate previously purchased securities. The client will also authorize LPL Financial to effect rebalancing for MWP accounts. The MWP program may make available model portfolios designed by strategists other than LPL’s Research Department. If such models are made available, the IAR will have discretion to choose among the available models designed by LPL and outside strategists. A minimum account value of $100,000 is required for MWP. Non-Investment Consulting/Implementation Services For certain clients, the Firm provides consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Neither the Firm, nor any of its representatives, serves as an attorney or accountant and no portion of the Firm’s services should be construed as or relied upon as legal or tax advice. At times, when appropriate, the Firm recommends the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.), including certain representatives of the Firm in their separate registered/licensed capacities as discussed in Item 5 and above. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Firm. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Firm, shall be responsible for the quality and competency of the services provided. MMA Asset Management LLC Firm Brochure - Retail Page 5 of 15  Inverse/Enhanced Market Strategies When appropriate, the Firm utilizes long and short mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. Considering these enhanced risks/rewards, a client may direct the Firm, in writing, not to employ any or all such strategies for their accounts. Non-Discretionary Service Limitations Clients that determine to engage the Firm on a non-discretionary investment advisory basis must be willing to accept that the Firm cannot affect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client. Thus, if the Firm would like to make a transaction for a client’s account, and client is unavailable, the Firm will be unable to affect the account transaction (as it would for its discretionary clients) without first obtaining the client’s verbal consent. Use of Mutual and Exchange Traded Funds Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by the Firm independent of engaging the Firm as an investment advisor. However, if a prospective client determines to do so, he/she will not receive the Firm’s initial and ongoing investment advisory services. In addition to the Firm’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Portfolio Activity The Firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the Firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when the Firm determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by the Firm will be profitable or equal any specific performance level(s). Retirement Rollovers-Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If the Firm recommends that a client roll over his or her retirement plan assets into an account to be managed by the Firm, such a recommendation creates a conflict of interest because the Firm will benefit by earning fees for providing services to the new account or additional assets because of the roll over recommendation. To mitigate this conflict, the Firm has implemented policies and processes so that when the Firm makes a recommendation (including a roll over recommendation), the Firm is acting in its fiduciary capacity and its recommendation is consistent with the client’s best interest. No client is under any obligation to rollover retirement plan assets to an account managed by the Firm. eMoney Advisor Platform When appropriate, the Firm provides its clients with access to an online platform hosted by “eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that the Firm does not manage (the “Excluded Assets”). The Firm does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, the Firm shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not the Firm, shall be exclusively responsible for such investment performance. The client may choose to engage the Firm to manage some or all the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between the Firm and the client. The eMoney platform also provides access to other types of information and applications MMA Asset Management LLC Firm Brochure - Retail Page 6 of 15  including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by the Firm. Finally, the Firm shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without the Firm’s assistance or oversight. Cash Positions When appropriate, the Firm maintains cash and cash equivalent positions (such as money market funds) for defensive and liquidity purposes. Unless otherwise agreed in writing, all cash and cash equivalent positions will be included as part of assets under management for purposes of calculating the Firm’s investment advisory fee. Trade Error Policy The Firm shall reimburse accounts for losses resulting from the Firm’s trade errors but shall not credit accounts for such errors resulting in market gains. The gains and losses are reconciled within the custodian firm account and the Firm retains the net gains and losses. Client Obligations In performing its services, the Firm will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s previous recommendations and/or services. to, or A copy of the Firm’s written Brochure as set forth on Part 2 of Form ADV will be provided to each client prior contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Related Services Agreement. The Firm will provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Firm will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Firm’s services. The Firm does not participate in a wrap fee program. As of December 31, 2024, in the aggregate, the Firm had approximately $364,799,465 in regulatory assets under management on a discretionary basis and $ 350,442,631 in regulatory assets under management on a non-discretionary basis, with respect to individual clients (including high net worth individuals), employer-sponsored retirement plans, corporations and other institutional clients. Item 5 Fees and Compensation The Firm provides discretionary and/or non-discretionary investment advisory services on a fee basis. Our annual investment advisory fee shall be based upon a percentage (%) of the market value and type of assets placed under the Firm’s management (between negotiable and 1.25%), to be charged quarterly in advance, as follows: Market Value of Portfolio % Of Assets $0-$1,000,000 $1,000,001-$5,000,000 $5,000,001-$10,000,000 $10,000,001+ 1.25 1.00 0.75 Customized The Firm's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, consulting, and financial planning services. The fee will be calculated on a tiered (or breakpoint) fee schedule that is based upon the overall value of the accounts included within the Client’s household (billing group) and will be calculated at the stated fee tier based upon the total aggregate value of assets under management. All assets under the detailed household will be charged at this stated fee tier. Where requested by a client, the Firm may charge a flat fee percentage (%) per annum for accounts rather than utilizing the noted tiered schedule. The election of tiered billing or flat fee billing will be noted in Section 2 of the Firm’s Investment Advisory Agreement. MMA Asset Management LLC Firm Brochure - Retail Page 7 of 15  If the client requires extraordinary consultation and/or planning services (to be determined at the sole discretion of the Firm), at times, we determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. The Firm’s investment advisory fee is negotiable at its discretion, depending upon objective and subjective factors including but not limited to: the amount of assets to be managed; portfolio composition; the scope and complexity of the engagement; the anticipated number of meetings and servicing needs; related accounts; future earning capacity; anticipated future additional assets; the professional(s) rendering the service(s); prior relationships with the Firm and/or its representatives, and negotiations with the client. As a result of these factors, similarly situated clients could pay different fees, the services to be provided by the Firm to any client could be available from other advisers at lower fees, than those specifically set forth above. and certain clients may have fees different Consulting and Financial Planning Services (Stand-alone) When requested by a client, the Firm provides consulting and/or financial planning services (including investment and non- investment related matters) on a stand-alone fee basis. The Firm’s consulting and planning fees are negotiable and are charged either on a fixed fee basis or on an hourly rate basis ranging from $250 to $750, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Clients may elect to have the Firm’s advisory fees deducted from their custodial account. Both the Firm’s Investment Advisory Agreement and the custodial/clearing agreement may authorize the custodian to debit the account for the investment advisory fee and to directly remit that management fee to the Firm in compliance with regulatory procedures. In the limited event that the Firm bills the client directly, payment is due upon receipt of the invoice. The Firm shall deduct fees and/or bill clients quarterly in advance, based upon the market value of the assets on the last business day of the previous quarter. As discussed below, unless the client directs otherwise or an individual client’s circumstances require, the Firm typically recommends that Charles Schwab & Co., Inc. (“Schwab”) or LPL Financial LLC (“LPL”) serve as the custodian for client investment management assets. Custodians such as Schwab and LPL charge brokerage and/or transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain mutual funds, individual equity, and fixed income securities transactions). Clients will incur, in addition to the Firm’s investment management fee, brokerage and/or transaction fees, and, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The Firm's annual investment advisory fee shall be prorated and paid quarterly, in advance, based upon the market value of the assets on the last business day of the previous quarter. The Firm does not generally require an annual minimum fee or asset level for investment advisory services. The Investment Advisory Agreement between the Firm and the client will continue in effect until terminated by either party by written notice in accordance with the terms of the Investment Advisory Agreement. Upon termination, the Firm shall refund the pro-rated portion of the advanced advisory fee paid based upon the number of days remaining in the billing quarter. Potential Conflict of Interest: If the client desires, the client can engage certain Firm’s representatives in their individual capacities as registered representatives of MMAS, a FINRA member broker-dealer and an affiliate of the Firm, and/or in their individual capacities as licensed insurance agents, to implement investment recommendations on a commission basis. In this case, MMAS receives 12b-1 payments or insurance commission compensation, including trailing compensation, directly from the fund company or insurance carriers during the period that the client maintains the mutual fund investment or insurance policies. MMAS will pay a portion of the 12b-1 payments or commissions, as applicable, to the Firm’s representatives. The sale of commission products by the Firm’s representatives is limited and not material to the Firm’s advisory operations. However, the recommendation that a client may purchase a commission product from MMAS presents a conflict of interest, as the receipt of commissions provides an incentive to recommend investment or insurance products based on commissions received, rather than on a particular client’s need. No client is under any obligation to purchase any commission products from MMAS. When the Firm’s representatives sell an investment or insurance product on a commission basis, the Firm does not charge an advisory fee in addition to the commissions paid by the client for such product. When providing services on an advisory fee basis, the Firm’s representatives do not also receive commission compensation for such advisory services (except for any 12b-1 payments or insurance commission compensation, including trailing compensation received as discussed above). However, a client may engage the Firm to provide investment management services on an MMA Asset Management LLC Firm Brochure - Retail Page 8 of 15  advisory fee basis and separate from such advisory services purchase an investment or insurance product from the Firm’s representatives on a separate commission basis. Clients may purchase investment or insurance products recommended by the Firm through other, non-affiliated broker dealers or agents. The Firm does not receive more than 10% of its revenue from advisory clients because of commissions or other compensation for the sale of investment or insurance products it recommends to its clients. We strive to recognize the success of our professionals and present some representatives, at times, with cash bonus and non-cash awards and recognitions, which can be interpreted as a type of incentive. Some of our professionals are eligible to receive cash bonus or non-cash benefits based on the totality of many different performance factors. These bonuses, awards and benefits present a conflict of interest due to the incentive professionals have to generate more revenues for the Firm. To mitigate this conflict, we operate a formal performance appraisal and reward system, designed to take many factors into account (i.e., not only success in achieving revenue goals) when determining an individual’s remuneration and non- cash benefits. At times, third-party providers give our professionals gifts up to a total value of $100 per provider per year, consistent with industry regulations. At times, our professionals receive invitations to attend training events and seminars or participate in virtual learning programs, where travel expenses, accommodation, or training expenses are paid for by the sponsoring fund company. This creates a conflict of interest to the extent that this causes our professionals to prefer those third parties that provide these non-cash incentives. We address these conflicts of interest by requiring that prospective attendees seek approval prior to attending such events, by monitoring key policies and deploying mandatory training to personnel, and by disclosing our practices to ensure you make a fully informed decision. In addition to the mitigation efforts described above, the Firm has policies, procedures, and codes in place to minimize the above conflicts, including our Code of Ethics “The Greater Good”, personal securities trading policies, gifts and entertainment policies and outside business activity policies. Please see Item 11 of this brochure for a discussion of our code of ethics, participation or interest in client transactions and personal trading. The Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Mutual Fund Share Class Selection / Mutual Fund and Exchange Traded Fund No Transaction Fee Networks Mutual Funds typically offer multiple share classes available for investment based upon certain eligibility and/or purchase requirements. For instance, in addition to the more commonly offered retail mutual fund share classes (typically, Class A, B and C shares), mutual funds may also offer institutional, or advisor share classes (the “lower cost share classes”) or other share classes that are designed for purchase in an account enrolled in investment advisory programs. These lower cost share classes usually have a lower expense ratio than other shares classes. In addition, lower cost share classes often do not charge a 12b-1 fee. The Firm will utilize the most appropriate mutual fund share classes for its portfolio allocations available to it. Regardless, clients may still be invested in funds with higher internal expenses when no lower cost share classes for a fund is available at the custodian or the client is not eligible due to investment minimums or other requirements. Clients, when participating in certain sponsored programs or our management services, should understand that a transaction charge for mutual fund and exchange traded fund (“ETF”) purchases and redemptions may occur in accordance with the appropriate custodial agreement. The applicable transaction charge varies depending on the amount of recordkeeping fees received by the custodian / broker-dealer from the mutual fund or ETF and/or whether the sponsor of the mutual fund or ETF participates in a No Transaction Fee (“NTF”) Network. When an NTF mutual fund or ETF is purchased in a client’s account, the NTF fund’s sponsor directs a payment to the custodian / broker-dealer on behalf and for the benefit of the client that is used exclusively as a credit to defray the bona fide transaction charge obligations of the client’s account. When an NTF fund is sold, the custodian / broker-dealer waives the transaction charge to the investment adviser representative (“IAR”). Each custodian which provides execution and custodial services to the Firm has a version of an NTF fund network specific to them and could vary across custodians. Clients should understand the cost to the IAR of transaction charges may be a factor the IAR considers when selecting securities and determining whether to place transactions in accounts. Specifically, the IAR has a financial incentive to select NTF funds to avoid paying or to lower the transaction charges. While these transaction charges are not passed to the Client, this does create a conflict of interest. Clients should consider this conflict when monitoring the purchase of NTF funds as all such conflicts may have an impact on the investment performance of accounts. MMA Asset Management LLC Firm Brochure - Retail Page 9 of 15  Clients also should be aware that NTF funds may have higher ongoing internal expenses that can be used to offset payments made by sponsors for transaction charge waivers, and this can reduce the investment returns over time relative to other share classes of the same fund. Certain Funds (“SWM Eligible Funds”) in the Strategic Wealth Management (“SWM”) program contain 12b-1 fees. The list of available mutual funds in SWM is selected by LPL Financial, the program manager. In the SWM program, there are certain SWM Eligible Funds available for each fund family. In certain instances, the best available fund may be a share class containing a 12B-1 fee. The Firm does not receive or accept 12b-1 fees on advisory accounts; any 12b-1 fees generated through these funds will be retained by the custodian. Item 6 Performance-Based Fees and Side by Side Management The Firm does not receive performance-based fees (fees based on a share of capital gains on or capital appreciation of your assets). Item 7 Types of Clients The Firm provides investment and non-investment consulting services to individuals, business entities, trusts, estates, and charitable organizations. The Firm provides information in a separate disclosure brochure for its advisory services to institutional clients. If clients would like more information on other advisory services, clients should contact the Firm for a copy of the disclosure brochure that describes those services or programs or go to www.adviserinfo.sec.gov. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss The Firm utilizes any one or more of the following methods of security analysis:  Charting – (analysis performed using patterns to identify current trends and trend reversals to forecast the direction of prices) Fundamental – (analysis performed on historical and present data, with the goal of making financial forecasts)   Technical – (analysis performed on historical and present data, focusing on price and trade volume, to forecast the direction of prices) The Firm utilizes any one or more of the following investment strategies when implementing investment advice given to clients: Long Term Purchases (securities held at least a year)   Short Term Purchases (securities sold within a year) Trading (securities sold within thirty (30) days  Investment Risk Investing in securities involves risk of loss that clients should be prepared to bear. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Firm) will be profitable or equal any specific performance level(s). The Firm’s methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risks. To perform an accurate market analysis the Firm must have access to current/new market information. The Firm has no control over the dissemination rate of market information; therefore, unbeknownst to the Firm, certain analyses may be compiled with outdated market information, severely limiting the value of the Firm’s analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable and/or profitable investment opportunities. The Firm’s primary investment strategies - Long Term Purchases, Short Term Purchases, and Trading - are fundamental investment strategies. However, every investment strategy has its own inherent risks and limitations. For example, longer term investment strategies require a longer investment period to allow for the strategy to potentially develop. Shorter term investment strategies require a shorter investment period to potentially develop but, because of more frequent trading, may incur higher transactional costs when compared to a longer-term investment strategy. Trading, an investment strategy that requires the purchase and sale of securities within a thirty (30) day investment period, involves a very short investment period but will incur higher transaction costs when compared to a short- t e r m investment strategy and substantially higher transaction costs than a longer-term investment strategy. MMA Asset Management LLC Firm Brochure - Retail Page 10 of 15  Currently, the Firm primarily allocates client investment assets among various individual equity and fixed income securities, mutual funds and/or exchange traded funds (“ETFs”) (including inverse ETFs and/or mutual funds that are designed to perform in an inverse relationship to certain market indices), on a discretionary and non-discretionary basis in accordance with the client’s designated investment objective(s). As disclosed above, the Firm utilizes, when appropriate, long and short mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. Considering these enhanced risks/rewards, a client may direct the Firm, in writing, not to employ any or all such strategies for his/her/their/its accounts. Our investment approach keeps the risk in mind. Strategies employed by the Firm can face the following risks: Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the originating country for the investment. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Mutual Fund Risk: The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. ETF Risk: Performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a brief time later. Item 9 Disciplinary Information Prior to the acquisition of the Firm by Marsh & McLennan Agency LLC in 2019, a management person of the Firm consented in 2016 to a Financial Industry Regulatory Authority (FINRA) order in which the individual agreed to neither admit nor deny participation in recommending a private securities transaction without prior approval of an unaffiliated broker-dealer the individual was associated with at that time. The order imposed on that individual a monetary penalty and a six-month suspension from association with a FINRA member firms. The order, however, did not affect the Firm’s investment advisory activities or that individual’s activities as an investment advisor representative (IAR) of the Firm. The Firm itself has not been the subject of any disciplinary action. MMA Asset Management LLC Firm Brochure - Retail Page 11 of 15  Specific information related to any IAR of the Firm will be detailed within their ADV Part 2B Brochure Supplement, and for those who additionally have FINRA securities registrations, on FINRA BrokerCheck at www.brokercheck.finra.org. Any information about disciplinary matters applicable to advisory affiliates of the Firm also is available on the SEC’s website at www.adviserinfo.sec.gov or at FINRA’s web site at http://www.finra.org. Item 10 Other Financial Industry Activities and Affiliations a. Other Financial Industry Activities The Firm is owned by Marsh & McLennan Agency LLC, a licensed insurance agency. The Firm and MMA Securities LLC (“MMAS”) are affiliated companies whose ultimate parent is Marsh & McLennan Companies, Inc. MMAS is a SEC registered investment adviser and general securities broker-dealer and a FINRA and SIPC member firm. MMAS primarily engages in investment advisory and consulting services to employer-sponsored retirement plans . No client is under any obligation to purchase products or engage the services of MMA or MMA Securities LLC. Clients are reminded that they may purchase insurance and securities products through other, non-affiliated entities. Additionally, certain of the Firm’s representatives, in their individual capacities, are licensed insurance agents, and, when appropriate, recommend the purchase of certain insurance-related products on a commission basis. b. Affiliations Marsh & McLennan Agency LLC Marsh & McLennan Agency LLC (“MMA”), a licensed insurance agency, is the direct owner of the Firm. Both the Firm’s and MMA’s ultimate parent company is Marsh & McLennan Companies, Inc. MMA Securities LLC MMA Asset Management and MMA Securities LLC are affiliated investment advisory firms under common ownership of MMA Asset Management LLC’s ultimate parent, Marsh & McLennan Companies, Inc. Mercer Investments LLC and Mercer Global Investments Canada Limited Mercer Investments LLC and Mercer Global Investments Canada Limited are affiliated investment advisory firms under common ownership of MMA Asset Management LLC’s ultimate parent, Marsh & McLennan Companies, Inc. Precept Advisory Group LLC Precept Advisory Group LLC is an affiliated advisory firm under common ownership with the Firm’s ultimate parent company, Marsh and McLennan Companies, Inc. For the disclosures of Precept Advisory Group LLC, please refer to its Form ADV Part 2A brochure which may be obtained at www.adviserinfo.sec.gov. Item 11 Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading The Firm has adopted a stringent Code of Ethics, which sets out high ethical standards of conduct for our employees consistent with our duty of loyalty, fairness, and good faith toward our clients. The Code of Ethics has specific sections regarding insider trading, protecting confidentiality, compliance with federal and state securities laws, avoiding and identifying conflicts of interest, and personal securities transactions. A copy of this Code of Ethics is available upon request. Code of Ethics includes policies and procedures regarding personal securities transactions. The procedures require the reporting of transactions by our employees, ongoing monitoring of the transactions and the prohibition on the use of material non-public information. We do not recommend clients transact in securities in which we have a material financial interest. At times, the Firm and/or representatives of the Firm buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where the Firm and/or representatives of the Firm are able to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. As indicated above, to mitigate this conflict, the Firm has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of the Firm’s supervised employees. Associated and supervised persons will provide services to entities considered publicly traded at certain times. In order to mitigate the actual conflicts of interest that will arise from these relationships, persons who service these relationships or supervise those efforts, are prohibited from transacting in any securities of the publicly traded entity during the entirety of the servicing relationship. The publicly traded entities are maintained on a “watch list” and MMA Asset Management will monitor the personal trading accounts of access persons via technology solutions to monitor and address potential violations to this prohibition. MMA Asset Management LLC Firm Brochure - Retail Page 12 of 15  Item 12 Brokerage Practices Neither our firm nor our related person(s) have authority to determine, without specific client consent, the broker- dealer/custodian to be used in any securities transaction or the commission rate to be paid. If the client requests that the Firm recommend a broker-dealer/custodian for execution and/or custodial services (exclusive of those clients that may direct the Firm to use a specific broker- dealer/custodian), we typically recommend that investment management accounts are to be maintained at Schwab or LPL (members of FINRA/SIPC). Prior to engaging the Firm to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with the Firm setting forth the terms and conditions under which we shall manage the client's assets and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Clients are permitted to select custodians other than Schwab or LPL, upon the approval of the Firm. Factors that the Firm considers in recommending Schwab, LPL or another broker-dealer/custodian include historical relationship with the Firm, financial strength, reputation, execution capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid by the Firm‘s clients shall be in accordance with the Firm’s duty to seek best execution, at times, a client will pay a commission that is higher than another qualified broker-dealer might charge to affect the same transaction where the Firm determines, in good faith, that the commission/transaction fee is reasonable. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although the Firm will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are exclusive of, and in addition to, the Firm’s investment management fee. The Firm’s best execution responsibility is qualified if securities that it purchases for client accounts are mutual funds that trade at net asset value as determined at the daily market close. Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, the Firm receives from Schwab, LPL or another broker-dealer/custodian, investment platform and/or mutual fund sponsor, without cost (and/or at a discount) support services and/or products, certain of which assist the Firm to better monitor and service client accounts maintained at such institutions. Included within the support services that are obtained by the Firm at times are investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by the Firm in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products assist the Firm in managing and administering client accounts. Others do not directly provide such assistance but rather assist the Firm to manage and further develop its business enterprise. As a result of receiving such products and/or services for reduced or no cost, our firm has an incentive to continue to place client trades through broker-dealers that offer those products and services. This incentive conflicts with the clients' interest of obtaining the lowest commission rate available. Therefore, our firm must determine in good faith, that transaction costs are reasonable in relation to the value of the services provided by such executing broker-dealers. Our firm examined this potential conflict of interest when deciding to enter relationships with Schwab and LPL. We have determined that these relationships are in the best interest of our firm’s clients and satisfies our client obligations, including our duty to seek best execution. There is no corresponding commitment made by the Firm to Schwab, LPL or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products because of the above arrangement. We periodically review Schwab, LPL and other broker-dealer/custodians including their historical relationships with the Firm, financial strengths, reputations, execution capabilities, pricing, research, and services. We will change our recommendation and arrangement if recommending Schwab or LPL is no longer consistent with our client’s best interest. The Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above arrangement. The Firm does not receive outside referrals from broker-dealers and typically does not accept directed brokerage arrangements (when a client requires that account transactions be affected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and the Firm will not seek better execution services or prices from other broker-dealers or be able to "batch" the client's transactions for execution through other broker-dealers with orders for other accounts managed by the Firm. As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. MMA Asset Management LLC Firm Brochure - Retail Page 13 of 15  If the client directs the Firm to effect securities transactions for the client's accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through the Firm. Higher transaction costs adversely impact account performance. Transactions for directed accounts typically are executed following the execution of portfolio transactions for non-directed accounts. To the extent that the Firm provides investment management services to its clients, the transactions for each client account typically will be affected independently, unless the Firm decides to purchase or sell the same securities for several clients at approximately the same time. When appropriate, although not obligated to do so, the Firm typically combines or “bunches” such orders to seek best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients any differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Although such concurrent authorizations could be either advantageous or disadvantageous to any one or more accounts, the transactions are effected only when our firm believes that to do so will be in the best interest of the included accounts. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. In any given situation, the Firm attempts to allocate trade executions in the most equitable manner possible, considering client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non- arbitrary methods of allocation. The Firm does not receive any additional compensation or remuneration because of such aggregation. Item 13 Review of Accounts The Firm’s representatives conduct account reviews on an ongoing basis, with the frequency determined by the client. Most clients select quarterly reviews, while some receive semi-annual or annual reviews. All clients are advised that it remains their responsibility to advise the Firm of any changes in their investment objectives and/or financial situation. All clients are encouraged to review investment objectives and account performance with the Firm on an annual basis. The Firm conducts account reviews on an other than periodic basis upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections and client request. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. The Firm also provides, where applicable, a written periodic report summarizing account activity and performance. Item 14 Client Referrals and Other Compensation We do not receive an economic benefit from a non-client for providing investment advice or advisory services to our clients other than those set forth in Item 12 provided by Schwab. The total compensation received by the Firm is only based on the amount of adviser fee agreed to by the Firm and the client. Please refer Item 10 for the disclosure of the client referral agreement between MMAS and us, under which MMAS will identify and contact prospective clients that MMAS believes are appropriate for the Firm in accordance with Rule 206(4)-1 of the Advisers Act. Item 15 Custody The Firm can have its advisory fee for each client debited by the custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. The Firm may also provide a written periodic report summarizing account activity and performance. Clients who have their advisory fees debited directly from their custodial accounts are urged to compare any written statement provided by the Firm with the account statements received from the account custodian to ensure that the proper advisory fee has been deducted from their custodial account. Please also note that the account custodian does not verify the accuracy of the advisory fee calculation. MMA Asset Management LLC Firm Brochure - Retail Page 14 of 15  Item 16 Investment Discretion The client can determine to engage the Firm to provide investment advisory services on a discretionary basis. Prior to the Firm assuming discretionary authority over a client’s account, the client shall be required to execute Investment Advisory Agreement, naming the Firm as the client’s attorney and agent in fact, granting the Firm full authority to buy, sell, or otherwise effect investment transactions involving the assets in the client’s name found in the discretionary account. Clients who engage the Firm on a discretionary basis may, at any time, impose restrictions, in writing, on the Firm’s discretionary authority. (i.e., limit the types/amounts of securities purchased for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe the Firm’s use of margin, etc.). Item 17 Voting Client Securities receive proxies The Firm does not vote client securities. Accordingly, we have not adopted a proxy voting policy. Clients will or other solicitations directly from their custodian. We do not provide advice with respect to securities solicitations. Item 18 Financial Information The Firm will not require you to prepay more than $1,200 in fees six months or more in advance of receiving services, therefore we are not required to provide a balance sheet. We must disclose any financial condition that could impair our ability to meet our contractual commitments to you, and whether we have been the subject of a bankruptcy proceeding. We have no financial condition to disclose to you and have never been the subject of a bankruptcy proceeding. MMA Asset Management LLC Firm Brochure - Retail Page 15 of 15 

MMA Asset Management LLC Form ADV Part 2A 161 Washington Street, Suite 1200, Conshohocken, PA 19428 Telephone: 610-684-3200 Website: marshmma.com/us/solutions/asset-management.html March 27, 2025 Last Revised on March 30, 2024 This brochure provides information about the qualifications and business practices of MMA Asset Management LLC (“MMA AM”). If you have any questions about the contents of this brochure, please contact us at 212-345-5000. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. You can find more information about MMA Asset Management LLC on the SEC’s website at www.adviserinfo.sec.gov. References herein to MMA Asset Management LLC as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training. 1  Item 2 Material Changes Within 120 days of the end of MMA AM’s fiscal year, we will provide you with a summary of material changes, if any, describing only material changes to this Brochure since the last annual update. In addition, if material changes occur throughout the year, we will promptly furnish you with a summary of those changes. Any summary of material changes will also include instructions for you to obtain a complete copy of the Brochure at no charge if you wish. There have been no material changes made to MMA AM’s Brochure since its last annual updating amendment filing on March 30th, 2024. Full Brochure Available Clients wishing to receive a complete copy of our current Brochure can request a copy at no charge by contacting its investment adviser representative or the Compliance Department at: 212-345-5000. Additional information about MMA AM also is available on the SEC’s website at www.adviserinfo.sec.gov. 2  Item 3 Table of Contents 1. Cover Page .......................................................................................................................................... cover 2. Material Changes ................................................................................................................................. 2 3. Table of Contents ................................................................................................................................. 3 4. Advisory Business ................................................................................................................................ 4 5. Fees and Compensation ...................................................................................................................... 5 6. Performance-Based Fees and Side-by-Side Management ................................................................. 7 7. Types of Clients .................................................................................................................................... 7 8 Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 7 9. Disciplinary Information ........................................................................................................................ 8 10. Other Financial Industry Activities and Affiliations ............................................................................... 8 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................... 9 12. Brokerage Practices ............................................................................................................................. 9 13. Review of Accounts .............................................................................................................................. 9 14. Client Referrals and Other Compensation ........................................................................................... 10 15. Custody ................................................................................................................................................ 10 16. Investment Discretion ........................................................................................................................... 10 17. Voting Client Securities ........................................................................................................................ 10 18. Financial Information ............................................................................................................................ 10 3  Item 4 MMA AM’s Advisory Business MMA Asset Management LLC (“MMA AM” or the “Firm”) is a limited liability company with headquarters in Conshohocken, PA. The Firm is owned by Marsh & McLennan Agency LLC (“MMA”), which is an indirect wholly owned subsidiary of Marsh & McLennan Companies, Inc. (“MMC”). MMC is a public corporation listed on the New York, Chicago, and London stock exchanges (ticker symbol: MMC). MMC’s website address is www.marshmclennan.com. The Firm began conducting business in 2009 and became registered as an investment adviser firm in November 2010. MMA AM provides investment advisory and consulting services to employer-sponsored defined benefit or defined contribution retirement plans, corporations, not-for-profit institutions, foundations, endowments and charities. These services include comprehensive consulting services by assisting plans in establishing and/or maintaining a consistent and ongoing documented process of prudent oversight and due diligence. Our investment services to plans regulated by the Employee Retirement Income Security Act (“ERISA”) include non-discretionary investment advisory services where we make investment recommendations as a co-fiduciary under Section 3(21) of ERISA. At the request of ERISA plan sponsors, we also provide discretionary investment management services as an ERISA 3(38) investment manager wherein we make investment decisions on behalf of the plan sponsor. MMA AM provides information in a separate disclosure brochure for its other advisory services to retail investors. If clients would like more information on our other services and programs, clients should contact MMA AM for a copy of the disclosure brochure that describes those services and programs or go to www.adviserinfo.sec.gov. Overview of Our Services to Employer-Sponsored Retirement Plans MMA AM offers a range of investment advisory and retirement plan consulting services to retirement plan sponsors and their participants. These services include: Investment Services Provided by MMA AM under Agreement     Preparation of Investment Policy Statement. MMA AM will prepare an investment policy statement (“IPS”) for review and acceptance by the Client based upon consultation with Client to ascertain Client’s investment objectives, policies, and constraints. [For 3(38) services, MMA AM requires that MMA AM and Client agree on the terms of the Investment Policy Statement]. Performance Monitoring and Reporting. MMA AM will monitor the Plan’s investments and/or investment managers according to the guidelines outlined in the IPS and, when applicable, the continued compliance of the Plan’s investments with the “broad range” requirement in the Regulations promulgated under Section 404(c) of ERISA. MMA AM will also prepare investment performance reports based upon information derived from statements provided by the Client and/or the Plan’s recordkeeper. MMA AM will not make recommendations or report on company stock or self-directed brokerage accounts if these investment options are available to participants. Investment Recommendations. Consistent with the policies outlined in the IPS, MMA AM will recommend, for selection by Client, [or, for 3(38) services, select from time to time,] specific investments to be held by the Plan or offered as investment options in participant- directed plans. MMA AM will also recommend possible replacements if an existing investment is no longer suitable and, if requested, will assist the Plan in transitioning to the replacement option selected by the Client. [For 3(38) Services, MMA AM will have the authority and responsibility to provide instructions to the recordkeeper with respect to such changes in the Plan’s investment options. MMA AM will not have any power or authority regarding whether to include any company stock as an investment option under the Plan or to offer participants a self-directed brokerage account, mutual fund window, or other similar arrangement.] Selection of Qualified Default Investment Alternative. Consistent with the IPS and for ERISA Plans, MMA AM will recommend [or, for 3(38) Services, select and monitor on an ongoing basis] an investment fund product or model portfolio meeting the definition of a “Qualified Default Investment Alternative” (“QDIA”) in ERISA Regulation §2550.404c-5(e)(3). Non-Investment Services Provided by MMA AM under Agreement   Plan Committee Services. MMA AM will assist Client in the creation and operation of a duly appointed Committee to oversee specified aspects of the Plan. Where requested, MMA AM will also provide educational training for the Plan’s named fiduciaries and Committee members, including guidance with respect to their fiduciary duties. If desired, a draft retirement committee charter will also be provided as needed. Fee Benchmarking. MMA AM will perform an analysis of all fees and expenses related to the Plan, its service providers and its investments, and provide a written report with findings and recommendations. 4   Plan Optimization Consulting. MMA AM will make recommendations for improving the administration or operation of the Plan. The client understands and agrees that any such recommendations shall be for the sole and exclusive benefit of the Plan’s participants and that MMA AM will not provide Client with advice on the formation or termination of the Plan. The Plan’s named fiduciaries understand and agree they shall have the exclusive duty to determine whether any of the Services provided hereunder constitute settlor activities that cannot be paid from Plan assets.  Request for Proposals/Plan Vendor Search. At a fee as agreed to in advance by the parties, MMA AM will manage the preparation, distribution, and evaluation of requests for proposal (“RFP”), interview finalists, and provide support services for the conversion to the selected vendor. As desired by the Client, MMA AM will distribute the initial RFP to vendors on behalf of the Client. This service may include an additional billed charge to the Client based on the number of vendors to which RFPs are provided. Education Services (where elected by the Client)  Enrollment Meetings: MMA AM will assist Client in enrolling Plan participants in the Plan, including conducting enrollment meetings.  Group Meetings: MMA AM agrees to have a retirement educator attend an agreed upon number of in-person and/or virtual group meetings during a calendar year to deliver the education service. Additional day(s) for group meetings can be made available for an additional agreed upon billed amount. These meetings include investment education meeting(s) for Plan participants consistent with the guidelines of Department of Labor Interpretive Bulletin 96-1.  One-on-One Participant Meetings: MMA AM agrees to make a retirement educator available to conduct an agreed upon number of days for one-on-one meetings with participants.  Webinars: MMA AM agrees to conduct an agreed upon number of days of participant webinars to include topics to be mutually determined by the Client and MMA AM. MMA AM provides investment services specific to needs of each client. Prior to providing investment services, MMA AM ascertains each client’s particular investment objective(s). MMA AM makes recommendations with respect to a client’s asset allocation or fund managers consistent with their designated investment objective(s). Currently, MMA AM primarily advises with respect to plan assets allocated to mutual funds, bank collective trust funds, insurance company general and separate account products and exchange traded funds. Clients can, at any time, impose written restrictions on MMA AM’s services. As of December 31, 2024, in the aggregate, MMA AM had approximately $ 364,799,465 in regulatory assets under management ("RAUM") on a discretionary basis and $ 350,442,631 in RAUM on a non-discretionary basis, with respect to individual clients (including high net worth individuals), employer-sponsored retirement plans, corporations and other institutional clients. As of December 31, 2024, the retirement plans to which MMA AM provided investment advisory services had over $9.3 billion in assets under advisement. Item 5 Fees and Compensation Our Fees Our fees for plan consulting and investment advisory services (whether we are engaged as a non-discretionary adviser or as a discretionary adviser with respect to plan investments) are determined through one or more of the methods mentioned below:  A fixed annual fee,  Per capita fee  Asset-based fees, or  Hourly fees at pre-established rates. A "per capita fee" is a fee based on the number of participants in a retirement plan, and such fees typically are charged quarterly. Plan sponsors either pay the per capita fees on behalf of the participants, or pass them along to be paid by each plan participant. If the per capita fees are passed along to each participant, those fees are deducted directly from the assets within each plan participant's retirement account. The per capita fee is a fixed amount for each plan participant, irrespective of the amount of assets within each plan participant's account. Accordingly, if a plan sponsor requires each plan participant to pay the per capita fee, then certain plan participants would pay disproportionately for the services depending on their account balance. As the number of plan participants increases to certain pre-determined thresholds under the agreement with the plan sponsor, the amount charged per capita will be reduced. An “asset based fee” is a fee based on an annual percentage of plan assets paid on a quarterly basis. 5  Clients have the option to make investment products available in a plan for plan participants to purchase through other brokers or agents not affiliated with MMA AM. The client can choose its provider and is under no obligation to accept any provider recommended by MMA AM. Our fees are negotiable. The specific fees and the manner in which fees are charged by MMA AM are set forth in your agreement with us. Expenses such as travel will be billed separately to clients at cost, unless otherwise agreed to in the client agreement. Our fees are dependent on such factors as the size of the client’s portfolio, the number of plan participants, the specific work required by our agreement, the location of the client and whether travel is required, and the number of meetings the client requires. As a result, we do not have a standard fee schedule or table that applies to all clients. We generally require a minimum annual fee of $10,000 to provide ongoing investment advisory services. Our hourly fees range between $250 and $750 per hour. Our Billing Methods Our fees for investment advisory and consulting services are typically billed on a quarterly basis in arrears. We do not require payment of client fees in advance. Our billing methods vary, at times, based on specific agreements between us and clients. If MMA AM serves for less than the complete period, its fees will be calculated and will be payable on a pro-rata basis for the period for which it has served as an investment adviser. Upon termination, any unearned fees that have already been paid will be refunded to the client. MMA AM will be entitled to payment of all fees and reimbursement of expenses incurred through the effective date of termination. Certain plan product vendors may set up so-called “Reimbursement Accounts” for their plans. A Reimbursement Account contains reimbursed or forfeited fees by the vendor either due to discounts or excess fees that are unassigned by the vendor. These amounts are often placed in a Reimbursement Account that the plan can use to pay for plan expenses. If the client has a Reimbursement Account, the client has the option to direct that MMA Securities’ advisory fees be paid from the assets in the Reimbursement Account. In this case the advisory fee charged to the client by MMA AM will be paid by the vendor at the direction of the client. Other Fees and Costs Incurred by You All fees paid to us for advisory or consulting services are separate from the fees and expenses charged to you or the plan by the plan administrator and to shareholders of mutual fund shares by the mutual funds or by the investment adviser managing the portfolio. Our fees do not include fees charged by plan vendors and other plan service providers but you will incur brokerage and other transaction costs and will be responsible for other fees that are charged directly to you or the plan by the applicable vendor or provider. Clients should review and consider the fees charged by us, as well as the fees charged by any plan vendor or service provider (e.g., investment companies, insurance companies, transfer agents, custodians, and administrators) to evaluate the advisory service that MMA AM is providing. Some investments (such as mutual funds) impose additional fees that will reduce the value of the investment over time. A complete explanation of the expenses charged by the mutual funds is contained in each mutual fund’s prospectus. Please see Item 12 of this brochure for a discussion of our brokerage practices. Additional Compensation Received by Our Professionals Certain of our professionals are also appointed as insurance brokers. In these capacities, these individuals, when appropriate, recommend insurance products to institutional clients and receive additional compensation if products are purchased through the insurance companies with which these individuals are appointed. Thus, a potential conflict of interest exists between the interests of these individuals and those of the advisory clients, creating an incentive for them to recommend products based on the compensation received, rather than on a client’s needs. These professionals manage the potential conflict of interest by ensuring that all recommendations are appropriate for a client’s specific needs. Clients are advised they have the option to purchase insurance products through insurance brokers not affiliated with our firm. We strive to recognize the success of our professionals and present some representatives, at times, with cash bonus and non-cash awards and recognitions, which can be interpreted as a type of incentive. Some of our professionals are eligible to receive cash bonus or non-cash benefits based on the totality of many different performance factors. These bonuses, awards and benefits present a conflict of interest because the professionals have an incentive to generate more revenues for MMA AM. To mitigate this conflict, we operate a formal performance appraisal and reward system, designed to take many factors into account (i.e., not only success in achieving revenue goals) when determining an individual’s remuneration and non-cash benefits. 6  At times, third-party providers give our professionals gifts up to a total value of $100 per provider per year, consistent with industry regulations. At times, our professionals receive invitations to attend training events and seminars or participate in virtual learning programs, where travel expenses, accommodation, or training expenses are paid for by the sponsoring fund company. This creates a conflict of interest to the extent that this causes our professionals to prefer those third parties that provide these non-cash incentives. We address these conflicts of interest by requiring that prospective attendees seek approval prior to attending such events, by monitoring key policies and deploying mandatory training to personnel, and by disclosing our practices to ensure you make a fully informed decision. In addition to the mitigation efforts described above, MMA AM has policies, procedures and codes in place to minimize the above conflicts, including our Code of Ethics “The Greater Good”, personal securities trading policies, gifts and entertainment policies and outside business activity policies. Please see Item 11 of this brochure for a discussion of our code of ethics, participation or interest in client transactions and personal trading. Item 6 Performance-Based Fees and Side by Side Management MMA AM does not receive performance-based fees (fees based on a share of capital gains on or capital appreciation of your assets). Item 7 Types of Clients MMA AM provides investment advisory and consulting services to employer-sponsored defined benefit or defined contribution retirement plans, corporations, not-for-profit institutions, foundations, endowments and charities. MMA AM provides information in a separate disclosure brochure for its advisory services to retail investors. If clients would like more information on other advisory services, clients should contact MMA AM for a copy of the disclosure brochure that describes those services or programs or go to www.adviserinfo.sec.gov. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis The investment strategy for a specific client (usually a retirement plan sponsor) is dependent upon the objectives stated by the client during consultations. Our clients typically execute an investment policy statement that documents their objectives and desired investment strategy. Our clients can change these objectives at any time. Investing in securities involves risk of loss that clients should be prepared to bear. Currently, MMA AM primarily advises with respect to plan assets allocated to mutual funds, bank collective trust funds, insurance company general and separate account products and exchange traded funds.MMA AM provides investment analysis through custom designed software that incorporates a rigorous multi-point screening process that evaluates comparative fund performance. We review an investment option’s return, risk, fund characteristics, expense, style consistency, volatility, and performance in both up and down markets. In addition to these and other quantitative factors, we review such qualitative factors as manager tenure, fund size, organizational stability and personnel qualifications. Material Risks MMA AM’s investment strategies and methods of analysis do not present any significant or unusual risks. Performance evaluation reports are based upon custodial data and information obtained and analyzed from a wide variety of sources including investment data aggregation services such as Morningstar. Although the information collected by MMA AM is believed to be reliable, MMA AM does not independently verify this information. While we follow a rigorous process in making investment recommendations, investments are inherently risky. Investing in any securities, including mutual funds, involves a risk of loss of both income and principal. Risks associated with mutual fund analysis include the risk that a fund’s performance track record may not be an accurate predictor of its future investment performance. Additionally, mutual fund managers may deviate from their stated investment style, objective or strategy. Also, a fund’s expenses may increase, which would adversely affect fund performance. Recommendations to investments could involve certain risks such as: Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. 7  This type of risk is caused by external factors independent of security’s underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the originating country for the investment. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Mutual Fund Risk: The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. ETF Risk: Performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a brief time later. Item 9 Disciplinary Information Prior to the acquisition of the Firm by MMA in 2019, a management person of the Firm consented in 2016 to a Financial Industry Regulatory Authority (FINRA) order in which the individual agreed to neither admit nor deny participation in recommending a private securities transaction without prior approval of an unaffiliated broker-dealer the individual was associated with at that time. The order imposed on that individual a monetary penalty and a six-month suspension from association with an unaffiliated FINRA member firm. The order, however, did not affect the Firm’s investment advisory activities or that individual’s activities as an investment advisor representative (IAR) of the Firm. Any information about disciplinary matters applicable to advisory affiliates of the Firm also is available on the SEC’s website at www.adviserinfo.sec.gov or at FINRA’s web site at www.finra.org. Item 10 Other Financial Industry Activities and Affiliations a. Other Financial Industry Activities The Firm is owned by MMA, a licensed insurance agency. The Firm and MMA Securities LLC (“MMAS”) are affiliated companies whose ultimate parent is Marsh & McLennan Companies, Inc. MMAS is a SEC registered investment adviser and general securities broker-dealer and a FINRA and SIPC member firm. MMAS primarily engages in investment advisory and consulting services to employer-sponsored retirement plans. 8  No client is under any obligation to purchase products or engage the services of MMA or MMA Securities LLC. Clients are reminded that they may purchase insurance and securities products through other, non-affiliated entities. Additionally, certain of the Firm’s representatives, in their individual capacities, are licensed insurance agents, and, when appropriate, recommend the purchase of certain insurance-related products on a commission basis. b. Affiliations Marsh & McLennan Agency LLC Marsh & McLennan Agency LLC (“MMA”), a licensed insurance agency, is the direct owner and affiliate of MMA AM. MMA Securities LLC MMA AM and MMA Securities LLC are affiliated investment advisory firms under common ownership of MMA Asset Management LLC’s ultimate parent, Marsh & McLennan Companies, Inc. Mercer Investments LLC and Mercer Global Investments Canada Limited Mercer Investments LLC and Mercer Global Investments Canada Limited are affiliated investment advisory firms under common ownership of MMA Asset Management LLC’s ultimate parent, Marsh & McLennan Companies, Inc. Precept Advisory Group LLC Precept Advisory Group LLC is an affiliated advisory firm under common ownership with the Firm’s ultimate parent company, Marsh and McLennan Companies, Inc. For the disclosures of Precept Advisory Group LLC, please refer to its Form ADV Part 2A brochure which may be obtained at www.adviserinfo.sec.gov. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MMA AM has adopted a stringent Code of Ethics, which sets out high ethical standards of conduct for our employees consistent with our duty of loyalty, fairness and good faith toward our clients. The Code of Ethics has specific sections regarding insider trading, protecting confidentiality, compliance with federal and state securities laws, avoiding and identifying conflicts of interest, and personal securities transactions. A copy of this Code of Ethics is available upon request. Our Code of Ethics also includes policies and procedures regarding personal securities transactions. These procedures require the reporting of securities transactions by our employees, ongoing monitoring of securities transactions and the prohibition on the use of material non-public information. We do not recommend clients transact in securities in which we have a material financial interest. At times, the Firm and/or representatives of the Firm buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where the Firm and/or representatives of the Firm are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. As indicated above, to mitigate this conflict, the Firm has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of the Firm’s supervised employees. Associated and supervised persons will provide services to entities considered publicly traded at certain times. In order to mitigate the actual conflicts of interest that will arise from these relationships, persons who service these relationships or supervise those efforts, are prohibited from transacting in any securities of the publicly traded entity during the entirety of the servicing relationship. The publicly traded entities are maintained on a “watch list” and MMA Securities will monitor the personal trading accounts of access persons via technology solutions to monitor and address potential violations to this prohibition. Item 12 Brokerage Practices With respect to institutional clients, we do not select or recommend a broker-dealer for a client’s transactions. We do not have any formal or informal soft-dollar arrangements and do not receive any soft-dollar benefits. Item 13 Review of Accounts MMA AM’s representatives conduct account reviews on an ongoing basis, with the frequency determined by the client. Most clients select quarterly reviews, while some receive semi- annual or annual reviews. All clients are advised that it remains their responsibility to advise MMA AM of any changes in their investment objectives and/or financial situation. All clients are encouraged to review investment objectives and account performance with MMA AM on an annual basis. MMA AM conducts 9  account reviews on an other than periodic basis upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections and client request. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. MMA AM also provides, where applicable, a written periodic report summarizing account activity and performance. Item 14 Client Referrals and Other Compensation We do not receive an economic benefit from a non-client for providing investment advice or advisory services to our institutional clients. The total compensation received by MMA AM is only based on the amount of adviser fee agreed to by MMA AM and the client. Item 15 Custody With respect to institutional clients, MMA AM does not maintain custody of client funds or securities. Item 16 Investment Discretion The client can determine to engage the Firm to provide investment advisory services on a discretionary basis. Prior to the Firm assuming discretionary authority over a client’s account, the client will be required to execute a written agreement, naming the Firm as the client’s attorney and agent in fact, granting the Firm full authority to buy, sell, or otherwise effect investment transactions involving the assets in the client’s name found in the discretionary account. Clients who engage the Firm on a discretionary basis may, at any time, impose restrictions, in writing, on the Firm’s discretionary authority. (i.e. limit the types/amounts of particular securities purchased for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe the Firm’s use of margin, etc). With respect to our advisory services to employer-sponsored retirement plans, MMA AM does not take discretion in regard to any client assets or accounts unless we are engaged as an ERISA 3(38) fiduciary pursuant to a written agreement. In such instances MMA AM accepts discretionary authority through a written advisory agreement with the client. Our discretionary authority is typically limited by the client’s Investment Policy Statement which sets out the client’s investment objectives, guidelines and strategy. Our authority as an ERISA 3(38) fiduciary is strictly limited to discretion over plan investments. Certain of our retirement plan clients have asked us to construct customized asset allocation portfolios utilizing the investment funds offered in their plan’s core investment menu. MMA AM determines the asset allocation percentages within each portfolio based on its strategy (e.g., conservative, moderate, aggressive) and determines the frequency and extent of rebalancing activity during the year. We do not manage the underlying funds, nor do we have custody of any client assets. Item 17 Voting Client Securities MMA AM does not vote client securities. Accordingly, we have not adopted a proxy voting policy. Clients will receive proxies or other solicitations directly from their custodian. We do not provide advice with respect to particular securities solicitations. Item 18 Financial Information MMA AM will not require you to pay more than $1,200 in fees six months or more in advance of receiving services, therefore we are not required to provide a balance sheet. We must disclose any financial condition that could impair our ability to meet our contractual commitments to you, and whether we have been the subject of a bankruptcy proceeding. We have no financial condition to disclose to you, and have never been the subject of a bankruptcy proceeding. 10