MORNINGSTAR INVESTMENT MANAGEMENT LLC

Morningstar Investment Management LLC Form ADV Part 2A: Firm Brochure Morningstar Retirement Advisory Services for Individuals 22 West Washington Street, Chicago, IL 60602 Phone: 312.696.6000 www.corporate.morningstar.com March 27, 2025 Item 14. Client Referrals and Other Compensation was updated to disclose that we receive compensation from unaffiliated third parties for referring their services to other advisory firms or investors and note we provide compensation to Institutional Clients to provide marketing or educational support to their financial professionals and to sponsor meetings and events for their clients. This brochure provides information about the qualifications and business practices of Morningstar Investment Management LLC. If you have any questions about the contents of this brochure, please contact us at 312.696.6000 or send an email to compliancemail@morningstar.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. We made other edits where necessary to correct grammar or punctuation, to provide clarification or further information, for consistency in terminology or content, or to improve the readability of the brochure. Additional information about Morningstar Investment Management LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Morningstar Investment Management LLC is registered with the SEC as a registered investment adviser. Registration with the SEC does not imply a certain level of skill or training. All current versions of our firm brochures are available in the Part 2 Brochures section of this record on the SEC’s website. You can also request a copy of our current brochure free of charge by contacting our Compliance Department at 312.696.6000, or by email to compliancemail@morningstar.com. In your request, please indicate the name of the company (Morningstar Investment Management) and the service brochure(s) (Morningstar Retirement Advisory Services for Individuals, Morningstar Retirement Institutional Advisory Services, or Morningstar Wealth Services) you are requesting. Item 2. Material Changes The Retirement Services for Individuals Firm Brochure dated March 2025 contains no following material changes since our last annual update dated March 25, 2024. Item 3. Table of Contents Item 4. Advisory Business ........................................................................................ 1 Item 5. Fees and Compensation ............................................................................... 4 Item 6. Performance Based Fees and Side-by-Side Management............................ 5 Item 7. Types of Clients ............................................................................................ 6 Item 8. Methods of Analysis, Investment Strategies, & Risk of Loss ........................ 6 Item 9. Disciplinary Information .............................................................................. 10 Item 10. Other Financial Industry Activities and Affiliations .................................... 10 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................... 13 Item 12. Brokerage Practices ................................................................................. 13 Item 13. Review of Accounts ................................................................................. 13 Item 14. Client Referrals and Other Compensation ................................................. 13 Item 15. Custody .................................................................................................... 14 Item 16. Investment Discretion .............................................................................. 14 Item 17. Voting Client Securities ............................................................................ 14 Item 18. Financial Information ................................................................................ 14 The non-material changes since our last annual update include: incorporated in 1999. Morningstar As applicable throughout the Firm Brochure, we noted that our subsidiary, Morningstar Investment Services, anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. Morningstar Investment Management will become the investment adviser to many of Morningstar Investment Services’ third-party financial institution clients. At the time of this change, trade recommendations for Morningstar Wealth portfolios will be communicated to non- discretionary clients after the close of the trading day and Morningstar-affiliated accounts in Morningstar Wealth strategies will be traded the next day so that no one person has an advantage over another. Item 4. Advisory Business Firm Information Morningstar Investment Management LLC (“we”, “our” or “us”) is a Delaware limited Investment liability company that was Management is a wholly owned subsidiary of Morningstar, Inc. (“Morningstar”). Morningstar is a publicly traded company (Nasdaq Ticker: MORN) with Mr. Joseph Mansueto, Executive Chairman of Morningstar, holding more than 35% of Morningstar’s outstanding shares. Because of that ownership, Mr. Mansueto is an indirect owner of Morningstar Investment Management. Item 4. Advisory Business was updated to reflect our assets under management and advisement as of December 31, 2024 and to remove references to Personalized Strategy Reports. Item 5. Fees and Compensation was updated to reflect lower fee ranges for some services and to disclose that we receive compensation from unaffiliated third parties for referring their services to other advisory firms or investors. Morningstar Investment Management is registered with the SEC under Section 203(c) of the Investment Advisers Act of 1940, as amended (“Advisers Act”). Morningstar Investment Management has filed the appropriate notices to conduct business in all 50 states, the District of Columbia, Guam, the Virgin Islands, and the Commonwealth of Puerto Rico. Morningstar Investment Management is registered with the U.S. Commodity Futures Trading Commission as a Commodity Pool Operator (“CPO”) and is a member of the U.S. National Futures Association. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss was updated to reflect the current makeup of the Morningstar Retirement Investment Policy Committee and remove information about an obsolete risk profiling methodology. Item 10. Other Financial Industry Activities and Affiliates was updated to disclose an investment in SMArtX. Morningstar Investment Management, along with other Morningstar subsidiaries authorized in appropriate jurisdiction to provide investment management and advisory services, is part of a global investment team composed of investment analysts, portfolio managers, and other investment professionals. These investment and ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  operations teams span the globe, with primary offices in Chicago, London, and Sydney. These advisory services are built on several fundamental principles: Page 2 of 14 Investment Management and an investment adviser unaffiliated with us (“Other IA”) who are each responsible for the provision of certain advice. In some instances, we have engaged an Other IA to perform portfolio construction services on our behalf as a sub-adviser (“Sub-Adviser”). Your Investment Advisory Agreement details which entity or entities are responsible for the advice you receive. Personalized. Our primary objective is to help you get on track for your retirement goals by furnishing you with a personalized strategy on asset allocation and investments. We tailor our strategy to your specific circumstances, including financial situation, future retirement goals, and risk capacity (the amount of risk you want to take to help reach your goals). If we are solely responsible for the advice provided to you, you give us responsibility for managing your retirement account. We build the asset allocation portfolios for your retirement plan and then choose from the available investment options to create the investment-specific portfolios to which you can be assigned. We communicate these investment decisions to your service provider, who implements them for your retirement account. The investment options available for your retirement account are defined by your service provider, plan sponsor, or other party chosen by your plan sponsor. Goals-Based. We recognize that a prudent strategy must be built in relation to specific goals, and we help you define those goals and develop a strategy aimed at reaching them. Diversified. While no investment strategy can ensure a profit or protect against a loss, diversifying your investments is a strategy designed to help mitigate the risk of all your investments losing money at the same time by investing in different types of investments. Our proprietary approach diversifies you across asset classes, as well as investment sectors and styles. We act as the independent “financial expert” (as defined in the Department of Labor’s Advisory Opinion 2001-09A dated December 14, 2001, commonly known as the “SunAmerica Opinion”) to other financial institutions who offer their own managed account programs to their clients. Under this service, we use the investment options available in the retirement plan or product to construct and monitor model portfolios designed for retirement investors across a broad range of risk exposure levels. Conservative. Our risk-based approach is designed to reduce the likelihood of significant losses in volatile markets. The assumptions we make about portfolio returns in our projections emphasize disciplined saving and investing rather than outsized capital market returns. Forward-Looking. Rather than relying only on historical data (which may not have any relevance to future conditions), we incorporate forward-looking estimates for assumptions about investment returns and performance behavior. Institutional-Quality. The components of our retirement advice are based on factors generally used by professional money managers and adapted to the needs of the individual investor. Under our Advisor Managed Accounts service, you give the responsibility for managing your retirement account to either (1) Morningstar Investment Management and the Other IA or (2) in those situations where a Sub-Adviser has been engaged, Morningstar Investment Management. The Other IA or Sub-Adviser is responsible for building the asset allocations for your retirement plan or product and choosing investments for the investment-specific portfolios. We then use our portfolio- assignment methodology to select an appropriate portfolio for you from those portfolios. If another financial institution or Other IA is solely or in part responsible for providing investment advice to you through Managed Accounts, you will need to obtain the financial institution’s or Other IA’s Firm Brochure for information about their services, fees, methodology, any conflicts of interest, and other important information. Please make sure you read this information carefully. Please note, in instances where a Sub-Adviser is engaged, we are responsible for the investment-specific portfolios available to you. No advisory relationship exists between you and the Sub-Adviser. Managed Accounts includes ongoing investment management of your retirement account. Your recommended account holdings are typically reviewed on at least a quarterly basis, or whenever you provide us with additional or updated information about your personal or financial situation. As necessary, we will send transaction instructions to your service provider to rebalance or reallocate your account. Advisory Services We Offer This brochure focuses on the services we provide to individual participants invested in employer-sponsored retirement plans or other retirement products, like individual retirement accounts (“IRAs”) or health savings accounts (“HSAs”) earmarked for retirement (each a “retirement account”) through Morningstar Retirement. These services are intended for citizens or legal residents of the United States or its territories and are offered through retirement plan sponsors and/or plan providers, plan administrators, retirement product providers, and/or other investment advisers (each a "service provider"). You can obtain a copy of our brochure describing our products and services in our core capabilities of asset allocation, investment selection, and portfolio construction that we offer to institutions such as asset management firms, banks, broker/dealers, consultants, insurance companies, investment advisers, investment fiduciaries, plan sponsors of retirement plans, plan providers of retirement plan services, trusts, and other business entities (“Morningstar Retirement Institutional Advisory Services” or “Morningstar Wealth Advisory Services”) by following the instructions above. You should be aware that the investment options available to your retirement account could be associated with a service provider or Sub-Adviser. In such instances, the service provider or Sub-Adviser, or their affiliate, may receive compensation based on the assets in those investments. This gives your service provider or the Sub- Adviser an incentive to make those investments available or build portfolios using those investments. Managed Accounts Under Managed Accounts, we propose an investment strategy for your retirement account based on your personal and financial situation using the information you, your plan sponsor, service provider(s) and/or an account aggregator provides to us. This strategy typically includes a retirement income goal and recommended savings level, retirement age, and asset allocation target designed to help you meet your retirement goals. After creating your personal investment strategy, we will select an investment- specific portfolio appropriate for your retirement account. We send transaction instructions to a service provider associated with your retirement account to implement the recommended retirement strategy in your retirement account. Please Note: Your service provider may not be able to process rebalancing transactions if any investment option in your retirement account has any restriction (e.g., equity wash restriction) at the time the rebalancing transaction instruction is received by the service provider. In addition, rebalancing transaction instructions may be rejected if any data validation error exists on your account. In these instances, we will work with your service provider to resolve any issues and to rebalance your retirement account as quickly as possible. In some cases, your retirement account will not be rebalanced until the next quarterly review period when all restrictions have been lifted and/or data validation errors have been corrected. If you choose the Managed Accounts service, the investment advice you receive is provided by either (1) Morningstar Investment Management or (2) Morningstar You will periodically receive progress reports reflecting your progress towards your retirement goals and other information in regard to your investments. Typically, these ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  reports are available electronically through our website on a quarterly basis. You have the option to terminate Managed Accounts at any time without penalty. Page 3 of 14 your account balance for the purchase of an annuity or other guaranteed income product. Some service providers extend Managed Accounts to those approaching or in retirement. If your service provider offers this service and you meet the retirement criteria established by your service provider, your investment strategy may include a suggested amount that you can withdraw while striving to maintain income throughout retirement. It may also include information about allocating a portion of your account balance for the purchase of an annuity or other guaranteed income product. Guidance Under Guidance, we provide information designed to help you make your own investment choices regarding your retirement account assets. Like Managed Accounts and Advice, we will propose an investment strategy based on your personal and financial situation, using the information you, your service provider, an account aggregator, and/or your plan sponsor provided to us. After creating your personal investment strategy, we provide asset allocation targets appropriate for your retirement account. Guidance is an educational, point-in-time service. Under Guidance the actual investment decisions you make are not monitored or reviewed, your retirement account is not monitored, reviewed or updated on an ongoing basis, and you do not receive updated asset allocation targets or projections. However, you can return to the service at any time to receive updated asset allocation targets and projections. Guidance is not available under the Advisor Managed Accounts service. Advice Under Advice, you are provided with information designed to help you make your own investment choices regarding your retirement account assets. Like Managed Accounts, you’ll receive a personal investment strategy, which includes asset allocation targets appropriate for your retirement account. You also receive investment-specific recommendations for your strategy using the investment options available to your retirement plan or product but unlike Managed Accounts, you are responsible for reviewing and determining whether our recommendations are suitable for you and implementing your own investment decisions. Outside Account Guidance Through Managed Accounts and Advice, you can enter information about assets in other accounts you have earmarked for use in retirement (“Outside Accounts”.) If you enter Outside Accounts, you will receive an asset allocation recommendation for those accounts as a whole. This information should not be considered advice to buy or sell a particular investment. You are responsible for determining whether any particular investment is suitable for you. If we are solely responsible for the advice provided to you under the Advice service, we build the asset allocation and investment-specific portfolios and recommend a specific portfolio for you. We build the asset allocation portfolios for your retirement plan or product and then choose from the available investment options to create the investment-specific portfolios available to you. The investments options available in your retirement plan or product are defined by your service provider, plan sponsor, or other party chosen by your plan sponsor. We act as the independent “financial expert” to other financial institutions who offer their own advice services to their clients. Under this service, we use the investment options available in the retirement plan or product to construct and monitor model portfolios designed for retirement investors across a broad range of risk exposure levels. We cannot monitor, review or update our suggestions or projections for Outside Accounts on an on-going basis, nor do we have the capability to monitor or review investment decisions you make in Outside Accounts. Because our services and recommendations depend on the completeness, accuracy, and timeliness of the information you, your service provider, plan sponsor, or an account aggregator provide, you are solely responsible for reviewing and updating your individual financial information. You are responsible for tracking your Outside Accounts and the market to be aware of any changes in the value of your Outside Accounts, and providing that information to us as changes occur. Until you do, we will continue to make recommendations for your retirement account in accordance with the information we have on file. Under our Advisor Managed Accounts service, the advice you receive is provided by (1) Morningstar Investment Management and an Other IA or (2) in those situations where a Sub-Adviser has been engaged, Morningstar Investment Management. The Other IA or Sub-Adviser is responsible for building the asset allocation and investment-specific portfolios. Morningstar Investment Management then uses our portfolio-assignment methodology to recommend an appropriate portfolio for you from those portfolios. Your Investment Advisory Agreement details which entity or entities are responsible for the advice you receive through Advice. There is no additional fee to receive an Outside Accounts recommendation, however, you could incur redemption fees, transaction costs, other investment or account level charges and expenses, and/or tax consequences for any changes in the investments in your Outside Accounts. You should consult with a professional financial adviser or tax adviser if you have any questions prior to making any investment decisions. If another financial institution or Other IA is solely or in part responsible for providing investment advice to you through Advice, you will need to obtain the financial institution’s or Other IA’s Firm Brochure for information about their services, fees, methodology, any conflicts of interest, and other important information. Please make sure you read this information carefully. recommendation; once you ByAllAccounts®, an account aggregation service offered by Morningstar, is integrated with our Managed Accounts and Advice services. ByAllAccounts gives you the option to link Outside Accounts to the Managed Accounts or Advice services so that your account balances and investment holdings are reported on your behalf. If you use ByAllAccounts, your Outside Account information can be refreshed each time you visit our service. For Managed Accounts users, we encourage you to visit our service regularly (i.e., at least once a quarter) so that we have current and accurate information about your financial situation. Note: Account availability is determined by your Outside Account’s custodian. All account custodians may not be available through ByAllAccounts. Advice provides a point-in-time receive a recommendation, the advisory relationship between you and us or, if applicable, the Other IA ends. (Please note, no advisory relationship exists between you and the Sub- Adviser, if applicable.) Under Advice, the actual investment decisions you make are not monitored or reviewed, your retirement account is not monitored, reviewed or updated on an ongoing basis, and you do not receive updated recommendations or projections. However, you can return at any time to receive new recommendations and projections. Some service providers extend Advice to those who are approaching or are in retirement. If your service provider offers this service and you meet the retirement criteria established by your service provider, your investment strategy may include a suggested amount that you can withdraw while striving to maintain income throughout retirement. It may also include information about allocating a portion of Personal Target-Date Fund Service Under the Personal Target-Date Fund Service, we propose an investment strategy consisting of an asset allocation target for your retirement account based on your personal and financial situation (e.g., age, salary, retirement account balance, and contribution rate) using the information you, your plan sponsor, and/or service provider(s). After determining your asset allocation target, we choose from the target-date funds available in your plan or product to create an investment-specific ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 4 of 14 option to retain all or a portion of the company stock. If you choose to retain your investment in the company stock, we will not be responsible for that portion of your retirement account, although we take it into consideration when creating your investment strategy. portfolio for you. Upon enrolling in the Personal Target-Date Fund Service, you give us responsibility for managing your retirement account. We communicate our investment decisions to your service provider, who implements them in your retirement account. You have the option to terminate the Personal Target-Date Service at any time without penalty. The investment options available for your retirement account are defined by your service provider, plan sponsor, or other party chosen by your plan sponsor. Morningstar Retirement Manager Morningstar Retirement Manager is an online platform designed to help retirement investors make better decisions about investing in their retirement accounts. Managed Accounts, Advice, Guidance, and the Personal Target-Date Fund Service are available through Morningstar Retirement Manager. Plan sponsors or service providers can choose to offer one or more of these services available. The Personal Target-Date Service includes ongoing investment management of your retirement account. Your recommended account holdings are typically reviewed on at least a quarterly basis, or whenever you provide us with additional or updated information about your personal or financial situation. As necessary, we will send transaction instructions to your service provider to rebalance or reallocate your account. You should be aware that the investment options available to your retirement account could be associated with a service provider. In such instances, the service provider, or their affiliate, may receive compensation based on the assets in those investments. This gives your service provider an incentive to make those investments available. The Morningstar Retirement Manager platform and/or the services offered through it can be branded under different names chosen by our service provider clients. These names include, but are not limited to, “Managed by Morningstar” (Managed Accounts), “Managed by You” (Advice), “Managed Advice” (Managed Accounts), or “Personalized Portfolios” (Managed Accounts or Advice). If you access a version of our platform with a customized name, please note that we use Managed Accounts, Advice, Guidance, Personal Target-Date Fund Service throughout this document, but the information included still applies to your service. Please contact your plan sponsor, service provider, or us if you are unsure what service option(s) apply to you. Please Note: Your service provider may not be able to process rebalancing transactions if any investment option in your retirement account has any restriction (e.g., equity wash restriction) at the time the rebalancing transaction instruction is received by the service provider. In addition, rebalancing transaction instructions may be rejected if any data validation error exists on your account. In these instances, we will work with your service provider to resolve any issues and to rebalance your retirement account as quickly as possible. In some cases, your retirement account will not be rebalanced until the next quarterly review period when all restrictions have been lifted and/or data validation errors have been corrected. Advisor Managed Accounts We use the product name “Advisor Managed Accounts” when Managed Accounts and/or Advice includes advice from (1) both Morningstar Investment Management and an Other IA or (2) Morningstar Investment Management with portfolio construction services performed on our behalf by a Sub-Adviser. The plan sponsor or service provider chooses the Other IA or Sub-Adviser and whether to offer one or both services to plan participants. As noted above, customized names (like “Personalized Portfolios”) can be used throughout the online platform instead of Managed Accounts or Advice. You will periodically receive progress reports reflecting your progress towards your retirement goals and other information in regard to your investments. Typically, these reports are available electronically through our website on a quarterly basis. Wrap Fee Programs We do not sponsor a wrap fee program, but we do provide portfolio management services to a wrap fee program offered by our subsidiary, Morningstar Investment Services LLC. This wrap fee program is scheduled to be closed around the end of the second quarter of 2025. Assets Under Management As of December 31, 2024, our discretionary regulatory assets under management (rounded to the nearest $100,000) were: Customized Services Under Managed Accounts and Advice, advice is provided based on the investment options (e.g., mutual funds, including money market funds and stable value funds, annuities, collective investment trusts, and/or exchange-traded funds) available in your retirement plan or product, as defined by your service provider or plan sponsor. Under the Personal Target-Date Fund Service, advice is provided based on the target- date funds available in your retirement plan or product, as defined by your service provider or plan sponsor. If we are responsible for investment selection, our selections are based on qualitative factors and quantitative analysis in addition to the judgment of our analysts. If an Other IA is responsible for investment selection under Advisor Managed Accounts, their selection methodology will be described in their Firm Brochure. Retirement Services to Individuals: $29,068,100,000 Investment Management Services to Institutional Clients: $36,267,000,000 Total Regulatory Asset Under Management: $65,335,000,000 Non-discretionary assets under advisement (rounded to the nearest $100,000) were: $235,870,200,000. If you choose, you may ask us to exclude specific investment options from your Managed Accounts, Advice, or Personal Target-Date Fund Service recommendations. However, if your requested restriction(s) prevent the building of an adequately diversified portfolio, you will need to remove some restrictions in order to use Managed Accounts, Advice, or the Personal Target-Date Fund Service. Item 5. Fees and Compensation Fees and Compensation Our fee is generally negotiated by your service provider or plan sponsor. The actual fee depends on a range of variables including the service used and retirement account balance. In some cases, our fee may be paid by your plan sponsor or service provider or may be part of the fees of the underlying investment options your retirement account is invested in. To view your specific fee schedule and method of paying those fees, you can access your account through our website or consult with your plan sponsor or service provider(s) for more information or if you have questions. You have the option to terminate your advisory relationship with us at any time without penalty. We believe that holding the stock of your employer greatly increases your portfolio risk, particularly in large concentrations. Prudent financial planning principles hold that any significant investment in a single stock creates a non-diversified situation in your portfolio with greater risk of investment losses. If your retirement plan or product includes your company’s stock as an investment option, and if you have a portion of your retirement account allocated to your company’s stock upon enrolling in Managed Accounts or Advice, we will recommend that you do not make additional investments in the company stock. Unless your company stock holdings are restricted due to a plan or product provision or a restriction imposed by your service provider or plan sponsor, at your direction we will decrease your allocation in your company’s stock down to zero, using the strategy outlined in your advisory agreement. You have the ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 5 of 14 Our services can be terminated without penalty at any time as outlined in your Personal Target-Date Fund Service contractual agreement. Upon termination, any earned, unpaid fees by you are due and payable. Managed Accounts. For Managed Accounts, your retirement account will be charged a fee based on the assets managed under the service in your retirement account. This fee is expressed in “basis points.” A basis point is equivalent to 0.01%; 100 basis points is equivalent to 1%. In some cases, your service provider(s) may charge an administrative user fee. Please check with your plan sponsor or service provider(s) for specific fee information for your plan. Our fee is generally less than 50 basis points and typically ranges from 8 to 50 basis points annually. For example, if your retirement account balance is around $50,000, your annual fee would be less than $250. This fee is charged monthly or quarterly, in arrears or in advance, depending on the capabilities of your service provider and are detailed in your advisory agreement with us. Your fee is calculated by applying the basis point rate to the assets in your retirement account in accordance with the terms of your agreement with us. As an example, your fee could be based on the average assets in your retirement account over the course of a quarter or based on the assets as of the month-end. In some cases, new Managed Accounts users are offered a “free look” period. During the free look period our fee will be waived for a specific timeframe, as detailed in your agreement with us. Payment For Managed Accounts and the Personal Target-Date Fund Service, your service provider will typically debit our fee from your retirement account and remit that fee to us. As noted above, in some cases, your plan sponsor or service provider will pay us for our services, or our fee will be a component of the fees charged by the investment options you are invested in. Your advisory agreement with us will include the details of how and when our fee is charged to you. Under Advisor Managed Accounts, your plan provider will typically also debit the Other IA’s fee from your retirement account and remit it to them. If you have questions about how the Other IA’s fee is assessed and remitted, please contact your plan sponsor or service provider(s). Under Advisor Managed Accounts, the Other IA charges a separate fee for their services. We are not involved in the setting or negotiation of this fee between your service provider or plan sponsor and the Other IA. This fee is a basis point fee applied to your retirement account balance (typically 0 to 30 basis points annually), or a basis point or flat annual fee charged to your plan. Please check with your plan sponsor or service(s) provider for further information about these fees. In instances where a Sub-Adviser has been engaged to undertake portfolio construction, the portfolios they create will typically consist of associated investment products in which they receive compensation based on the amount of assets invested. For example, the Sub-Adviser acts as investment adviser to mutual funds used in creating the portfolios and receives asset-based compensation from the funds related to the investment management activities they perform for the funds. Our services can be terminated without penalty at any time as outlined in your Managed Accounts contractual agreement. Upon termination, any earned, unpaid fees by you are due and payable. Other Costs in Connection with Our Advisory Services Our advisory fee is separate from fees and expenses charged by the investment options or fees that are charged by a third party, such as your service provider(s). The investment options’ fees and expenses are described in the investment’s prospectus or equivalent. These fees will generally include a management fee, other investment expenses, and possibly a distribution fee (e.g.,12b-1). Annuities typically have additional fees, such as surrender charges, mortality and expense risk charges for death benefits or payout options like guaranteed income for life, administrative fees, underlying fund expenses related to investment sub-accounts, and other charges for special features, like guaranteed minimum income benefits, principal protection, or stepped-up death benefits. In some cases, an investment option may also charge an initial or deferred sales charge. Neither us nor any of our employees receive transaction-based compensation for the investment recommendations we make. You may incur custodian, brokerage, and other transaction costs from third parties. Your plan provider or recordkeeper can provide you with specific fee information for your plan. In some cases, your service provider(s) may charge an administrative user fee. Please check with your plan sponsor or service provider(s) for specific fee information for your plan. You may have the option to purchase investment products we recommend or similar services through other investment advisers or financial professionals not affiliated with us. Advice and Guidance. We do not charge you a fee to use Advice or Guidance. However, in some cases, your service provider(s) may charge an administrative user fee. Please check with your plan sponsor or service provider(s) for your specific fee information. Compensation from Sales of Securities We do not expect, accept or receive compensation for the sale of securities, including asset-based sales charges or service fees from the sale of open-end mutual funds, used in the Managed Accounts, Advice, or Guidance services. If a Sub-Adviser has been engaged for Advice, the portfolios they create will typically consist of associated investment products in which they receive compensation based on the amount of assets invested. Revenue Sharing Arrangements We do not have any revenue sharing arrangements with any mutual funds. Personal Target-Date Fund Service. Your retirement account will be charged a fee based on the assets managed under the Personal Target-Date Fund Service in your retirement account. This fee is expressed in “basis points.” A basis point is equivalent to 0.01%; 100 basis points is equivalent to 1%. Third-Party Compensation We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. Item 6. Performance Based Fees and Side-by-Side Management We do not have performance-based fee arrangements (fees based on a share of capital gains or on capital appreciation of the assets in your account) with any qualified client pursuant to Rule 205-3 under the Advisers Act. Therefore, we do not manage any performance-based fee accounts side-by-side with non-performance- based fee accounts. Our fee is generally around 5 basis points annually. For example, if your retirement account balance is around $50,000, your annual fee would be around $25. This fee is charged monthly or quarterly, in arrears or in advance, depending on the capabilities of your service provider and are detailed in your advisory agreement with us. Your fee is calculated by applying the basis point rate to the assets in your retirement account in accordance with the terms of your agreement with us. As an example, your fee could be based on the average assets in your retirement account over the course of a quarter or based on the assets as of the month-end. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Item 7. Types of Clients In addition to the retirement services for individuals described in this brochure, we also provide investment advisory services to institutional clients such as financial institutions, third-party investment advisers, broker/dealers, consultants, investment companies, pension or profit-sharing plans, or other business entities (“Institutional Clients”). If you would like a copy of our brochure describing these services, please follow the instructions on page 1 of this brochure to access the SEC website or contact us. Page 6 of 14 and ask you to provide any additional data that wasn’t available from your service provider. Through our website or over the phone, you will be presented with an initial strategy as a starting point. You can model many scenarios by changing your retirement age, desired retirement income, social security start age, and savings rate. We will update your retirement strategy in real time to reflect any change you make. We also encourage you to provide additional account information in regard to your retirement savings such as assets you hold outside your retirement account or benefits for you or your spouse/partner in order to further personalize the recommendations. We do not provide advice on outside assets but will take those into consideration when determining the investment strategy for your retirement account assets. The Managed Account, Advice, Guidance services and the Personal Target-Date Fund Service are only available to individuals with retirement accounts. While the Managed Accounts, Advice, and Guidance services are similar in nature to the Personal Target- Date Fund Service, these services offer a more comprehensive retirement strategy and provide advice after considering the full investment lineup in your retirement plan or product, not just the target-date funds. We do not require a minimum account balance to use our services, and we generally do not impose any other conditions on your use of our services. Item 8. Methods of Analysis, Investment Strategies, & Risk of Loss Investment Philosophy Our investment philosophy is driven by the investment principles that are promoted throughout our organization. The principles are intended to guide our thinking, behavior and decision making. These principles also reflect and align with the history and foundation of Morningstar and are described above in the Firm Information section. Enrollment. Your service provider has the option to make one or more websites available to you for enrollment in Managed Accounts or the Personal Target-Date Fund Service. If you use a streamlined version of our enrollment process, you should be aware that it does not consider all information relevant to your financial situation, including some of the information discussed in this section. (For example, for Managed Accounts, the streamlined process takes into account your age, retirement account type, and the balance, fund allocation, and contributions for your retirement account as provided by your service provider.) You can access our full enrollment process at any time by logging into the Morningstar Retirement Manager platform through your service provider’s website. The full enrollment process for Managed Accounts allows you to provide us with additional information about your retirement situation and goals so that we can further customize your retirement strategy. If you have additional retirement assets outside your retirement account, have a spouse or partner you’d like us to consider, want to restrict certain securities from being used in your retirement account, or want to change suggestions made for you in the streamlined enrollment process (i.e., your savings rate), or if you want to see how changes would impact your retirement strategy, we encourage you to use our full enrollment process instead of the streamlined process. For the Personal Target-Date Fund Service, if you want to view the information your service provider gave to us about you, or you want to restrict certain securities from being used in your retirement account, we encourage you to use our full enrollment process instead of the streamlined process. Morningstar Retirement Investment Policy Committee The Morningstar Retirement Investment Policy Committee is responsible for oversight of the investment methodologies across the Morningstar Retirement’s products and services, including those described in this brochure. Members of the Morningstar Retirement Investment Policy Committee includes the Morningstar Retirement’s chief investment officers, head of advice and financial planning, head of business development and client success, head of channel strategy, head of research, director of retirement research, director of product management, head of investments for institutional and retirement solutions, and the senior director of automated portfolios management. The investment advice we offer through the products and services referenced in this brochure are provided by an investment team. Information on key members of this investment team is included in the attached Brochure Supplement. For Advisor Managed Accounts, the Other IA has their own Brochure Supplement that you should obtain and review. Analysis Methods Our Managed Accounts and Advice Analysis Methods. Where we are responsible for creating the asset allocation and investment specific portfolios used in our services, we review available quantitative data to analyze and screen the investment options available to us, which are typically constrained to a universe defined by your plan sponsor or service provider. We also apply qualitative analysis by our investment professionals, such as evaluations of investment managers, portfolios and individual investments. We combine this information with other factors—including actuarial data, stock market exposure, probability analysis, and mean-variance optimization— into a proprietary software program to analyze a complex set of market data and variables. The result is an advanced model, or robo-adviser, which can provide investment recommendations and a projection of different outcomes. use a combination of portfolios and customizations as part of a larger portfolio We construction process. For Managed Accounts and Advice, we generate hundreds of unique portfolios (ranging from conservative to aggressive) for each retirement plan or product using a customized approach to blending traditional asset allocation models with liability-driven investing and decumulation strategies. Which asset classes and sub-asset classes are used to build these model portfolios is dependent on the specific investment options available to us. Using this model, we develop an investment strategy tailored to your investment goals, as described below, and assign you to one of those portfolios. Data While Managed Accounts, Advice, Guidance, and the Personal Target-Date Fund Service use a powerful robo-advice program for evaluating your goals, the appropriateness of the advice you receive is dependent on the personal information we receive from you, your service provider, and/or the account aggregation services described in the Outside Account Guidance section above. While we strive to provide the most accurate and timely economic forecast and financial information, we depend on you to provide the most accurate assessment of your financial status and goals. We will collect relevant personal and financial data about you (and, if applicable, your spouse or partner) that, depending on the service you’re enrolled in, can include your age, current savings rate, employer contributions (if applicable), retirement income goal, state of residence, retirement account balance, projected or actual social security amount, any outstanding loans from your retirement account, balances of any other investment accounts intended for retirement, expected pensions, and balances in company stock. The Personal Target-Date Service makes assumptions about Social Security Income, potential salary growth, inflation rates, retirement income goal, and your risk capacity. This information is collected in order to personalize the advice you receive. We start with all of the available information we receive from your service provider and/or you and then make assumptions about certain pieces of information. You have the ability to review and refine some of these assumed data points through our website or over the phone. These assumptions can have a significant impact on the strategies created for you and are related to social security income, salary growth, inflation rates, retirement income goal, and risk capacity. We combine this In creating your strategy for Managed Accounts, Advice, or Guidance, the more information you provide to us, the more personalized the investment strategy we are able to deliver. We collect information your service provider is able to provide to us ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  information with other factors into a proprietary software program that can provide investment recommendations and a projection of different outcomes. Page 7 of 14 balance, additional cash flows and life expectancy. This retirement strategy may include some or all of the following: Retirement Income Goal (accumulation phase) We define your retirement income goal as the projected amount of money that you will need during retirement. We calculate this amount based on your current income, adjusted to reflect the estimated dollar value at your retirement age. Typically, we use an amount equal to 100% of your take-home pay (although some plan providers request we use a different rate, e.g., 80% of your gross pay), and then project the value of that amount at your retirement age to determine your retirement income goal. You have the option to change this projected retirement income goal amount. We use a concept called total wealth to determine your risk capacity. This helps us determine an appropriate target risk level for your retirement account by considering your risk exposure in all your other accounts that you’ve told us about that are earmarked for retirement. Our total wealth methodology accounts for your financial capital (total saved assets and tradeable assets such as stocks and bonds) as well as your human capital (future earnings and savings potential). Using this methodology, we assign a target risk level based on your total economic worth. If made available to you by your service provider, you can also complete an optional risk tolerance questionnaire that could result in further adjustments to your investment strategy. Income Outlook (accumulation phase) We define the income outlook as a projection of the annual income that you may receive during retirement. We base this on an annualized view of the investment wealth you accumulate, combined with social security benefits and any pension or other income you might receive. In general, human capital is a large percentage of total wealth for younger investors, which means attaining the overall market portfolio allocation (the optimal portfolio for every investor based upon each asset’s current market value) typically requires younger investors to allocate their financial portfolio more heavily in equities. As the investor ages, the human capital portion of total wealth declines, which means that older investors generally should consider investing their financial portfolios more heavily in fixed-income investments, resulting in a more conservative risk capacity. Total Retirement Income (in-retirement phase) If your service provider offers the services described above while you are in retirement, we define your total retirement income as the projected amount of money, typically at some level of probability that you can expect to receive on an annual basis in order to maintain income throughout retirement. If made available to you through your service provider, you also have the option to complete a risk tolerance questionnaire, which helps you think about your attitude towards risk. Risk tolerance is a personality trait based partly on genetics and partly on life experience. Typically risk tolerance decreases slowly with age and may be changed by major life events. We encourage you to retest your risk tolerance every two to three years and after any major life event. IMPORTANT: When we determine the income projections described above, these projections are based on hypothetical performance data and do not represent actual or guaranteed results. Your projections may vary over time with each additional use of our service. After completing the risk tolerance questionnaire, your score will account for a 20% weighting in our target equity determination for your investment strategy, with the other 80% weighting coming from your total wealth determination. The target risk level changes over time to help ensure you are still investing in a portfolio for your specific situation and risk capacity. In general, we try to provide a smooth transition from an aggressive equity portfolio to a more conservative fixed portfolio as you near retirement. We believe in a creating a customized long-term asset allocation based on your risk capacity. Changes in your financial situation, such as the addition of Outside Accounts, pension benefits, or contribution rates, are likely to result in a change to your asset allocation. In addition, changes to your personal situation, such as the addition of a spouse or partner or a different retirement age, could also impact your asset allocation. We encourage you to update the information you have on file with us in such events, so that we can update your asset allocation accordingly. If you use Managed Accounts, we will typically review portfolios on a quarterly basis to determine if market shifts require us to rebalance your account. On an annual basis, we will re-run our analysis of your future wealth forecast. If you use Advice or Guidance, we encourage you to re-enter our website on a periodic or as-needed basis, in order to review your information and receive an updated strategy. At a minimum, we recommend that you receive an updated strategy on an annual basis. Your strategy considers the following items when building a target equity allocation for your retirement account, but they are restricted from our investment selection process: outside investment accounts you own, assets designated as “restricted” or “frozen” by your employer, assets you have chosen to retain in company stock, funds affiliated with Morningstar or its subsidiaries, or custom funds created specifically for your plan. Other IA’s Analysis Methods. For Advisor Managed Accounts where an Other IA is responsible for reviewing and selecting from the investment options within your plan, the Other IA’s methodologies and methods of analysis can be found in their Other IA’s Firm Brochure. If made available by your service provider, you have the option to complete an annuity questionnaire. Through this questionnaire you can indicate whether you would like to receive a recommendation for how much of your retirement account could be invested in an annuity while still aligning with our investment strategy. We do not recommend, endorse, or sell any specific annuity products as part of this allocation recommendation and do not provide advisory or discretionary investment management services to assets invested in an annuity. If requested by your plan sponsor or service provider, we will integrate access to an annuity marketplace or provider into our platform to help you facilitate your decision to purchase an annuity, if you choose to do so. In such instances, the annuity or annuities available to you are chosen by your plan sponsor or service provider and we had no role in selecting those annuities. An annuity allocation recommendation is only available through the Managed Accounts service. Sub-Adviser’s Analysis Methods. For Advisor Managed Accounts where a Sub- Adviser has been engaged to perform portfolio construction services, the Sub-Adviser will build portfolios based on our pre-determined equity targets using investment options they designate based on their methods of investment analysis. (As noted above, the Sub-Adviser will generally use their associated investment options and will not select from the full universe of investments available to you. To do this, your plan sponsor or service provider must make the Sub-Adviser’s investment options available as part of your retirement plan lineup or product universe.) These portfolios will be blended to create the portfolios available to you, as described in the section above on our analysis methods. It is our responsibility to ensure the portfolios available to you meet appropriate standards, therefore, we reserve the right to modify the portfolios provided by the Sub-Adviser. Our Personal Target-Date Fund Service Analysis Methods. To choose investments for your retirement account enrolled in our Personal Target-Date Fund Service, we use If you are accumulating for retirement savings, our investment strategy is generally based on information such as your retirement account balance, expected retirement age, contribution rate and other preferences you may have. If you have already retired, and if your service provider offers Managed Accounts or Advice while you are in retirement, our strategy is based on information such as your current account ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 8 of 14 Advice, and Guidance users can adjust the benefit amount and start age if desired, however, the start age must be between 62 and 70. Note: Spouse/partner social security estimates are not available in the Personal Target-Date Fund Service. Salary Growth To estimate future salary, we use a salary growth curve based on academic research rather than assuming a single, fixed growth rate. This curve takes into account the fact that salaries tend to grow most rapidly for young employees, peak around age 51, and then slightly decline later in life. If you are retired, we assume you are no longer collecting a salary. your age to narrow down the target-date funds we consider for your retirement account to no more than five funds. These funds include the target-date fund vintage associated with your age and the next two vintages further from and closer to the assumed retirement age of 65. The target-date fund options available to us are typically chosen by your plan sponsor or service provider. (For example, if the target- date fund associated with your age is the 2050 vintage, we’ll consider the 2040, 2045, 2050, 2055, and 2060 vintages.) We combine this information with other factors—including actuarial data, stock market exposure, probability analysis, and mean-variance optimization—into a proprietary software program to analyze a complex set of market data and variables. The result is an advanced model, or robo- adviser, that can provide investment recommendations and a projection of different outcomes. Retirement Age For Managed Accounts, Advice, and Guidance, we assume a default retirement age of 65, or your current age plus one year if you are older than 65. You have the option to change this to a different retirement age. We start with the available information we receive from your service provider and then make assumptions about certain pieces of information. You have the ability to review and refine some of these assumed data points through our website or over the phone. These assumptions can have a significant impact on the strategies created for you and are related to social security income, salary growth, inflation rates, retirement income goal, and risk capacity. We combine this information with other factors into our proprietary software program. The Personal Target-Date Fund Service defines retirement age as the age at which you will begin withdrawing money from your primary retirement account. We assume a default retirement age of your ”Full Retirement Age”, as defined by the Social Security Administration. Your Full Retirement Age depends on your birthday, or your current age plus one year if you are older than your Full Retirement Age. As discussed in the Our Managed Accounts and Advice Analysis Methods section above, we also use the total wealth concept to determine your risk capacity with Personal Target-Date Fund Service. Using this methodology, we assign a target risk level based on your total economic worth. The target risk level changes over time to help ensure you are still investing in a portfolio for your specific situation and risk capacity. In general, we try to provide a smooth transition from an aggressive equity portfolio to a more conservative fixed portfolio as you near retirement. Income Projections For Managed Accounts, Advice, and Guidance, your income projection is the level of annual income we project you have at least a 70% chance of achieving and is calculated for both your current strategy and our proposed strategy. We use forecasts for investment returns, portfolio risk, and correlation for each of 12 asset classes and an average expense ratio for each asset class to estimate investment fees. The projections consider different scenarios for your life span, based on standard published mortality tables (based on the Society of Actuaries Individual Annuity Mortality (IAM) table). We assume that your risk capacity (and corresponding asset allocation) will change over time, generally growing more conservative as you approach retirement, and that your savings rate will not change. Note: Income projection assumptions do not apply to the Personal Target-Date Fund Service. Your strategy only considers the assets in your retirement account when building a target equity allocation for your retirement account. It does not consider any outside investment accounts you own, assets designated as “restricted” or “frozen” by your employer, assets you have chosen to retain in company stock, funds affiliated with Morningstar or its subsidiaries, or custom funds created specifically for your plan. We believe in a creating a customized long-term asset allocation based on your risk capacity. Changes in your financial situation, such as a change in your contribution rate, are likely to result in a change to your asset allocation. In addition, changes to your personal situation, such as a different retirement age, could also impact your asset allocation. We encourage you to update the information you have on file with us in such events, so that we can update your asset allocation accordingly. We will typically review portfolios on a quarterly basis to determine if market shifts require us to rebalance your account. On an annual basis, we will re-run our analysis of your future wealth forecast. Estimated Tax We estimate federal and state income, and capital gains taxes based on marginal tax rate calculations. Tax data is updated annually based on U.S. Internal Revenue Code (IRC) and similar state tax data. We use income data for you, as well as for your spouse/partner, if applicable, to estimate federal and state tax exposure. Tax exposure is appropriately reduced for pretax deferrals, tax-deferred capital gains, and yield and distribution of Roth proceeds. Based on the information we know about you, we estimate your tax exposure, but do not include all tax considerations. Our recommendations are made without taking into consideration potential tax consequences and we do not provide tax advice. Potential tax consequences can exist. We encourage you to consult with a tax professional about these and other tax consequences. Note: Estimated Tax assumptions do not apply to the Personal Target- Date Fund Service. Key Assumptions We make assumptions about certain pieces of information that have a significant impact on the strategy we will create for you. In particular, these assumptions relate to inflation rates, retirement income goals, federal/state/capital gains/other taxes (for Managed Accounts, Advice, and Guidance), risk capacity, social security amounts (if you are not yet retired), and salary growth. Inflation Assumptions When projecting the growth of various income sources and expenses, we use a variety of different inflation rates. These rates are reviewed and updated annually by our research team. For example, a long-term inflation rate is used to help calculate retirement need and cash flows and a simulated inflation rate is used for Social Security calculations, pensions, and cost of living adjustments. Additionally, different inflation rates are used for major expenses. We believe that our multifaceted approach to calculating inflation results in more realistic and more accurate projections compared with using one set rate. IRS Limitations and Application of Penalties We incorporate all IRS contribution limits, eligibility requirements, and withdrawal penalties into the retirement strategies. Social Security We can incorporate Social Security for you and, if applicable, your spouse/partner, using an estimate based on calculations/formulas from the Social Security Administration or a number you input from your Social Security statement. Social Security payments are inflated using a simulated cost-of-living allowance designed to replicate the actual Social Security Administration (“SSA”) formulas and are applied at the maximum benefit age as defined by the SSA. We account for reduction in payments while working in retirement, increases in benefits for the spouse 50% rule and increased benefits for the surviving spouse 100% rule. The program assumes you complete all applications required to collect the maximum benefit. We also take Social Security into consideration while analyzing income replacement. We default to the age at which you will receive full benefits from the SSA. Managed Accounts, ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  responsible for choosing the Sub-Adviser but Morningstar Page 9 of 14 If applicable under Advisor Managed Accounts, your plan sponsor or service provider is Investment Management must agree to engage and is responsible for ongoing monitoring of the Sub-Adviser. In making portfolio recommendations, we are limited to those portfolios created by the Sub-Adviser but have discretion to reject or edit those portfolios if we feel necessary. Brokerage Account Some retirement plans allow participants to maintain a brokerage account within the plan. If your plan allows this option, you will be responsible for managing and monitoring those assets. We do not manage brokerage account assets; however, if you provide us with detailed information on the holdings within the brokerage account, our Managed Accounts, Advice, and Guidance methodology will consider these holdings in developing an appropriate investment strategy for your retirement account. If you do not provide detailed information, our methodology will assume that the balance in the brokerage account is 45% stocks and 55% fixed income. Risk of Loss and Strategy Risk We determine a risk strategy for you based on several factors, such as your current age and time until retirement, gender, salary, total current wealth, deferral rate, and retirement goals. If you have retired or are approaching retirement, and if you have the opportunity to purchase an annuity, the risk strategy also considers your longevity and liquidity needs. Your risk level corresponds to an asset mix, or the combination of stocks, bonds and cash, that will serve as the basis for our recommendations of specific funds appropriate for you. Information Sources Where we are responsible for investment selection, our global resources used in the formulation of our advisory services go down to our roots—the data and analysis from Morningstar, Inc. that form the base of our investment process. This expansive, in-house network of global data and investment analysis spans asset classes and regions to help drive timely new ideas. Morningstar or its affiliates have more than 800 analysts and makes data available on more than 600,000 investment options and 5.2 million privately-held companies. The extensive data, analysis, and methodologies from these resources, along with external research reports, data, and interviews with investment managers are combined with financial publications, annual reports, prospectuses, press releases, and SEC filings to serve as the basis of our primary sources of information. For some of our services, we combine this information with other factors—including actuarial data, stock market exposure, probability analysis, and mean-variance optimization—into a proprietary software program to analyze a complex set of market data and variables that results in an advanced model that can provide investment recommendations and a projection of different outcomes. You should remember that investments in securities involve market risk, risk of loss, and other risks, and will not always be profitable. We do not guarantee that the intended objectives of our recommendations will result in achieving your retirement income goal. We cannot guarantee that negative returns can or will be avoided in any of our recommendations. We do not represent or guarantee that our investment recommendations can or will predict future results, will successfully identify market highs or lows, or will result in a profit or protect clients from loss. An investment’s future performance may differ substantially from its historical performance, which is no indication of future performance. A security’s investment return and an investor’s principal value will fluctuate so that, when redeemed, an investor’s shares may be worth more or less than their original cost. We are unable to predict or forecast market fluctuations or other uncertainties that may affect the value of any investment. Security Type Risks Mutual Funds and Collective Investment Trusts Investments in mutual funds and collective investment trust (CITs) funds involve risk, including loss of principal as a result of changing market and economic conditions and will not always be profitable. Our investment strategy for Managed Accounts, Advice, and Guidance is intended to provide you with an investment portfolio that is diversified across various asset classes and appropriate based on your facts and circumstances. A collective investment trust may also be called a commingled or collective fund. CITs are tax-exempt, pooled investment vehicles maintained by a bank or trust company exclusively for qualified plans, including 401(k)s, and certain types of government plans. CITs are unregistered investment vehicles subject to banking regulations of the Office of the Comptroller of the Currency (OCC), which means they are typically less expensive than other investment options due to lower marketing, overhead, and compliance-related costs. CITs are not available to the general public but are managed only for specific retirement plans. Our investment strategy for the Personal Target-Date Fund Service is intended to provide you with an investment portfolio that is diversified across various asset classes and appropriate based on your facts and circumstances using only the target- date funds made available through your retirement plan or product. An investment in a target date fund is not guaranteed, and you may experience losses, including losses near, at, or after the target date. There is no guarantee that the fund will provide adequate income at and through your retirement. Target-Date Funds An investment in a target date fund is not guaranteed, and you may experience losses, including losses near, at, or after the target date. There is no guarantee that the fund will provide adequate income at and through your retirement. Asset allocation and diversification are investment strategies which spread assets across various investment types for long-term investing. However, as with all investment strategies, these strategies do not ensure a profit and do not guarantee against losses. Capital market assumptions are forecasts which involve known and unknown risks, uncertainties, and other factors which may cause the actual results to differ materially and/or substantially from any future results, performance, or achievements expressed or implied by those projections for any reason. Past performance does not guarantee future results. Money Market Funds A money market fund may impose a fee upon the sale of shares or may temporarily suspend your ability to sell shares if the fund’s liquidity falls below a required minimum because of market conditions or other factors. An investment in a money-market vehicle is not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. For most money market funds, their sponsor has no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to the fund at any time. Although some money market funds seek to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. It is possible to lose money by investing in money market funds. Income projections used in our services are based on hypothetical performance data and do not represent actual or guaranteed results. Projections may vary over time and with each use of our service. Stable Value Funds and Guaranteed Investment Contracts (“GICs”) The interest rate on a stable value fund or GIC is typically only guaranteed for a certain amount of time and may vary with changing market conditions. Withdrawal fees or penalties, sometimes substantial, may be charged if you decided to move money out of a stable value fund or GIC. Stable value funds and GICs are less likely to provide long-term protection against inflation, as compared to other options. If applicable under Advisor Managed Accounts, your plan sponsor or service provider is responsible for choosing and monitoring the Other IA. In making our portfolio recommendations, we are limited to those portfolios created by the Other IA. We do not have any input over the choice of the Other IA, nor do we review the Other IA’s asset allocation or portfolio creation methodologies or investment selection process. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 10 of 14 through expected future returns, and asset allocations. Capital market assumptions are updated on an annual basis. We also update our methodologies with updated tax limits on an annual basis. Asset allocation and advice methodologies are updated when there is a regulatory change that requires an update or when research we have completed warrants enhancing our asset allocation process or advice methodology. Item 9. Disciplinary Information We are required to disclose all materials facts in regard to any legal or disciplinary events that would influence a potential client to engage us. We do not have any material legal or disciplinary events to disclose. Exchange-traded Funds ETFs, like all investments, carry certain risks that may adversely affect their net asset value, market price, and/or performance. An ETF’s net asset value (NAV) will fluctuate in response to market activity. Because ETFs are traded throughout the day and the price is determined by market forces, the market price you pay for an ETF may be more or less than the NAV. Because ETFs are not actively managed, their value may be affected by a general decline in the U.S. market segments relating to their underlying indexes. Similarly, an imperfect match between an ETF’s holdings and those of its underlying index may cause its performance to not match the performance of its underlying index. Like other concentrated investments, an ETF with concentrated holdings may be more vulnerable to specific economic, political, or regulatory events than an ETF that mirrors the general U.S. market. Item 10. Other Financial Industry Activities and Affiliations Morningstar Investment Management is a wholly owned subsidiary of Morningstar. Our offerings center around advisory services in our core capabilities of asset allocation, investment selection, and portfolio construction that we offer to individual investors and institutions. Our portfolio managers and their team members who are responsible for the day-to- day management of our portfolios are paid a base salary plus a discretionary bonus. The bonus is fully or partially determined by a combination of the employee’s business unit’s overall revenue and profitability, Morningstar’s overall annual revenue and profitability, and the individual’s contribution to the business unit. For many of our advisory services, the universe of investment options from which we make our investment selections is defined by our Institutional Client. In some cases, this universe of investment options includes proprietary investment options of the Institutional Client. To mitigate any actual or potential conflict of interests presented by this situation, we subject all investment options to the same quantitative and qualitative investment selection methodology, based on several factors, including performance, risk, and expense so that the proprietary nature of an investment option does not influence our selection. Annuities An annuity is a tax-deferred investment structured to convert a sum of money into a series of payments over time. Annuity contracts have limitations and are not viewed as short-term liquid investments. An insurance company’s fulfillment of a commitment to pay a death or living benefit, a schedule of payments, a fixed investment amount guaranteed by the insurance company, or another form of guarantee depends on the claims-paying ability of the issuing insurance company. Any such guarantee does not affect or apply to the investment return or principal value of the separate account and its subaccount(s). The financial ratings quoted for an insurance company do not apply to the separate account and its subaccount(s). The insurance company offering an annuity will charge several fees to investors, including annual contract charges that compensate the insurance company for the cost of maintaining and administering the annuity contract, mortality and expense risk charges based on a percentage of a subaccount’s assets to cover costs associated with mortality and expense risk, and administration fees that are based on a percentage of a subaccount’s assets to cover the costs involved in offering and administering the subaccount. An annuity investor can also be charged a front-end load by the insurance company on their initial contribution, ongoing fees related to the management of the fund and surrender charges (which can be substantial) if the investor makes a withdrawal prior to a specified time. If the annuity subaccount is invested in a money-market fund, the money market fund is not FDIC-insured, may lose money, and is not guaranteed by a bank or other financial institution. Annuities can be complicated, and an investor should carefully read the insurance company’s offering material to understand how a specific annuity’s return will be determined. We provide consulting or investment management services to Institutional Clients that offer registered or pooled investment products, such as mutual funds, variable annuities, collective investment trusts, or model portfolios. To mitigate the conflict of interest presented by our role in these investment products, we exclude such investment products from the universe of investment options from which we make our recommendations to other clients. Variable Annuities have a rate of return that varies with underlying investment options in the market, and do not include a guarantee from the insurance company that you will earn a return. Fixed annuities have a predetermined rate of return an investor earns and a fixed income payout that is guaranteed by the issuing investment company and may be immediate or deferred. Payouts may last for a specific period or for the life of the investor. Investments in a deferred fixed annuity grow tax-deferred with income tax incurred upon withdrawal, and do not depend on the stock market. Fixed annuities typically do not have cost-of-living payment adjustments and are regulated by state insurance commissioners. Morningstar Funds Trust is registered with the SEC as an open-end management investment company under the Investment Company Act of 1940, as amended, and has retained us as its investment adviser. The funds within the Morningstar Funds Trust will be used as the underlying holdings for certain Morningstar Wealth portfolios, most notably the mutual fund model portfolios series. The funds within the Morningstar Funds Trust can only be utilized in connection with the model portfolios and separately managed accounts offered by Morningstar Wealth. To mitigate the conflict of interest presented by our role in these investment products, we exclude such investment products from the universe of investment options from which we make our recommendations to other clients, including participants in Managed Accounts and Advice. For more information about the Morningstar Funds Trust, please request a copy of our Institutional Advisory Services brochure and visit http://connect.rightprospectus.com/Morningstar to view the prospectus. We are registered as a Commodity Pool Operator with the Commodity Futures Trading Commission. Some our employees are registered with the National Futures Association as principals or associated persons. Fixed indexed annuities, also called equity index annuities, are a combination of the characteristics of both fixed and variable annuities. Fixed indexed annuities offer a predetermined rate of return like a fixed annuity, but they also allow for participation in the stock market, like a variable annuity. Fixed indexed annuities are typically risker and offer the potential for greater return than fixed annuities, but less so than a variable annuity. Investments in a fixed indexed annuity grow tax-deferred with income tax incurred upon withdrawal and are regulated by state insurance commissioners. Methodology Updates Our capital market assumptions and investment policy committees typically meet monthly. These committees have oversight for their respective areas of expertise. If any of these committees makes an adjustment, the changes are thoroughly reviewed and tested before being implemented. These changes are manifested in portfolios We receive compensation for our research and analysis activities (e.g., research papers) from a variety of financial institutions including large banks, brokerage firms, insurance companies, and mutual fund companies. In order to mitigate any actual or potential conflicts of interest that arise from this service, we ensure that our research and analytical activities are non-biased and objective given our business relationships. Employees who provide research and analysis for clients are separate from our sales and relationship manager staff in order to mitigate the conflict of interest that an ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  employee may feel pressure to present results in such a way as to maintain existing or gain new business. In addition, methodology updates that impact investment recommendations or decisions for Morningstar Retirement services are peer reviewed by the Morningstar Retirement Investment Policy Committee, which mitigates the conflict of interest by providing checks and balances so that no employee can act unilaterally in making recommendation decisions. Page 11 of 14 Morningstar Retirement and Morningstar Wealth have set up service teams composed of employees of our affiliate and located at our affiliate’s office in Mumbai, India. In addition, Morningstar Retirement has a team composed of employees of our affiliate located at our affiliate’s office in Toronto, Canada. We compensate our affiliates for services rendered via intercompany charges. The services and compensation will be governed by intercompany agreements. This compensation will likely be lower than compensation negotiated with non-affiliated firms for the same or similar services. To mitigate any conflict of interest between us and our affiliates we have established dual reporting lines for employees on these teams so that such employees report up to employees of Morningstar Investment Management. We’ve also established information security boundaries and technology separation to protect our non-public information and Morningstar’s compliance department monitors the personal trading activity of these employees. Morningstar Research Services LLC is also a wholly owned subsidiary of Morningstar and an investment adviser registered under the Advisers Act. Morningstar Research Services’ offerings center around the production of investment research reports and investment consulting services to financial institutions/institutional investors who themselves are registered with and governed by a regulatory body. Conflicts of interests between us and Morningstar Research Services are mitigated by such things as the maintenance of separate legal entities and dual reporting/organization lines, and the utilization of physical (i.e., separate office “neighborhoods”) and technological separation. Morningstar Research Services also maintains a committee structure so as to limit any unilateral decisions. Morningstar’s compliance department monitors the personal trading activities of Morningstar Research Services’ employees. Our investment professionals provide portfolio construction and ongoing monitoring and maintenance for the Morningstar Wealth portfolios within the Morningstar Wealth Platform offered by our subsidiary, Morningstar Investment Services and to third-party financial institutions on Morningstar Investment Services’ behalf. While the same or similar portfolios are offered by us to our Institutional Clients, we do not believe these responsibilities create any material conflicts of interest for our clients. In order to mitigate any perceived conflict of interest, when we offer discretionary services for Morningstar Wealth’s portfolios, transactions for our clients are placed at the same time as transactions for Morningstar Investment Services’ discretionary clients as part of block trades. We have procedures in place to ensure that trades are allocated in such a manner as to not favor one client over another. When we offer portfolios on anon-discretionary basis to third-party Institutional Clients, our Institutional Clients receive trade recommendations just after trades are placed for discretionary clients, due to our heightened fiduciary responsibilities to our discretionary clients. In addition, all non-discretionary clients are notified of transaction recommendations after the close of the trading day, so that no one such client has an advantage over another. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. Morningstar Investment Management will become the investment adviser to many of Morningstar Investment Services’ third-party financial institution clients. Trade recommendations will be communicated to non- discretionary clients after the close of the trading day and Morningstar-affiliated accounts in Morningstar Wealth portfolios will be traded the next day so that no one person has an advantage over another.) We invested in the Series D funding round of SMArtX Advisory Solutions, a managed account technology provider and architect of the SMArtX turnkey asset management platform. This investment will assist in the build out of SMArtX’s development capabilities, which could benefit us or our parent company. Daniel Needham, our co- president serves on the board of SMArtX. We have the option to engage Morningstar Research Services to perform investment manager due diligence and/or selection services on our behalf as a sub-adviser or consultant. The notification to and authorization by the Institutional Client to our engaging Morningstar Research Services as a sub-adviser is addressed in our agreement with the Institutional Client. On such occasions, we compensate Morningstar Research Services for services rendered via an intercompany charge. The services and compensation will be governed by an intercompany agreement. This compensation will likely be lower than compensation negotiated with non- affiliated financial institutions/institutional investors for the same or similar services. Morningstar Research Services’ employees who are engaged to provide manager due diligence and/or selection services are prohibited from using non-public/confidential information obtained because of their engagement in its investment research reports and/or investment consulting services to clients, including us. When we, along with Morningstar and/or our other affiliates offer services to the same client, we have the option to enter into a bundled agreement with the client that encompasses all or part of those services. Additional fee(s) for such product(s) or service(s), if required, will be set forth in our agreement with the client. In these situations, clients pay a fee directly to us and each such affiliate for its products or services, or as part of a joint fee schedule which encompasses all services. Morningstar Research Services provides information to the public about various securities, including managed investments like open-end mutual funds and ETFs, which include written analyses of these investment products in some situations. Although we use certain products, services, or databases that contain this information, we do not participate in or have any input in the written analyses that Morningstar Research Services produces. While we consider the analyses of Morningstar Research Services, our investment recommendations are based on our decisions in regard to the investment product. Affiliations – Registered Entities Morningstar has various subsidiaries across the globe that are each registered with the applicable regulatory body or bodies in that country to provide investment management or other advisory services. We share resources with this global group, as described earlier in this brochure. One subsidiary, Morningstar Investment Services LLC, is our subsidiary and is also an investment adviser registered under the Advisers Act. Morningstar Investment Services is additionally registered with the Securities and Exchange Commissions as a broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA). Morningstar Investment Services offers model portfolios and separately managed accounts through its role as the sponsor of an investment advisory program known as the Wealth Platform and through third-party financial institutions, plan sponsor services, and retirement plan services for institutional and retail clients. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025.) Morningstar Research Services issues investment research reports on securities we hold in our portfolios or recommend to our clients, but they do not share any yet-to- be published views and analysis and/or changes in estimates (i.e., their confidential information) with us on these securities. In making investment decisions or recommendations, we use of Morningstar Research Services’ publicly available analysis as part of our review process and do not we have access to their analysis prior to its public dissemination. We mitigate any actual or potential conflicts of interest that could arise from the access of their analysis prior to publication through measures such as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. Morningstar Research Services prepares qualitative analysis on separately managed accounts and model portfolios. To mitigate conflicts of interest, Morningstar In some cases, our senior management members have management responsibilities to these other affiliated entities. We do not believe that these management responsibilities create any material conflicts of interests for our clients. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Research Services does not prepare qualitative analysis on, nor recommend any Morningstar separately managed account or model portfolio we create and manage. Some of Morningstar Research Services’ clients are sponsors of funds or associated with other securities that we recommend to our clients. We mitigate any actual or potential conflicts of interests resulting from this fact through such measures as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar Research Services and their clients when analyzing investments or making recommendations. Page 12 of 14 products. In other cases, some of Morningstar’s clients are sponsors of funds that we recommend to our clients. Morningstar does not and will not have any input into our investment decisions, including what investment products will be recommended for our recommended portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar when analyzing investments or making recommendations. We mitigate any actual or potential conflicts of interests resulting from that by not producing qualitative analysis on any such exchange-traded fund as well as imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines between, and monitoring by the compliance department. Morningstar Investment Management serves as an investment adviser to investment companies registered under the Investment Company Act of 1940, as amended, and to other pooled investment products. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis on nor recommend as part of their investment consulting services any investment company we are an investment adviser or sub-adviser to. In some instances, we create portfolios that track an index created and maintained by Morningstar. Morningstar does not and will not have any input into our investment decisions, including what investment products will be included in our portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. Affiliations – Morningstar, Inc. Our parent company, Morningstar, Inc., is publicly traded (Ticker Symbol: MORN). We may recommend an investment product that holds a position in publicly traded shares of Morningstar’s stock. Such an investment in Morningstar’s stock is solely the decision of the investment product’s portfolio manager. We have no input into a portfolio manager’s investment decision nor do we require that the investment products we recommend own shares of Morningstar. An investment product’s position in Morningstar has no direct bearing on our investment selection process. We mitigate any actual or potential conflicts of interest by not factoring Morningstar’s publicly traded stock into our qualitative or quantitative analysis nor in our recommendations. Morningstar has and maintains accounts which they invest in accordance with investment strategies created and maintained by us. Those investment strategies are deployed using equity securities. As we have discretion over these accounts, Morningstar’s accounts are traded at the same time as our and Morningstar Investment Services’ other discretionary client accounts in order to ensure that Morningstar’s accounts are not treated more favorably than our client accounts. Some of Morningstar’s accounts are used as the subject of newsletters offered by Morningstar. In order to ensure that Morningstar’s newsletter subscribers are not treated more favorably than our clients, which would result in a breach of our fiduciary duty, we do not report trades in Morningstar’s accounts invested in our strategies to newsletter subscribers until after our client accounts have been traded or our non- discretionary clients have been notified. resources, accounting, Morningstar offers various products and services to the public. Some of Morningstar’s clients are service providers (e.g., portfolio managers, advisers, or distributors affiliated with a mutual fund or other investment option). We may have a contractual relationship to provide consulting or advisory services to these same service providers or we may recommend the products of these service providers to our advisory clients. To mitigate any actual or potential conflicts of interest, we do not consider the relationship between Morningstar and these service providers when making recommendations. We are not paid to recommend one investment option over another, including products of service providers with which Morningstar has a relationship. As a wholly owned subsidiary, we use the resources, infrastructure, and employees of Morningstar and its affiliates to provide certain support services in such areas as legal, compliance, technology, procurement, human information security, and marketing. We do not believe this arrangement presents a conflict of interests to us in terms of our advisory services. Employees of Morningstar that provide support services to us have the option to maintain their Financial Industry Regulatory Authority (“FINRA”) security licenses under Morningstar Investment Services’ limited broker/dealer registration, if appropriate for their current job responsibilities. We believe no conflict of interest exists due to the maintenance of these security licenses. Morningstar provides information to the public about various investment products, including managed investments like open-end mutual funds and ETFs. In some cases, this information includes written analyses of these investment products. Although we use certain products, services, or databases of Morningstar, we do not have any decision-making input in the written analyses that Morningstar provides its licensees. While we consider the analyses of Morningstar, our investment recommendations are oriented to the mandates of the investment products in question. In certain situations, we make our clients aware of various products and services offered by Morningstar or its affiliates. We do not receive compensation for that introduction. Morningstar and its affiliates also have the option to make their clients aware of various products and services offered by us. Morningstar and its affiliates do not receive any compensation from us for that introduction, unless it falls under a solicitation arrangement, as described in Item 14 below. Morningstar hosts educational events and conferences and on occasion provides us with the opportunity to suggest invitees or offer (proactively or upon request) discounted or waived registration fees. We mitigate any actual or potential conflicts of interest this may introduce by using pre-defined criteria to select Institutional Clients for these opportunities. Morningstar Wealth, through Morningstar and its subsidiaries, make available products such as: (i) the Morningstar Wealth Platform; (ii) Morningstar Funds Trust, (iii) Morningstar Office, Morningstar’s RIA portfolio software service; (iv) Morningstar investment data aggregation service; and (v) ByAllAccounts, Morningstar’s Morningstar.com, Morningstar’s individual investor site offering. Daniel Needham, our co-president, has management responsibilities for Morningstar Wealth. We do not believe that these management responsibilities create any material conflicts of interests for our clients, but we mitigate any actual or potential conflicts of interests resulting from that by imposing informational barriers where appropriate and undertaking compliance monitoring. Morningstar offers various products and services to retail and institutional investors. In certain situations, we recommend an investment product that tracks an index created and maintained by Morningstar. In such cases, the investment product sponsor has entered into a licensing agreement with Morningstar to use such index. To mitigate any conflicts of interest arising from our selection of such investment products, we use solely quantitative criteria established by our advisory client to make such selection, or, in the alternative, Morningstar’s compensation from the investment product sponsor will not be based on nor will it include assets that are a result of our recommendation to our advisory client to invest in those investment ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 13 of 14 of its discretionary advisory services by the end of the second quarter of 2025. When this occurs, trade recommendations will be communicated to non-discretionary clients after the close of the trading day and seed and Morningstar-affiliated accounts in the Strategies will be traded the next day so that no one person has an advantage over another.) Affiliations – Morningstar, Inc. Subsidiaries Equity and manager research analysts based outside the United States are employed by various wholly owned subsidiaries of Morningstar. These analysts follow the same investment methodologies and process as Morningstar Research Services, as well as being held to the same conduct standards. As a result, we do not believe this structure causes actual or a potential for a conflict of interest. Affiliations – Credit Rating Agency We are affiliated with the Morningstar DBRS group of companies, which include DBRS, Inc., DBRS Limited, DBRS Ratings GmbH, and DBRS Ratings Limited. DBRS, Inc. is registered with the Securities and Exchange Commission as a Nationally Recognized Statistical Rating Organization (NRSRO). Morningstar DBRS’ companies are also registered with and governed by applicable regulatory body or bodies in other countries around the globe. In our analysis of certain securities, we use the publicly available credit rating and analysis issued by Morningstar DBRS. Because of our use of Morningstar DBRS’ ratings and analysis is limited to that which is publicly available, we do not believe there is an actual or potential conflict of interest that arises from such use. Personal Trading By Access Persons Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities do not interfere with our clients’ interests. While our Access Persons have the option to maintain personal investment accounts, they are subject to certain restrictions. Our Code of Ethics includes policies designed to prevent Access Persons from trading based on material non-public information. Access Persons in possession of material non-public information are prohibited from trading in securities which are the subject of such information and from tipping such information to others. In certain instances, we employ information blocking devices such as restricted lists to prevent illegal insider trading. Morningstar’s compliance department monitors the activities in the personal accounts of our Access Persons (and any accounts in which they have beneficial ownership) upon hire and thereafter. Access Persons are required to pre- clear IPO, initial digital coin offerings, and private placement transactions with Morningstar’s compliance department. Item 12. Brokerage Practices Where we exercise investment discretion, we will generate trade instructions for each retirement account that requires investment, reallocation, or rebalancing and forward those instructions to the appropriate institution as designated by the service provider. As a result, we do not have the ability to make decisions regarding which broker is used to execute the transactions nor the timing of when the trade is executed. This could result in different pricing of client trades. We do not participate in any soft dollar practices. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics We have in place a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act (“Code of Ethics”). Our Code of Ethics strives to uphold the highest standards of moral and ethical conduct, including placing our clients’ interest ahead of our own. Our Code of Ethics covers all our officers and employees as well as other persons who have access to our non-public information (collectively “Access Persons”). Our Code of Ethics addresses such topics as professional and ethical responsibilities, compliance with securities laws, our fiduciary duty, and personal trading practices. Our Code of Ethics also addresses receipt and/or permissible use of material non- public information and other confidential information our Access Persons may be exposed and/or have access to given their position. The Code of Ethics is provided upon hire and at least annually thereafter and at each time, the Access Person must certify in writing that she or he has received, read, and understands the Code of Ethics and that they agree to or have complied with its contents. A copy of our Code of Ethics is available to existing and prospective clients by sending written request to compliancemail@morningstar.com. Item 13. Review of Accounts Retirement accounts enrolled in Managed Accounts and the Personal Target-Date Fund Service are typically rebalanced to your account’s asset allocation target or reallocated on a quarterly basis as necessary and your portfolio allocations will be adjusted on an annual or as-needed basis to account for changes in your age and any other significant personal or financial changes to your situation that you have informed us about. Our methodology has a built-in mechanism to help prevent unnecessary trading and therefore will not propose any changes to your investment strategy if the adjustments are relatively small. You are responsible for notifying us of changes in your personal and financial information, investment objectives, and investment restrictions so that we can make the necessary adjustments to your investment strategy. Periodically, you will receive a written progress report with information about your account, either in an electronic format (e.g., by email or through Internet account access). This progress report may include such things as your progress toward your retirement goal, investment performance information, and an analysis of your retirement account. Interest in Client Transactions Our Access Persons have the option to maintain personal investment accounts and purchase or sell investments in those accounts that are the same as or different from the investments we recommend to clients. Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities should not conflict with our advisory activities or the timing of our recommendations and will not interfere with our clients’ interests, while allowing our Access Persons to invest in their own accounts. We do not engage in principal transactions (transactions where we, acting in our own account or in an affiliated account, buy a security from or sell a security to a client’s account) nor do we engage in agency cross transactions (transactions where we or our affiliate executes a transaction while acting as a broker for both our client and the other party in the transaction). We do not provide ongoing account reviews as part of Advice and Guidance. You should review your retirement account asset allocation recommendations on a regular basis. You can use the Morningstar Retirement Manager platform at any time to update your personal information and review your retirement strategy, which will likely change as the result of the updated information. We recommend you return to our site every six months to receive an updated strategy, or sooner if you have had any significant changes in your personal or financial situation. We also recommend you return to our site whenever there has been a chance in the available investment options in your retirement plan or product lineup. We do not prepare periodic reports as part of Advice or Guidance. Item 14. Client Referrals and Other Compensation We make direct or indirect cash or non-cash payments to our affiliates or to unaffiliated third parties for recommending our services. If such payments occur, they will be done pursuant to Rule 206(4)-1 of the Advisers Act. Clients referred by third party solicitors may in some cases pay a higher fee than clients who contract with us Interest in Securities That We May Recommend Morningstar Investment Management has and maintains a number of seed accounts (accounts used to establish a strategy we offer or are tracking), many of which follow strategies we offer to clients. We place block trades for our accounts, therefore trade requests for our seed accounts are placed at the same time as trades are placed for those client accounts invested in the same strategy and for which we have discretion. Block trades are allocated in such a manner as to ensure that our seed accounts do not receive more favorable trades than our clients’ accounts. Client accounts that we manage on a discretionary basis and thus, our seed accounts, are traded before we provide model portfolio trade recommendations to other clients using our model portfolios. However, our model portfolio clients receive trade recommendation after the close of the trading day, so that no one model portfolio client is favored over another. (As noted above, Morningstar Investment Services anticipates the cessation ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 14 of 14 directly. Through disclosures, which are spoken or given in writing to Clients at the time of the solicitation, solicited Clients are made aware of the arrangement between the solicitor and us (and therefore that the solicitor has a financial interest in recommending us to Client), any other material conflicts of interest, and the terms of any compensation paid directly or indirectly to the solicitor as a result of their referral. Item 18. Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We do not have any financial commitment that impairs our ability to meet our contractual and fiduciary commitments to clients, nor have we been the subject of any bankruptcy proceeding. We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. We enter into agreements with certain Institutional Clients whereby we provide compensation to Institutional Clients in exchange for access to their financial professionals to educate them about our advisory products and services, having our name, products, or services listed or highlighted in Institutional Client materials, attendance or booth space at Institutional Client conferences, and/or similar marketing, distribution, and educational activities. We also provide compensation to Institutional Clients to sponsor meetings and events for their financial professionals and/or clients. Item 15. Custody We do not serve as a custodian of client assets. However, in cases where we have the ability to debit fees directly from client accounts, we are deemed to have custody of client assets under Rule 206(4)-2 of the Advisers Act, even if we do not act as a custodian. Your service provider or its designee is responsible for selecting the custodian for your plan assets and you should receive statements from the qualified custodian that holds your assets at least quarterly. You should carefully review such statements and compare them to the written progress reports we provide to you. Our progress reports may vary from custodial statements because of differences in accounting procedures (e.g., trade-date versus settlement-date accounting) or reporting dates. If you note any discrepancies on your account statements, please promptly contact your service provider. Item 16. Investment Discretion When you accept the advisory agreement for Managed Accounts or the Personal Target-Date Fund Service, you assign to us or us and the Other IA (applicable to Advisor Managed Accounts) full discretion to manage the investments of your retirement account on your behalf and to monitor it on an ongoing basis. Based on information provided by you, you receive an individualized asset allocation strategy and investment options appropriate for that strategy which are selected from the options or, in the case of the Personal Target-Date Fund Service, target-date funds available to your retirement account. As described above, you have the right to impose reasonable restrictions on your retirement account. We, and if applicable the Other IA, will exercise our discretion in managing your account consistent with your individualized strategy and within the account restrictions, if any. If you elect Advice or Guidance, you retain the investment discretion and control of your retirement account. We provide you with information designed to help you make investment choices regarding your retirement account assets, but you are responsible for managing the investments in your account. We do not monitor, review or update our recommendations or projections on an ongoing basis. Item 17. Voting Client Securities You are responsible for receiving and voting proxies for all investments held in your retirement account. You may receive proxies or other solicitations directly from your account’s custodian. We do not have the authority to and will not vote proxies. We cannot provide information or advice in regard to questions you have about a particular solicitation. We do not advise or act for you in legal proceedings, including class actions or bankruptcies, involving recommended securities. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc. 

Morningstar Investment Management LLC Form ADV Part 2A: Firm Brochure Morningstar Retirement Institutional Advisory Services 22 West Washington Street, Chicago, IL 60602 Phone: 312.696.6000 www.corporate.morningstar.com March 27, 2025 Item 5. Fees and Compensation was updated to reflect lower fee ranges for some services and to disclose that we receive compensation from unaffiliated third parties for referring their services to other advisory firms or investors. us at 312.696.6000 or send an email This brochure provides information about the qualifications and business practices of Morningstar Investment Management LLC. If you have any questions about the contents of this brochure, please to contact compliancemail@morningstar.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss was updated to reflect the current makeup of the Morningstar Retirement Investment Policy Committee, information about valuation, sub-advisers, and the prospectus risks for the Morningstar Funds Trust, to remove mention of an optional risk tolerance questionnaire in the managed accounts, advice, and guidance services. Additional information about Morningstar Investment Management LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Item 10. Other Financial Activities and Affiliations was updated to disclose an investment in SMArtX. Morningstar Investment Management LLC is registered with the SEC as a registered investment adviser. Registration with the SEC does not imply a certain level of skill or training. Please retain this brochure for future reference. Item 14. Client Referrals and Other Compensation was updated to disclose that we receive compensation from unaffiliated third parties for referring their services to other advisory firms or investors and note we provide compensation to Institutional Clients to provide marketing or educational support to their financial professionals and to sponsor meetings and events for their clients. We made other edits where necessary to correct grammar or punctuation, to provide clarification or further information, for consistency in terminology or content, or to improve the readability of the brochure. All current versions of our firm brochures are available in the Part 2 Brochures section of this record on the SEC’s website. You can also request a copy of our current brochure free of charge by contacting our Compliance Department at 312.696.6000, or by email to compliancemail@morningstar.com. In your request, please indicate the name of the company (Morningstar Investment Management) and the service brochure(s) (Morningstar Retirement Advisory Services for Individuals, Morningstar Retirement Institutional Advisory Services, or Morningstar Wealth Advisory Services) you are requesting. Item 2. Material Changes The Institutional Advisory Services Firm Brochure dated March 2025 contains no material changes since our last annual update dated March 25, 2024. Non-material changes since our last annual update include: Information about advisory services offered solely by Morningstar Investment Management’s Morningstar Wealth group were removed from this brochure and placed in a new Form ADV Part 2A: Firm Brochure, Morningstar Wealth Advisory Services. Investment Services, anticipates the cessation of Item 3. Table of Contents Advisory Business ....................................................................................... 1 Fees and Compensation .............................................................................. 4 Performance Based Fees and Side-by-Side Management ........................... 5 Types of Clients ........................................................................................... 5 Methods of Analysis, Investment Strategies, and Risk of Loss ................... 6 Disciplinary Information ............................................................................. 17 Other Financial Industry Activities and Affiliations ..................................... 17 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................ 20 Brokerage Practices ................................................................................... 20 Review of Accounts .................................................................................. 21 Client Referrals and Other Compensation .................................................. 21 Custody ..................................................................................................... 21 Investment Discretion ................................................................................ 21 Voting Client Securities ............................................................................. 21 Financial Information .................................................................................. 22 As applicable throughout the Firm Brochure, we noted that our subsidiary, its Morningstar discretionary advisory services by the end of the second quarter of 2025. Morningstar Investment Management will become the investment adviser to many of Morningstar Investment Services’ third-party financial institution clients. At the time of this change, trade recommendations for Morningstar Wealth portfolios will be communicated to non-discretionary clients after the close of the trading day and Morningstar-affiliated accounts in Morningstar Wealth strategies will be traded the next day so that no one person has an advantage over another. that was incorporated in 1999. Morningstar is a wholly owned subsidiary of Morningstar, Item 4. Advisory Business Firm Information Morningstar Investment Management LLC is a Delaware limited liability company Investment Inc. Management (“Morningstar”). Morningstar is a publicly traded company (Nasdaq Ticker: MORN) with Mr. Joseph Mansueto, Executive Chairman of Morningstar, Item 4. Advisory Business was updated to reflect our assets under management and advisement as of December 31, 2024 and to remove references to Personalized Strategy Reports. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 2 of 22 holding more than 35% of Morningstar’s outstanding shares. Because of that ownership, Mr. Mansueto is an indirect owner of Morningstar Investment Management. Morningstar Investment Management is registered with the SEC under Section 203(c) of the Investment Advisers Act of 1940, as amended (“Advisers Act”). Morningstar Investment Management has filed the appropriate notices to conduct business in all 50 states, the District of Columbia, Guam, the Virgin Islands, and the Commonwealth of Puerto Rico. Morningstar Investment Management is registered with the U.S. Commodity Futures Trading Commission as a Commodity Pool Operator (“CPO”) and is a member of the U.S. National Futures Association. about the Funds is are managed in a multimanager structure. Subject to the review and approval by the Morningstar Funds Trust’s board, we set each Morningstar Fund’s overall investment strategy. We are also responsible for the oversight and evaluation of each Morningstar Fund’s sub-advisers. The Morningstar Funds will be used as the underlying holdings for certain model portfolios, most notably mutual fund model portfolios, offered by Morningstar Investment Management and our subsidiary, Morningstar Investment Services LLC The Morningstar Funds include the Morningstar Alternatives Fund, Morningstar Defensive Bond Fund, Morningstar Global Income Fund, Morningstar International Equity Fund, Morningstar Multisector Bond Fund, Morningstar Municipal Bond Fund, Morningstar Total Return Bond Fund, Morningstar U.S. Equity Fund, and the Morningstar Global Opportunistic Equity Fund. More information at Morningstar http://connect.rightprospectus.com/Morningstar. Morningstar Investment Management, along with other Morningstar subsidiaries authorized in appropriate jurisdictions to provide investment management and advisory services, is part of a global investment team composed of investment analysts, portfolio managers, and other investment professionals. These investment and operations teams span the globe, with primary offices in Chicago, London, and Sydney. Morningstar Retirement is committed to helping people improve their financial health and prepare for retirement by offering investment advice and managed accounts, custom model portfolios, and fiduciary services to plan providers, employers, and retirement investors. The advisory services below are offered through Morningstar Retirement: Morningstar Wealth and Morningstar Retirement are groups within Morningstar Investment Management that independently offer certain products and services. This brochure focuses on the products and services provided to institutional clients through the Morningstar Retirement group. You can obtain a copy of our brochure describing our products and services for individuals (managed account, advice, and personal target-date fund services for retirement investors) or our products and services offered through our Morningstar Wealth group by following the instructions above. Custom Model Portfolios We construct custom asset allocation model portfolios for use with employer- sponsored retirement plan accounts using the investment options available in a plan’s lineup. Model portfolios can be time-based, risk-based, or a combination of time- and risk-based. Model portfolios, including target-date glide paths where relevant, are customized to the specific plan, and can take into account a wide range of factors including the presence of defined benefit assets, company stock holdings, savings rates, and account balances. We provide monitoring of the model portfolios (and glide paths), making recommendations to change investment allocations, and/or to add, remove, or modify the model portfolios’ underlying investment options when necessary. Our recommendations and investment decisions are limited to those investment options available under the client’s retirement plan lineup. Advisory Services We Offer – Overview Morningstar Investment Management offers various investment advisory services that focus on our core capabilities in asset allocation, investment selection, and portfolio construction to financial or other institutions including, but not limited to, asset management firms, banks, broker/dealers, consultants, endowments, foundations, insurance companies, investment advisers, investment fiduciaries, plan sponsors of retirement plans, providers of retirement plan services, trusts, and other business entities (collectively “Institutional Clients” or individually, an “Institutional Client”.) The advisory service below is offered through both Morningstar Wealth and Morningstar Retirement: Fiduciary Services We provide Institutional Clients with retirement plan services that include the construction, monitoring, and/or management of plan lineups. These services typically include automated reporting capabilities, marketing and sales support, and an online reporting delivery mechanism. We provide documentation of the process used to select, review, monitor, and update the funds chosen. We offer a workforce profile questionnaire designed to help a plan sponsor identify the investment sophistication, funding status, investment goals, and/or risk tolerance of the retirement plan or its participants. We also typically provide methodology documents, an investment policy statement, quarterly fund and plan performance reports, annual summary reports, and a quarterly market summary. In providing these services, we serve as a fiduciary, as defined in section 3(21)(A) ERISA, as amended, and may additionally serve as an investment manager, as defined in section 3(38) of ERISA. Institutional Asset Management For Institutional Clients who sponsor registered or pooled investment products, we serve as a portfolio manager, portfolio construction adviser, or sub-adviser. We provide recommendations for asset class allocation targets and/or selection of underlying holdings to fulfill each asset class allocation target. Underlying holdings may include, but are not limited to, open-end mutual funds, exchange-traded funds (“ETFs”), and collective investment trusts. The universe of underlying holdings is generally defined by the Institutional Client and can include investment products that are affiliated with that Institutional Client. This service typically includes ongoing responsibilities such as monitoring the underlying holdings and reviewing and updating asset allocation percentages and/or underlying holdings as necessary. We construct a list of lineup options (including, but not limited to, collective investment trusts and/or mutual, money market, and/or stable value funds) from the universe of investment options defined by the Institutional Client. We provide asset-class requirements for the lineup, with specific investment options identified for each asset class, for use in developing a lineup for a defined contribution or defined benefit retirement plan. This process is designed to provide the Institutional Client with investment choices that will We are an investment adviser to Morningstar Funds Trust, registered with the SEC as an open-end management investment company under the Investment Company Act of 1940, as amended. We have overall supervisory responsibility for the general management and investment of the fund portfolios within the Morningstar Funds Trust (“Morningstar Funds”), which ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 3 of 22 result in a lineup that is appropriately diversified with a sufficient broad range of risk/return characteristics. Under our standard 3(21) service, we serve as a fiduciary with respect to the investment selection and monitoring we provide, but the Institutional Client retains responsibility for investing plan assets in accordance with our recommendations. We provide ongoing monitoring of the specific investments in the approved investment list and monitor individual plans to ensure they are meeting our asset-class requirements and investing in approved funds. Typically, if we recommend modifications to a lineup, we provide notice to the Institutional Client who has discretion to implement our recommended changes. offers each retirement investor a target retirement income goal, projected retirement income amount, recommendations on savings rate and retirement age, personalized asset allocation strategy, and professional investment selection. Under Advice, the retirement investor is responsible for the implementation of any changes to and the monitoring of their retirement account. Under Managed Accounts, we will manage the retirement investor’s account on an ongoing basis, in addition to the items provided under Advice. Our account management includes ongoing monitoring, automatic account rebalancing and implementation of changes, quarterly progress reports, and an annual progress report. Typically, these reports are available electronically through our website on a quarterly basis. We use the investment options available in the retirement plan or product to construct a portfolio and, when applicable, monitor model portfolios designed for retirement investors across a broad range of risk exposure levels. For our “flexible” 3(21) service, we offer the services outlined under our standard 3(21) service but allow the Institutional Client the flexibility to choose investments from our approved investment list along with non- approved investment options for their lineup. Our fiduciary support covers the use of investment options from our approved list only. Under this service, we do not provide any fiduciary coverage on the end lineup. In some cases, Institutional Clients delegate discretionary management responsibilities to us. For our standard 3(38) service, we serve as a fiduciary with respect to the investment selection and monitoring we provide and we act as an investment manager for the plan, with full authority to select, remove and replace investment options from the plan lineup. We provide periodic monitoring of the specific investments in the approved investment list and monitor individual plans to ensure they are meeting our asset-class requirements and investing in approved funds. For our “flexible” 3(38) service, we offer the services outlined in our standard 3(38) service but allow the Institutional Client the flexibility to request some variability in our standard process, such as the ability to include more approved investment options in asset classes than we allow under our standard service. This service is designed to help avoid too much disruption as Institutional Clients convert their plans to our service. Advisor Managed Accounts is a product name for Managed Accounts or Advice that allows investment advisers, consultants, or asset managers to incorporate their own asset allocation and fund selection capabilities into our offering. Under this service, the investment adviser, consultant, or asset manager is responsible for building plan-level portfolios from each plan or product’s investment options or non-core investment options, if available through the service provider. The plan-level portfolios are used in our portfolio assignment methodology to create hundreds of retirement investor-level portfolios that span the equity spectrum. If we engage an asset manager as a sub-adviser (“Sub-Adviser”) to provide portfolio construction services for Advisor Managed Accounts, we are responsible for the investment-level portfolios created for users of our services and there is no advisory relationship between you, your retirement investors or product users, and the Sub-Adviser. Each retirement investor is then assigned to a portfolio appropriate for their retirement goals. As part of Managed Accounts, each retirement investor receives a target retirement income goal, projected retirement income amount, and recommendations on savings rate and retirement age. We manage the retirement investor’s account on an ongoing basis, which includes ongoing monitoring, automatic account rebalancing and implementation of changes, quarterly progress reports, and an annual progress report. Typically, these reports are available electronically through our website on a quarterly basis. We offer Morningstar Plan Advantage, an online platform designed to help retirement plan sponsors served by financial professionals of Institutional Clients (1) identify a category-level plan lineup, (2) choose a plan provider from those available through Morningstar Plan Advantage (choice of plan provider can be further limited by the Institutional Client), and (3) access 3(21) or 3(38) fiduciary services as part of a bundled offering. Once enrolled, plan sponsors and their designated plan advisor can review their lineup and access reports, view notifications, and learn more about plan lineup changes. If made available by the plan sponsor or service provider, retirement investors have the option to complete an annuity questionnaire. Through this questionnaire they can indicate whether they would like to receive a recommendation for how much of their retirement account could be invested in an annuity while still aligning with our investment strategy. We do not recommend, endorse, or sell any specific annuity products as part of this allocation recommendation and do not provide advisory or discretionary investment management services to assets invested in an annuity. If requested by the plan sponsor or service provider, we will integrate access to an annuity marketplace or provider into our platform to help facilitate the retirement investor’s purchase of an annuity, if they decide to do so. In such instances, the annuity or annuities available are chosen by the plan sponsor or service provider and we have no role in selecting those annuities. An annuity allocation recommendation is only available through the Managed Accounts service. Managed Accounts, Advice, and Guidance We offer services to Institutional Clients for use with individual retirement investors in their employer-sponsored retirement plans or other retirement products, like individual retirement accounts or health savings accounts earmarked for retirement (each a “retirement account”). These services are intended for citizens or legal residents of the United States or its territories and are offered through retirement plan sponsors and/or plan providers, plan administrators, retirement product providers, and/or other investment advisers (each a “service provider.”) These services typically include guidance, advice and/or managed account options, along with an online platform to access those services. Guidance includes general and educational information and tools to help retirement investors manage their retirement account. Under Guidance, the retirement investor is responsible for determining the suitability of investments, implementing changes to their retirement account, and monitoring their account on an ongoing basis. Advice We offer advisory services to Institutional Clients who offer their own investment advice or managed account programs to their clients. In most cases, we serve as the independent “Financial Expert” as defined within the Department of Labor’s Advisory Opinion 2001-09A dated December 14, 2001 (commonly referred to as the “SunAmerica Opinion.”) We use the investment options available in a retirement investor’s lineup or product to construct and, ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 4 of 22 The non-discretionary assets under advisement for Morningstar Investment Management (rounded to the nearest $100,000) were $235,870,200,000. when applicable, monitor model portfolios designed for retirement investors across a broad range of risk exposure levels. We may also use information provided by independent third parties such as mutual fund data or index providers in the construction of advice for the program. Item 5. Fees and Compensation Fees and Compensation – Overview We typically negotiate our fees, payment terms, and payment schedules on an individual basis with each Institutional Client. The services we provide, the specific fees for such services, and the contract term are governed by the contractual agreement between us and our Institutional Client. Institutional Clients may not receive all of the services listed above. Our fees vary depending on the services selected and could include a fixed fee, a basis- point fee, and/or a technology licensing fee. Fees for some services take into consideration such factors as the number of services being provided and service specific variables such as the universe of investments, variables in monitoring frequency, delivery type, investment types, and frequency of written analysis. Personal Target Date Fund Service We offer a personalized target date fund service to Institutional Clients for use with retirement investors. This service includes a personalized asset allocation strategy and professional investment selection for individual retirement investors invested in employer-sponsored retirement plans or other retirement products, like individual retirement accounts (“IRAs”) or health savings accounts (“HSAs”) earmarked for retirement through an online platform. The asset allocation strategy utilizes one or more target date fund vintages, is based on the retirement investor’s financial situation and retirement goals using the information the retirement investor, plan sponsor, service provider(s) and/or an account aggregator provides, and includes ongoing monitoring and automatic account rebalancing and implementation of allocation changes. After determining the retirement investor’s asset allocation target, the target-date funds available in the retirement investor’s plan or product are used to create an investment-specific portfolio. We manage the retirement investor’s account on an ongoing basis and communicate our investment decisions to the plan or product’s service provider. Institutional Asset Management Our Institutional Asset Management fees are negotiable but generally include an asset-based fee and can include a minimum annual fee. The asset-based fee typically ranges from 2 to 15 basis points of the assets being managed or consulted upon while the minimum annual fee is $100,000 - $200,000. The actual fee depends on a range of variables including our role in providing the services, the type of security we are providing services for, and the amount of assets involved. The fee is typically charged monthly in arrears. The target date fund series available in the retirement plan or product could be associated with an Institutional Client or plan or product’s service provider. In such instances, the service provider, or their affiliate, may receive compensation based on the assets in those investments which gives the service provider an incentive to make those investments available. As the investment adviser to the Morningstar Funds Trust (“Trust”), we are compensated by the Trust based on assets within the Morningstar Funds for our investment management activities in accordance with the Investment Management Agreement between the Trust and us. We are entitled to receive an annual management fee calculated daily and payable monthly equal to the following percentage of a Morningstar Fund’s average daily net assets: Retirement investors will periodically receive progress reports reflecting progress towards their retirement goals and other information in regard to their investments. Typically, these reports are available electronically through our website on a quarterly basis. Morningstar Fund Morningstar U.S. Equity Fund Morningstar International Equity Fund Morningstar Global Income Fund Morningstar Total Return Bond Fund Morningstar Municipal Bond Fund Morningstar Defensive Bond Fund Morningstar Multisector Bond Fund Morningstar Global Opportunistic Equity Fund Morningstar Alternatives Fund Management Fee 0.67% 0.83% 0.35% 0.44% 0.44% 0.36% 0.61% 0.47% 0.85% Customized Services At an Institutional Client’s request, we will take under consideration a request to provide them with a customized version of the above services or a different type of advisory services that would utilize our core capabilities in asset allocation, investment selection, or portfolio construction. Given the customized nature, the Institutional Client can impose constraints/restrictions on such things as security types, asset classes, or proprietary security requirements and/or wish to collaborate with us on such things as investment methodology and screening criteria. More information about the Morningstar Funds’ fees and expenses can be found in the prospectus at http://connect.rightprospectus.com/Morningstar. Wrap Fee Programs We do not sponsor a wrap fee program, but we do provide portfolio management services to a wrap fee program offered by our subsidiary, Morningstar Investment Services LLC, through the Morningstar Wealth program. This wrap fee program is scheduled to be closed around the end of the second quarter of 2025. Custom Model Portfolios Our Custom Model Portfolio fees are negotiable but generally include a minimum and an asset-based fee. Asset-based fees generally range between 2 and 8 basis points. Minimum fees typically vary from $100,000 to $300,000. The actual fees depend on a range of variables including our fiduciary role, services used, asset size, and whether services are opt-in or opt-out. The licensing and/or minimum fee is typically charged in arrears. The asset-based fee is generally charged quarterly by applying the pro-rated basis point rate to the average assets in a retirement account during the quarter. Assets Under Management As of December 31, 2024, the discretionary regulatory assets under management for Morningstar Investment Management (rounded to the nearest $100,000) were: Retirement Services to Individuals: $29,068,100,000 Investment Management Services to Institutional Clients: $36,267,000,000 Fiduciary Services Our 3(21) and 3(38) Fiduciary Services fees are negotiable but generally include a minimum and an asset-based fee. Asset-based fees generally range Total Regulatory Asset Under Management: $65,335,000,000 ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 5 of 22 between 2 and 8 basis points. Minimum fees typically vary from $100,000 to $450,000. The actual fees depend on a range of variables including our fiduciary role, service used, asset size, and whether services are opt-in or opt- out. The fee is typically charged quarterly in arrears based on assets held at calendar quarter-end or the average assets in the service over the quarter. fee, other investment expenses, and possibly a distribution fee (e.g., 12b-1). In some cases, an investment option may also charge an initial or deferred sales charge. Annuities typically have additional fees, such as surrender charges, mortality and expense risk charges for death benefits or payout options like guaranteed income for life, administrative fees, underlying fund expenses related to investment sub-accounts, and other charges for special features, like guaranteed minimum income benefits, principal protection, or stepped-up death benefits. Neither Morningstar Investment Management nor any of our employees receive transaction-based compensation for the investment recommendations we make. Our Morningstar Plan Advantage fees are negotiable but generally include a minimum and an asset-based fee that typically ranges between 3 and 8 basis points annually. The actual fee depends on a range of variables including our fiduciary role, services used, and asset size. The fee is typically charged quarterly in arrears by applying the pro-rated basis point rate to the average assets in a plan during the quarter. Fees Charged in Advance Our services can be terminated as outlined in the contractual agreement between Morningstar Investment Management and the Institutional Client. Termination of services and refunds of fees, if any, are governed by the contractual agreement between the parties, which is negotiated on an individual basis. Upon termination, any earned, unpaid fees by the Institutional Client are due and payable. If, in accordance with contractual terms, the Institutional Client terminates their contract prior to the end of the billing period, we will refund any unearned fees on a pro rata basis after the termination of the contract. Managed Accounts, Advice, and Guidance Managed Accounts, Advice, and Guidance fees are negotiable, but generally include a minimum and/or licensing fee, and an asset-based fee. Minimum and/or licensing fees typically vary from $100,000 to $800,000. Asset-based fees for Managed Accounts typically range from 8 to 50 basis points annually. The actual fees depend on a range of variables including our fiduciary role, services used, asset size, and whether services are opt-in or opt-out. The licensing fee is typically charged annually in advance. The asset- based fee is typically charged quarterly in arrears by applying the pro-rated basis point rate to the average assets in a retirement account during the quarter. Compensation from Sales of Securities We do not expect, accept or receive compensation for the sales of securities, including asset-based sales charges or service fees from the sale of open- end mutual funds. Please note, in instances where a Sub-Adviser has been engaged to undertake portfolio construction for these services, the portfolios they create will typically consist of associated investment products in which they receive compensation based on the amount of assets invested. investment advisers or You may have the option to purchase investment products we recommend financial or similar services through other professionals not affiliated with us. Because our services are not exclusive, the fee for our services may be higher than fees charged by other financial firms who provide services similar to ours or if you paid separately for investment advice and other services. In addition, because the underlying holdings of our portfolios are not exclusive to the services described herein, you may buy securities (e.g., mutual funds, exchange-traded funds, equity securities, etc.) outside of this service without incurring our fees. Revenue Sharing Arrangements We do not have any revenue sharing arrangements with any mutual funds. Personal Target Date Fund Service Personal Target Date Fund Service fees are negotiable, but generally include a one-time set-up fee, a minimum fee, and an asset-based fee. The set-up fee typically ranges from $100,000 to $200,000. The annual minimum is generally in the range of $200,000 to $500,000. The annual asset-based fee typically ranges from 4.5 to 7 basis points. The actual fees depend on a range of variables including the asset manager size and the overall fees charged. The set-up fee is typically charged in advance. The asset-based fees are typically charged quarterly in arrears by applying the pro-rated basis point rate to the assets in the retirement account enrolled in the service. Third-Party Compensation We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. Payment Payments, payment terms and payment schedules are negotiated and governed by the contractual agreement we enter into with each Institutional Client. We typically send an invoice on a periodic basis (e.g., monthly or quarterly), although in some instances, we bill annually. For services we provide to an affiliate, fees are charged through an intercompany charge. Fixed and licensing fees are typically paid in advance of services being provided, and basis-point fees are typically charged in arrears. Item 6. Performance Based Fees and Side-by-Side Management We do not have performance-based fee arrangements with any qualified client pursuant to Rule 205-3 under the Advisers Act. Item 7. Types of Clients Our clients include advisory programs or platforms of third-party advisory or platform providers, entities such as financial institutions, third-party investment advisers, broker/dealers, investment companies (including the Morningstar Funds Trust), and other business entities, consultants, plan providers, product providers, and sponsors who offer investment advice programs to individual retirement investors in defined contribution plans such as 401(k), 457, and 403(b) retirement plans, individual retirement plan Other Costs in Connection with Our Advisory Services Our fees are separate from fees and expenses charged by the investment products (including redemption fees or asset- or transaction-based trading fees), fees and expenses charged by the Institutional Client for their products (including any revenue sharing arrangements that they have with the investment option’s investment adviser and/or distributor), or fees that are charged by a third party, such as a proprietary advisory program, financial advisor, platform, custodian, transfer agent, plan provider, or recordkeeper. The investment options’ fees and expenses are described in the prospectus or an equivalent document. These fees will generally include a management ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 6 of 22 participants, health savings accounts, and individuals who are in retirement. Please see our Retirement Services for Individuals brochure, available on the SEC website, for further information about Morningstar Retirement’s advisory services provided to retirement investors. We do not require a minimum account size for our institutional investment advisory services, and we generally do not impose other conditions for using our institutional advisory services. working groups also exist with the goal of sharing methodologies and research across regions. These groups focus on specific investment areas such as valuation models driven by our capital markets research and methodologies used for asset allocation, investment selection, portfolio construction for different investment strategies and advice. In addition to governance bodies, the investment team has regional research and portfolio construction workflows that surface best thinking across investment opportunities and guide portfolio construction. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss Investment Philosophy Our investment philosophy is driven by the investment principles that are promoted throughout our organization. The principles are intended to guide our thinking, behavior and decision making. These principles have been inspired by a number of the most experienced and successful investors in the last century. These principles also reflect and align with the history and foundation of Morningstar. The investment principles are: Morningstar Retirement Investment Policy Committee The Morningstar Retirement Investment Policy Committee is responsible for oversight of the investment methodologies across Morningstar Retirement’s products and services including some of our Institutional Asset Management, Managed Accounts, Advice, and Guidance, Personal Target Date Fund Services, Custom Model Portfolios, Fiduciary Services, and some of our Investment Analytics, Monitoring, and Comparative Analysis Reports. Members of the Morningstar Retirement Investment Policy Committee includes the Morningstar Retirement’s chief investment officers, head of advice and financial planning, head of business development and client success, head of channel strategy, head of research, director of retirement research, director of product management, head of investments for institutional and retirement solutions, and the senior director of automated portfolios management. - We put investors first - We’re independent-minded - We invest for the long term - We’re valuation-driven investors - We take a fundamental approach - We strive to minimize costs - We build portfolios holistically Institutional Asset Management Investment Process Our investment process starts with scouring the globe for opportunities. Instead of hewing closely to an index-defined universe, we look broadly, investigating asset classes, sub-asset classes, sectors, and securities in markets around the world. Our capital markets research extends to more than 200 equity and 150 fixed-income asset classes. We also track around 30 world currencies. We apply deep valuation analysis supported by in-depth fundamental research to find opportunities around the globe. Building upon our investment principles, our investment philosophy is built on the belief that portfolios should maintain a risk profile commensurate with the desired long-term asset allocation guidelines we provide to the client. We focus extensively on the portfolio structure to maintain a careful balance between being allocated similarly to the portfolio benchmarks and one that reflects our assessment of the value available in the current market environment. We select managers that we believe manage fund assets with a consistent and disciplined process that can provide for sustainable long- term results. We prefer managers with a prudent, logical, and repeatable process and remain keenly focused on the consistency of the implementation of their investment disciplines. Alongside this analysis, which looks at both absolute and relative valuation, we also consider investor sentiment and positioning, which adds contrarian elements to our process and tells us how the market consensus views an investment idea we’re considering. We prefer to invest in ideas contrary to the market consensus because one needs to be different to be able to outperform. We also look closely at each asset class’s risk, which can be complex, multifaceted, and vary over time. We believe that one of the best ways to control for risk is to buy fundamentally strong assets that seem underpriced. To align with our business structure, we have two Investment Policy Committees. The investment advice used in the products and services referenced in this brochure from Morningstar Investment Management is provided by investment teams. Information on key members of these investment teams is included in our Form ADV Part 2B Brochure Supplement for Institutional Advisory Services. For Advisor Managed Accounts, the registered investment adviser responsible for portfolio construction has their own Brochure Supplement that you should obtain and review. Our in-depth valuation analysis and contrarian indicators, when brought together, are the key ways we generate investment ideas. These ideas might be names to include in a stock portfolio or our best thinking on reward for risk at the asset class-level. In addition, our valuation-driven asset allocation process paired with our in-house investment selection skill allows us to holistically build portfolios for our clients for the long term. The Investment Management group, as a global team, works to understand markets and opportunities, monitor risk in existing portfolios, and vet ideas to make investment changes. We use this ongoing investment process to manage a variety of equity and multi-asset portfolios for our Institutional Clients. Global Investment Committee Morningstar Wealth’s Global Investment Committee and its regional governance bodies, in addition to the Americas Investment Product Committee, are responsible for oversight of the investment methodologies across some of our Institutional Asset Management, Model Portfolios and Separately Managed Accounts, Asset Allocation Services, and some of our Investment Analytics, Monitoring, and Comparative Analysis Reports products and services. Members of the Global Investment Committee may include officers, chief investment officers, managing directors, or managers of Morningstar Investment Management or its affiliates. The regional governance bodies meet quarterly to review guideline changes and performance across portfolios. Formal and informal global best practice ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 7 of 22 Institutional Client to identify and evaluate manager candidates for possible addition to or removal from the available investment universe. Investment Selection Finding investment opportunities isn’t just about great ideas; it’s also about selecting great investments for our clients. Investments may be individual stocks, or active managers and/or passive exchange-traded products in a multi-asset portfolio. Our research-driven approach to selecting investments is designed to help investors reach their goals and objectives. Building Portfolios Armed with investment ideas, our global team works together to holistically build portfolios suited to each strategy we offer or the objectives of our clients. Portfolio construction is about ranking and risk management. We seek to gain the largest exposure to our best ideas, while building robust portfolios designed to stand up to challenging investment environments or investment errors. When building multi-asset portfolios, we need to evaluate the active investment managers and/or passive funds we use to implement our investment strategies. Our investment selection process begins with analysis from Morningstar and its affiliates, which covers hundreds of thousands of investment offerings globally, including mutual funds, closed-end funds, separate accounts, exchange-traded products, individual stocks, and hedge funds. We then build upon that analysis with reviews by our internal investment team, which includes not only quantitative screens and assessments, but also one-on-one conversations with portfolio managers as part of our fundamental due diligence. This judgment-driven approach also allows us to evaluate the complexity and multifaceted nature of investment risk. We view risk as the permanent loss of capital. Our valuation-based approach (that is, seeking underpriced assets and avoiding overpriced assets), fundamental diversification, and forward- looking approach to viewing asset class co-movements (that is, those that buffer gains and losses), all help mitigate risk in the portfolios we build. In our due diligence, we assess whether their investment team is qualified, experienced, and talented; that they follow a consistent and disciplined investment process; that their organization is strong and stable; and that they operate professionally and ethically. To prepare investors for the future, we seek to construct robust portfolios designed to perform well in different environments rather than being considered “optimal” based on expected results or a specific environment. We avoid forecasts and building strategies based on our ability to predict specific environments. Instead, we aim to prepare for different environments through constructing portfolios that will hold up under many possible environments—even ones that we haven’t seen before. In effect, this involves trade-offs of aggregate reward for risk and a calibration of the probability and impact of negative outcomes. We study managers’ holdings using our proprietary tools and analytics to assess how well their strategy may work in combination with those of other managers. And we consider managers’ ability to outperform in different market environments. Rather than following simple style analytics or style neutrality blends, we seek process diversification and try to avoid the pitfalls of over-diversification often found in fund-of-fund investment strategies. Once we have selected active managers, we tend to keep them in place for the long haul. We believe hiring independent managers to run high-conviction strategies is a far better approach to multimanager portfolios. Asset allocation guidelines for multi-asset portfolios are developed by our Asset Allocation Committee, which comprises most of the investment professionals in Morningstar’s Investment Management group. Our investment professionals serve in different asset-class specialties on the committee. The committee jointly decides on organization-wide portfolio positioning policy, and strategy teams and portfolio managers adapt the positioning decision, as applicable, to their particular strategies and client portfolios. Teams of our portfolio managers are supported by the broad array of investment professionals within the Investment Management group, who contribute to manager research, asset-class research, investment-process the development and maintenance of portfolio enhancement, and management tools used in providing this service. All portfolios are reviewed by a team of peers before we deliver them to our Institutional Client. As for passive vehicles, our selection process begins with the thousands of exchange-traded products in the Morningstar database and includes the work of Morningstar and its affiliates’ ETF analyst team. Our own analysts perform qualitative work that can’t be found in an automated service. ETFs are often less expensive than their open-end mutual fund counterparts but assessing them has to go beyond this fact. We closely examine the risk characteristics that define ETFs—including tracking to the index, trading volume, bid/ask spread, and premium/discount—to help ensure the goals are realistic and the liquidity is what we expect. As with other funds, we assess ETFs within a portfolio context to achieve access to a particular market segment or sub- asset class. Individual stock selection relies heavily on our asset class research to identify attractive segments of the market (sectors, countries, or factors like quality) and a review of the valuations and fundamentals of the underlying stocks. We rely heavily upon Morningstar’s Equity Research group in addition to our own proprietary insights. Managing Portfolios Once we’ve holistically built portfolios, we manage them. This part of the process is simply continuing to find opportunities, thinking through ways those opportunities might be included in our portfolios, and watching markets closely for any signs that would call for adjustments within the portfolio. Portfolio management is not a stop/start process. We constantly review our positions, seeking to maximize reward for risk. Each strategy we manage has a set of investment guidelines that outline the investment objectives, risk levels, and investment constraints. These are monitored to stay within the defined ranges. As valuation-driven investors, we primarily focus on price changes relative to fair value through time. Given that markets are dynamic, we reassess the portfolio given the changes in investment ideas, aggregate risks, and portfolio exposures. This iterative process reconsiders the opportunity set, with a constant eye on fundamental diversification and portfolio allocations. Specific to our Institutional Asset Management service, the portfolios we build for an Institutional Client are typically constrained to a universe of investment options defined by our client, which include their affiliated investment products in some instances. Our analysis will still include quantitative analytics and fundamental research on the investment options available. We draw on Morningstar’s comprehensive database of fund and security analytics as well as utilizing portfolios information provided by our Institutional Client, if applicable. In some instances, we work closely with our ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 8 of 22 Turnover and trading reduce returns for investors and therefore any changes should be expected to add value by a comfortable margin. Investment decisions happen in the real world rather than on paper—transaction costs and taxes are real. This means being biased toward inaction and long-term holdings, keeping turnover and transaction costs as low as possible. Morningstar Funds Trust Valuation The Morningstar Funds Trust’s Board of Directors has oversight responsibility for the Morningstar Funds Trust’ portfolio valuation and pricing practices but has the discretion to delegate authority to the adviser or sub-adviser of the funds. Fair valuation matters are also addressed within the Morningstar Funds Trust’s valuation policies and procedures. Our global investment team works around the clock to understand markets and opportunities, monitor risk in existing portfolios, and vet ideas to make investment changes. This ongoing investment process powers every portfolio managed by the entities within Morningstar’s Investment Management group. Morningstar Funds Trust Subadvisor Oversight and Multi-style Management We are responsible for hiring, terminating, and replacing sub-advisers to the Morningstar Funds, subject to board approval. Before hiring a sub-adviser, we perform due diligence on them including, but not limited to, quantitative and qualitative analysis of their investment process, risk management, and historical performance. We are responsible for the general supervision of the sub-advisers as well as allocating each Morningstar Fund’s assets among the sub-advisers and rebalancing the portfolio as necessary, the timing and degree of which will be determined by us. We have processes and risk controls in place at multiple levels of the investment process to ensure that our portfolios are created in a manner consistent with their risk and return objectives. We evaluate risk at both the asset class model level and the portfolio level. At the asset class level, we monitor easily observable metrics such as standard deviation, skew, kurtosis, historical beta and overall tracking error relative to our stated benchmark. Our standard deviation and covariance matrix figures are estimated by a proprietary factor analysis system that ensures consistency across multiple asset classes and time periods. We delve deeper by examining conditional value-at-risk and conducting scenario analysis testing under different market conditions. At times, allocation adjustments among sub-advisers may be considered tactical with over- or under-allocations to certain sub-advisers based on our assessment of the risk and return potential of each sub-adviser’s strategy. Sub-adviser allocations are also influenced by each sub-adviser’s historical returns and volatility, which are assessed by examining the performance of strategies managed by the sub-advisers in other accounts that we believe to be similar to those that will be used for a Morningstar Fund. We have retained the following investment advisers to act as a sub-adviser for the listed Morningstar Fund Trust fund pursuant to a sub-advisory agreement: Sub-adviser Portfolio Sub-advised Morningstar U.S. Equity Fund Morningstar U.S. Equity Fund At the portfolio level, we conduct a detailed style analysis of our underlying funds using holdings information, quantitative regressions, and manager meetings. The underlying styles allow us to determine the effective rolled up portfolio asset class exposures and compare them to our asset allocation targets. Further, we analyze each manager’s style consistency to make sure we monitor and adjust for huge swings in our effective asset class exposures. This analysis ensures that we are aware of, and comfortable with, our effective asset class exposures. Additional analysis is done routinely to measure our fund portfolio duration, tracking error, sector exposures and betas. Morningstar U.S. Equity Fund Morningstar U.S. Equity Fund ClearBridge Investments, LLC Diamond Hill Capital Management, Inc. Massachusetts Financial Services Company, d/b/a MFS Investment Management Wasatch Advisors, LP d/b/a Wasatch Global Investors Westwood Management Corp. Harding Loevner LP Harris Associates L.P. While actively managed portfolios will exhibit certain biases in terms of asset class weightings or security characteristics relative to their blended benchmarks at times (based our intended investment decisions and the actions of the underlying managers), they are constrained by setting minimum and maximum allocations to different asset classes, as stated in our investment policy guidelines. Establishing allowable ranges for asset classes helps enable the strategy to take advantage of opportunities and avoid risks at the asset class level, but also keeps the portfolios tethered to their blended benchmarks. Lazard Asset Management LLC T. Rowe Price Associates, Inc. Morningstar U.S. Equity Fund Morningstar International Equity Fund Morningstar International Equity Fund Morningstar International Equity Fund Morningstar International Equity Fund Morningstar Global Income Fund Morningstar Global Income Fund Ongoing monitoring of the underlying position weights is critical to keeping the portfolio exposures as intended. Each fund is assigned a target position and a “deviation threshold,” which governs the degree to which a fund may sway from its target. Each fund has a different degree of latitude, based on both its weight in the portfolio and the volatility of the assets in which it typically invests. If a fund deviates from its target weight, we evaluate whether the accounts that contain the fund need to be adjusted (i.e., rebalanced) to bring the alignment back in order. Cullen Capital Management, LLC Western Asset Management Company, LLC BlackRock Financial Management, Inc. Allspring Global Investments, LLC T. Rowe Price Associates, Inc. First Pacific Advisors, LP Loomis, Sayles & Company, L.P. TCW Investment Management Company LLC Morningstar Total Return Bond Fund Morningstar Municipal Bond Fund Morningstar Municipal Bond Fund Morningstar Defensive Bond Fund Morningstar Multisector Bond Fund Morningstar Multisector Bond Fund For registered or collective investment products we manage on behalf of an Institutional Client, we review and revise portfolio allocation targets on a continuous basis to ensure that asset class targets outlined in the prospectus are maintained. Reviews are implemented to ensure that the underlying investments in the portfolio don’t exceed allocations noted in the product’s prospectus or breach other restrictions. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 9 of 22 Voya Investment Management Company, LLC Lazard Asset Management LLC Morningstar Multisector Bond Fund Morningstar Global Opportunistic Equity Fund Morningstar Alternatives Fund Morningstar Alternatives Fund Morningstar Alternatives Fund SSI Investment Management LLC Water Island Capital, LLC BlackRock Financial Management, Inc. We use historical data for these benchmarks/proxies in an attempt to forecast the expected return, standard deviation, and cross-correlation of the asset classes. We use multiple statistical techniques to extend the returns data for all domestic equity asset classes back to 1926. Fixed income and non-U.S. equity asset classes go back to 1970, due to significant structural changes in the fixed income market that made the interest rate environment since 1970 inherently different from previous periods. We then use a "building-blocks" approach to set expected returns for asset classes. The return building blocks are based on forward-looking assumptions about an asset's underlying economic and corporate fundamentals. We use historical data to help forecast standard deviation. Since most data series only extend back to the 1970s, we use the ratio method to extend the standard deviation estimates of the shorter-lived asset class benchmarks so that they incorporate relevant economic events. The ratio method attempts to extend the standard deviation estimate for certain asset class benchmarks using a short benchmark (an asset class benchmark that does not have historical data over the full, relevant time period starting from 1926 for domestic equities and 1970 for fixed income and non-U.S. equities) and a long proxy (an index that has historical data over the full, relevant time period and is economically similar to the short benchmark). The ratio method leads to an estimate of what the standard deviation of the short benchmark would have been had it existed over the full, relevant period. Sub-advisers have discretionary authority to determine, subject to each portfolio’s investment policies and restrictions, the securities in which the portfolios advised by them will invest, which may include domestic and foreign equity securities, warrants, derivatives, delayed settlement securities, commercial paper, certificates of deposit, investment company securities, United States government securities, and options, futures, and forward contracts. The sub-advisers employ proprietary methods of securities analysis in making investment decisions for the portfolios and may rely upon a variety of sources for information, including internally generated research. In making investments on behalf of the portfolios, the sub-advisers may employ investment strategies and techniques which include long and short-term purchases, short-term trading, short sales, derivatives, and options writing. Potential investors in the Morningstar Funds Trust should carefully read the prospectus, statement of additional information and/or portfolio’s offering documents for additional information on each portfolio’s investment objectives, risks and restrictions. We use correlation coefficients based on the historical returns of the asset class benchmarks from 1970 to the present. Correlation coefficients must be extended for series that do not have history for the full relevant period. In an attempt to create this history, we use a sophisticated statistical process that extends asset class benchmarks that do not have complete data histories but that have a relatively high correlation coefficient with another proxy (or benchmark). This estimate approximates what the correlation coefficient between the two series might have been if both had existed over the longer period. Custom Model Portfolios For our Custom Model Portfolios service, we build portfolios for Institutional Clients that are typically constrained to a universe of investment options defined by our client, which include their affiliated investment products in certain situations. Our analysis includes quantitative analytics and fundamental research on the investment options available. We draw on Morningstar’s comprehensive database of fund and security analytics as well as utilizing portfolio information provided by our Institutional Client, if applicable. The capital markets assumptions that help inform the portfolio construction and wealth forecasting aspects of our advisory services are updated periodically to reflect our expectations of the capital markets. The detailed asset allocations of the target-date models are strategic in nature and are closely tied to our long-term, unconditional capital market expectations (rather than our valuation-implied returns). Moreover, the allocations do not change significantly on a year-over-year basis. We believe that asset allocation policy is one of the most important determinants of a portfolio’s risk and return characteristics over time. When constructing a model portfolio, we believe it is critical to take advantage of potential diversification benefits over the long run. The primary objective of our investment selection process is to find the best combination of investment options that will maximize alpha (excess return above a benchmark) for any given level of tracking error (risk/standard deviation of the alpha), while maintaining the appropriate target asset allocation. As part of our overall process, we continually search for ways to enhance our inputs, understanding of market behavior, and forecasting methodology to provide our clients with optimal advice. We use a six-step investment process that relies on a number of complex optimization routines to find the right mix of asset classes and managers to meet our objective. We use the following six-step process to construct an investment portfolio for our custom models: Each year, we update the capital market assumptions. We focus on return forecasts over multiple time horizons: 10 years, 20 years, and long-term unconditional expected returns. The 10-year forecasts assume that various valuation metrics will return to “fair value” over a 10-year period. Similarly, the 20-year forecasts assume the return to fair value for the various valuation metrics will occur over a 20-year period. The long-term unconditional expected returns do not have a valuation component, essentially assuming the markets are fairly valued. Step 2: Total Wealth: Building Glide Paths Our method for creating glide paths builds on our asset-allocation expertise and applies a total wealth approach. When determining the optimal portfolio for investors, we take a holistic view of their total wealth so we can construct Step 1: Asset Class Inputs Asset class performance expectations are critical in developing a diversified portfolio that aims to help meet an individual’s retirement income goal. We rely on the capital market assumptions described in the section above. We forecast expected risk and returns for each asset class under consideration by gathering and analyzing a broad range of data points, including historical data, current market information, and the correlations between asset classes. More details on this step are provided above, in the Capital Market Assumptions section. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 10 of 22 the most appropriate glide path based on the total value and risk attributes of the different assets owned by that investor. Our total wealth approach considers assets that are often overlooked, like human capital and pension wealth. Human capital can be thought of as the present value of an individual’s future wage income, whereas pension wealth represents assets like Social Security retirement benefits and defined benefit pensions. into an aggregate cohort portfolio (e.g., into a 2040 Target Date portfolio). These cohort portfolios can then be viewed in combination to form the glide path. The actual portfolio selected to represent a given cohort can be based on a number of different factors, and it is possible for us to create different glide paths for different groups of employees (e.g., hourly versus salary, union versus non-union). This enables to determine the relative difference for different employee groups and cohorts. It is worth noting that our glide path approach is not static, and the actual portfolios will change over time based on the risk characteristics of the defined contribution plan participants in that cohort. A fundamental part of our total wealth approach requires an understanding of how an individual’s wealth changes over their lifetime. For example, the total wealth of younger investors is almost always dominated by human capital. As individuals age, they tend to save money for retirement, accumulating financial assets and accruing benefits in pension plans such as Social Security. In other words, most investors convert a portion of their salary over time into financial capital by saving and accruing pension benefits, which can be used to fund retirement. Step 3: Asset Allocation Using our total wealth approach, we first create the stock/bond allocation for an investor and then determine the asset class targets for the portfolio. We use some of the most advanced asset allocation techniques to determine these weights. Three examples include: our proprietary approach to formulating capital market assumptions; how we incorporate non-normal returns and downside risk in the portfolio optimization routine; and how we build portfolios based on the specific objectives of the investor. Human capital is a relatively bond-like asset. We say “relatively” because the riskiness of human capital varies across business cycles, by job skills, and by the individual’s occupation or industry. Our research suggests that, for the average investor, human capital is approximately 30% stock-like and 70% bond-like. Individuals with riskier human capital who have jobs in cyclical industries should have more conservative portfolios, and individuals with secure jobs and stable incomes can invest in more aggressive portfolios. Younger workers typically have higher weights to human capital as a function of their total wealth. Because human capital is untradeable, from a total wealth perspective these young workers have an overweight to a bond-like asset. As the median plan participant’s overall economic situation evolves and as the participant transitions from accumulation into drawdown, the asset allocation evolves throughout their lifetime. Overall, as investors age, we believe asset allocations should have a more pronounced home country bias to help pay for their U.S. dollar denominated retirement income liability (e.g. a real inflation adjusted income in retirement) and shift from growth- oriented asset classes, such as small cap equities to lower-risk, high-quality asset classes such as U.S. large cap equities. Additionally, we find intra- bond allocations should gradually shift from high-return, long-duration, nominal-bond-oriented asset allocations towards a less volatile, shorter- duration, real-return-oriented asset allocation. That’s why their financial assets should generally be invested more aggressively to achieve a more balanced risk level from a total wealth perspective. When the relative value of human capital (as a percentage of total wealth) declines as the individual ages, financial capital often needs to be invested more conservatively to balance the risk of the total wealth. Step 4: Analyze Investment Options Investment screening is particularly important when working with investment menus that have many options for an investment option-level model portfolio from which to choose. Once we’ve built the asset allocation targets for the portfolio, we determine which investment options from the lineup to use to meet our asset class targets and our standards for quality. Our selection process relies on both quantitative and qualitative measures. The selection criteria we use to narrow the available universe include manager experience, performance record, manager history, alpha, style consistency, fund type, and fund fees. Here is an overview of the some of the key steps: Risk tolerance and risk preference are often used interchangeably, but we treat them as two related, but different, concepts. Risk tolerance should be driven by risk capacity and risk preference. Risk capacity is an investor’s ability to take on risk given the composition of his or her total wealth, while risk preference is the individual’s desire to take on risk. These two types of risk combine to determine an appropriate total wealth allocation for participants. Our approach to constructing the glide path is based on a significant number of assumptions. At a high level, our approach to determining the glide path is based on using the financial assets (i.e., the 401k plan balance) as a “completion portfolio” that is optimized based on the other assets owned by the investor and the risk attributes of those assets (a concept referred to as background risk). Determining the glide path effectively means determining the appropriate stock/bond split for different retirement investors, we generally refer to this process as “portfolio assignment”. Our approach towards portfolio assignment considers an individual’s total wealth, of which human capital is a dominate asset for younger individuals. Once investment options pass the initial screening, we then peer group all remaining funds for further analysis. The peer grouping process begins by evaluating investments based on their Morningstar Category (if available). Returns Based Style Analysis (“RBSA”), which looks at the “behavior” of an investment option rather than its actual holdings, is used to determine the appropriate category, because it takes a longer-term view of an investment option’s style and consistency, which is important for peer grouping. The category is validated through a series of regression analyses against sets of benchmark returns. The Morningstar Category determines which set of benchmarks is used in the initial regression. Based on this initial regression result, R-square, and benchmark exposures, the investment option may be sent for further regression analysis to better determine the appropriate peer group. If the R-square of the final regression is greater than or equal to 65, then the peer group is assigned. If through all sets of regression analysis, the investment option does not achieve an R-square of 65 or greater, then the investment option is unclassified and may not be used. When building a glide path, we determine the optimal allocation for each retirement investor individually and then aggregate the individual allocations ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 11 of 22 If an investment option is not a public fund or does not have a Morningstar Category, the same process is followed, but the initial set of benchmarks used in the regression analyses is a general set. Again, the investment option goes through a series of regression tests to determine the best peer group fit. This alpha-tracking error optimization is similar to MVO described earlier. MVO is conducted using as inputs the expected return, standard deviation, and correlations of the asset class returns. The alpha-tracking error optimization, however, is conducted using the FLA and tracking errors of each investment option. The asset class exposures of the available investment options are determined using HBSA. One of the quantitative inputs we use when constructing fund-level portfolios is a proprietary measurement known as forward-looking alpha (“FLA”). This measure helps us identify managers that we believe will add alpha and help drive the long-term positive performance of their portfolios. HBSA calculates the exposure of a fund based on the characteristics of each of its underlying securities. The most recent portfolio available in our database is used for this analysis. In addition, there are certain tolerances, constraints, and maximum fund allocations. FLA uses historical data to forecast how well an investment option is likely to perform in the near-term future. Unlike traditional methods of calculating alpha, FLA is based on alpha over two time periods (12 months and 60 months), and rewards managers for consistent performance over both the short and long term. By using these two time periods, we believe that they are better able to predict how a manager might perform in the future. The alpha-tracking error frontier offers an entire spectrum of efficient allocations among all funds for the target asset allocation. We select the appropriate portfolio based on multiple iterations of evaluating possible outcomes, starting with a higher emphasis on alpha (i.e., portfolios with higher excess returns). If the portfolio is found to be outside these tolerances, the emphasis on alpha is lowered and a new set of portfolios is generated for evaluation. The final step is to generate portfolios that place all the emphasis on the tracking error, to help ensure the asset allocation targets are met. If at this point the portfolios generated are not within the tolerances set, including hitting the asset allocation targets, then the investment menu would not qualify for our advice services. This multiple iterative process helps ensure that for each portfolio the investment options chosen maximize the potential portfolio alpha within the tolerances for tracking error while hitting the asset allocation targets. From the investment options that pass all of the prior screening criteria above, we will form a “main” list, and ultimately a “select” list of the funds that are included in the final fund optimization process. However, arriving at the select list is a two-tiered screening process. To form the main list, index funds are ranked by their tracking error. The top two funds in each peer group (with the lowest tracking error) form the main list. When there aren’t enough index funds available, the actively managed fund with the lowest tracking error is chosen instead. The two index funds on the main list are then ranked by expense ratio, and the one with the lowest expense ratio is included in the select list. Actively managed funds are evaluated based on their information ratio and FLA. The three funds in each peer group with the highest information ratio and FLA form the main list. Active funds are then ranked on R-square relative to a single peer-group primary benchmark, the number of years the fund outperformed its customized benchmark from the RBSA results over the past five years, and a customized consistency score from the RBSA results. One fund from the “highest information ratio” main list and one fund from the “highest FLA” main list, each with the highest average score, form the select list. We first attempt to build fund-level portfolios at the highest level of complexity/granularity. The large-, mid-, and small-cap asset classes are split into growth and value; aggregate bonds are split into long- and short-term bonds. If we are unable to hit the asset class targets at the highest complexity, then a second attempt is made at a lower complexity. The process continues until the asset class targets are met (within the tolerances), while minimizing tracking error and maximizing alpha. If an investment menu fails at all of the asset class complexities, we will not be able to construct fund-level portfolios. Step 6: Monitor the Portfolio Once the portfolio is constructed, we will monitor and re-evaluate the investments on an ongoing basis to ensure it is still aligned with asset allocation targets and diversification objectives. In addition to using the above quantitative steps based, we may also consider qualitative measures such as an investment option’s holdings, style changes, style drift over time, manager changes, and SEC actions. These qualitative steps are mainly used when the quantitative results are questionable due to low statistical significance, quantitative results differing from expectations, or simply to ensure that the quantitative techniques are accurate. For example, this analysis may help confirm the peer group and style analysis, confirm that the processes in place that generated past returns are still relevant, and gives us an opportunity to apply human judgment to the process. When a new fund is added to an investment menu, we reevaluate the new investment mix and determines if new asset class and fund-level model portfolios are necessary. When a fund that is used in a portfolio is dropped from a plan menu or closes, the plan’s portfolios will be immediately rebalanced, as it would not be possible to implement the existing fund-level portfolios. Step 5: Construct the Portfolio Once we determine the asset class models and which funds from the plan’s lineup will be included in the portfolio, our portfolio construction team then determines what combination of these funds will help us reach our asset class weights. The team also considers the combination of funds that we think will help drive the portfolio’s performance in the future. Using the select list, we construct the fund-level model portfolios using a proprietary alpha-tracking error optimization process. The primary objective is to find the best combination of investment options (for each of seven risk levels) that will maximize the FLA for any given level of tracking error, while hitting the asset class allocation targets. We monitor fund lineups on a quarterly basis to determine if changes are needed. We review and rebalance the fund-level portfolios quarterly. We’ve established a range of +/– 5% based on the most recently delivered fund- level allocations to prevent large fluctuations in investment option allocations from quarter to quarter. If a more attractive alternative is present, an investment option will be phased out over time rather than in one quarter, to minimize large portfolio reallocations on a quarterly basis. This approach also helps to minimize short-term redemption fees to investors, should they exist. All asset class model portfolios are updated annually, as we review and ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 12 of 22 update the MVO inputs (expected returns, standard deviations, and cross- correlation). extensive experience in evaluating investment managers to analyze the people and process behind the investment. In doing so, our goal is to anticipate how an investment option is likely to be positioned in the future, which helps us build expectations of performance and capability of consistently playing a specific portfolio role. In our fundamental assessment, we review a number of characteristics of the investment option and its manager that could be relevant to how well it can fill the role for which it is being considered. Those include reviewing the manager’s performance and risk record against his or her peers in the same style—not just at the manager’s current fund but also any other investment vehicles they’ve managed in the past. We analyze the subtleties of the manager’s investment process to understand what drives performance. We observe which types of markets the investment option fares best in and which types are trouble for its style. We also determine what it is about their style that explains the performance pattern. Fiduciary Services Investment Selection for Investment Lineups For our Fiduciary Services, the lineups we build for an Institutional Client are typically constrained to a universe of investment options (typically a subset of the entire universe of investment options publicly available for purchase by investors) defined by our client, which include their affiliated investment products in certain situations. We have no ability to choose the investment options that are made available under our Institutional Client’s products and contracts and may have more favorable opinions of certain investment options which are not included in the defined universe of investment options. Our analysis includes quantitative analytics and fundamental research on the investment options available, holdings-based style analysis to determine an investment’s style over time. We draw on Morningstar’s comprehensive database of fund and security analytics as well as utilizing portfolio information provided by our Institutional Client, if applicable. We assess whether a manager’s investment process leads to a more aggressive or more conservative performance profile relative to its style peers, and how a manager’s process might lead to persistent over- or under- weights in certain sectors. We also assess how performance, both absolute and relative to a peer group, has changed as a manager’s assets have grown. When analyzing investment options or managers for use in a lineup, our goal is to determine their true investment style, identify what we believe to be best-in-class managers, and identify the factors contributing to their performance and risk characteristics with the aim of assessing whether their performance appears to be sustainable over time. We use many factors to evaluate funds depending on the specific situation and the questions we are trying to answer including investment sub-style, manager skill, impact of asset growth on performance, sources of investment ideas, investment decision-making process, actions in previous market environments, manager ownership, process repeatability, and performance attribution. Our qualitative assessment of a fund will draw on Morningstar’s forward- looking Morningstar Medalist RatingTM, when available, for additional perspective in evaluating factors such as those noted above. We start with a propriety peer grouping analysis using the available investment options. Once investment options have been placed into their appropriate peer groups, our methodology begins with a quantitative review process. First, we apply a series of screens designed to flag funds that exhibit characteristics that are apt to hinder long-term performance in order to efficiently filter a large universe of investment options to focus our efforts on a more manageable opportunity set. Second, we use a multitude of statistics to begin to assess the overall quality of an investment option. We gather current and historical data points to evaluate investment style, structure, and performance and consider key factors that include fees, management tenure, style consistency, alpha, volatility, fund size, asset class exposure, and holdings concentration. We conduct further style analyses on managers that pass our initial screens to identify nuances of their strategies. Just as important as selecting qualified managers is determining how well an investment option will fit with other investments in the lineup. We want each investment to fill a distinct stylistic role within a plan lineup, so we carefully assess how it can be expected to complement other options we are recommending in adjacent styles. In general, we want to have a number of strategies investing in a specific space while employing different investment approaches. Lineup Design and Construction The area of behavioral finance has shown that investors don’t always behave rationally and that the manner in which a problem is posed can impact individual actions. We are mindful of simple heuristics employed by retirement investors in making investment-related decisions and design lineups that attempt to drive better action on the part of investors. When constructing a lineup, we consider issues around choice overload, naïve allocations, and loss aversion. We strive to select investments to fill a distinct stylistic role within a lineup and carefully assess how each investment can be expected to fit with other investments. We strive to choose funds that are clearly different from one another, rather than similar or redundant. The goal is to establish a specific role for each investment option in the lineup that minimizes holdings overlap and maximizes diversification. To accomplish this, we rely largely on a holdings-based style analysis to build a picture of an investment option’s style positioning based on its underlying holdings. This means drilling down to examine the asset class exposure within the investment option. We evaluate overall diversification to ensure that the investment option is not exposed to undue security or sector specific risk. The goal is to provide a selection of investments that are likely to meet their investment mandate, but also to provide options that differ in their pursuit of that objective. Managing Lineups We formally review investment options in our investment lineups quarterly. The majority of our watch-list notifications (a notice to indicate an investment option is under extra scrutiny due to factors such as performance, risk, straying from its stated investment style, or management changes) and approval changes occur on a regular quarterly schedule. However, we are always monitoring our approved investment options and if something occurs intra-quarter that we believe merits immediate action, we will take action outside of the normal review schedule. When an investment option is removed by one of our investment professionals, a memo to the plan is produced outlining the rationale for such After an extensive quantitative review, we review an investment from a qualitative perspective. The purpose here is to allow our investment professionals to gain conviction in their investment thesis by developing a firm fundamental understanding of the strategy. Our professionals draw from their ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 13 of 22 a decision, and for Institutional Clients of our 3(21) services, a timeframe is typically noted for a plan to make a particular change. If the plan opts out of the replacement investment option or fails to choose a replacement investment option from the approved list of investment options, the plan is terminated from the service. A negative consent process for changes can also be implemented wherein an investment option change is automatically implemented if the plan does not take any action within a specified window of time. For Institutional Clients of our 3(38) services, we will direct the plan’s provider to implement the change as detailed in the memo. For Institutional Clients utilizing our Fiduciary Services website, notices are sent to the plan sponsor via the website portal. For those Institutional Clients who opt to own communications to plan sponsors, they are responsible for creating their own notifications, but we will provide memos outlining our rationale for any change decision. In creating recommendations, we believe that the more information the retirement investor provides to us, the better the investment strategy we are able to deliver. We collect information the plan provider, plan sponsor, or other service provider is able to provide to us, which is pre-populated into the user interface. The retirement investor is prompted to provide any additional data that wasn’t available from other sources. After collecting those key pieces of data, the user is presented with an initial strategy as a starting point. The retirement investor can model many scenarios by changing variables such as retirement age, desired retirement income, and savings rate. We will dynamically update the retirement investor's retirement strategy to reflect any changes made. The retirement investor is also encouraged to enter, and/or use an account aggregator to enter, additional information for savings earmarked for retirement such as out-of-plan assets or benefits for themselves or their spouse/partner (“outside assets”) in order to further personalize the recommendations. They can provide detail regarding the investments or select from one of the pre-defined investment styles. We do not provide investment specific advice on outside assets but provide an asset allocation recommendation for outside assets as a whole and will take those into consideration when determining the investment strategy for the retirement account. The portfolio recommendation for the retirement account will take into consideration the amount of advisable retirement account relative to outside assets as well as the equity/fixed composition of those outside assets. Managed Accounts, Advice, and Guidance Investment Process In providing Managed Accounts and Advice, we start with the five-step investment process detailed above in the Custom Model Portfolios section to build model portfolios. In providing Guidance, we use the first two steps of the investment process described above in the Custom Model Portfolio section to create an asset allocation model. Data incorporated in the recommendations include the plan’s or product’s investment lineup and for retirement plans, plan design requirements such as plan limits and matching formulas. We start with all of the available retirement investor-specific data and then makes assumptions about certain pieces of information. A retirement investor can review and refine some of these assumed data points through the user interface. These assumptions can have a significant impact on the strategies we will create for them and are related to social security income, salary growth, retirement age, inflation rates, estimated taxes, retirement income goal, and risk capacity. We combine this information with other factors into a proprietary software program that can provide investment recommendations and a projection of different outcomes. Using this model, we develop an investment strategy tailored to each retirement investor’s investment goals. For these services, the portfolios we build are typically constrained to a universe of investment options defined by our Institutional Client, which include their or Sub-Adviser’s affiliated investment products in certain situations. Our analysis will still include quantitative analytics and fundamental research on the investment options available. We draw on Morningstar’s comprehensive database of fund and security analytics as well as utilizing portfolios information provided by our Institutional Client, if applicable. For those retirement investors that are accumulating for retirement, our investment strategy is generally based on information such as their retirement account balance, expected retirement age, contribution rate and other preferences. If a retirement investor has already retired, and our Institutional Client makes available our In-Retirement services, our strategy is based on information such as their current account balance, additional cash flows and life expectancy. This retirement strategy may include some or all of the following: use a combination of model portfolios and customization as part of a We larger portfolio construction and fund implementation process. For Managed Accounts and Advice, we generate hundreds of unique model portfolios (ranging from conservative to aggressive) for each retirement plan or product using a customized approach to blending traditional asset allocation models with liability-driven investing and decumulation strategies. Which asset classes and sub-asset classes are used to build these model portfolios is dependent on the specific investment lineup for each retirement plan or product. We always try to build the model portfolios with the greatest number of sub-asset classes, but this is contingent on whether the investment options available can fulfill each asset class. Retirement Income Goal (accumulation phase). We define the retirement income goal as the projected amount of money that the retirement investor will need during retirement. We calculate this amount based on current income, adjusted to reflect the estimated dollar value at retirement age. Typically, we use an amount equal to 100% of take-home pay, however, some plan or service providers request we use a different rate. We then project the value of that amount at retirement age to determine the retirement income goal. A retirement investor using our user interface has the option to change this projected retirement income amount. Each retirement investor that receives investment advice as part of Managed Accounts or Advice is assigned into one of up to 589 model portfolios for the account we advise on (“retirement account”). The large number of model portfolios is to address the personalization that is needed by retirement investors. These model portfolios account for not only varying equity/fixed- income allocations but also how close the individual is to retirement. As the individual nears retirement, the sub-asset allocation changes to reflect a liability-driven investment overlay used in the model portfolios for a retirement investor near or in retirement. Any change within the model portfolios is reflected at the individual level as soon as the retirement investor is reevaluated each quarter. Income Outlook (accumulation phase). We define the income outlook as a projection of the annual income that the retirement investor may receive during retirement. We base this on an annualized view of the investment wealth accumulated, combined with social security benefits and any pension or other income the retirement investor might receive. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 14 of 22 Total Retirement Income (in-retirement phase). For those plans that offer our In-Retirement service, we define total retirement income as the projected amount of money, typically at some level of probability that the retirement investor can expect to receive on an annual basis in order to maintain income throughout retirement. take Social Security into consideration while analyzing income replacement. We default to the age at which the retirement investor will receive full benefits from the Social Security Administration. Retirement investors can adjust the benefit amount and start age if desired, however, the start age must be between the ages of 62 and 70. For our Advice services, many of our Institutional Clients offer a similar experience to retirement investors either through our user interface or their proprietary user interface. Salary Growth - To estimate future salary, we use a salary growth curve based on academic research rather than assuming a single, fixed growth rate. This curve takes into account the fact that salaries tend to grow most rapidly for young employees, peak around age 51, and then slightly decline later in life. Retirement Age - We assume a default retirement age of 65, or the retirement investor’s current age plus one year if they are older than 65. Retirement investors have the option to change this to a different retirement age. We believe in long-term strategic asset allocation based on an individual’s risk capacity. Changes in an investor’s financial situation, such as the addition of outside retirement accounts, pension benefits, or contribution rates, can result in a change to their model portfolio assignment. In addition, changes to their personal situation, such as the addition of a spouse or partner or a different retirement age, could also impact the model portfolio assignment. For Managed Accounts, we will typically review portfolios on a quarterly basis to determine if market shifts require a rebalancing of the portfolio. Retirement investor wealth re-forecasting occurs on an annual basis for our Managed Accounts service. For Advice, we encourage retirement investors to re-enter our user interface on a periodic or as-needed basis, in order to review their information and receive an updated strategy. At a minimum, we recommend that a retirement investor’s portfolio is rebalanced on an annual basis. At this point, the retirement investor is one year closer to retirement, and we will shift them along their glide path. Income Projections – A retirement investor’s income projection is the level of annual income we project the retirement investor has at least a 70% chance of achieving and is calculated for both the retirement investor’s current strategy and our proposed strategy. We use forecasts for investment returns, portfolio risk, and correlation for each of the 12 asset classes and an average expense ratio for each asset class to estimate investment fees. The projections consider different scenarios for life span, based on standard published mortality tables (based on the Society of Actuaries Individual Annuity Mortality (IAM) table). We assume that the retirement investor’s risk capacity (and corresponding asset allocation) will change over time, generally growing more conservative as they approach retirement, and that their savings rate will not change. Our projections are provided based upon an investor’s personal financial situation using our total wealth approach. We use MVO, resampling the mean-variance outputs using a Monte Carlo simulation, and our process incorporates liability-relative optimization. We solve for a specific probability of success when determining the sustainable retirement income. The Monte Carlo simulation uses our long-term capital market assumptions when projecting the future returns for the various asset classes. Estimated Tax - We estimate federal and state income, and capital gains taxes based on marginal tax rate calculations. Tax data is updated annually based on U.S. Internal Revenue Code (IRC) and similar state tax data. We use income data for the retirement investor, as well as for a spouse/partner, to estimate federal and state tax exposure. Tax exposure is appropriately reduced for pretax deferrals, tax-deferred capital gains, and yield and distribution of Roth proceeds. Based on the information we know about the retirement investor, we provide an estimate of tax exposure but may not include all tax considerations. Approximately 20,000 cases are used to routinely test engine functionality to help ensure our recommendations are in line with our expectations. The test data consists of real retirement investor information as well as generated cases, and covers a gamut of possible ages, balances, salaries, and other optional data points. Running these cases and analyzing the results help ensure we are confident in the advice we provide retirement investors. Inflation Assumptions - When projecting the growth of various income sources and expenses, we use a variety of different inflation rates. These rates are reviewed and updated annually by our research team. Different inflation rates are used for different projections and major expenses. We believe that our multifaceted approach to calculating inflation results in more realistic and more accurate projections compared with using one set rate. IRS Limitations and Application of Penalties - We incorporate all IRS contribution limits, eligibility requirements, and withdrawal penalties into the retirement strategies. Brokerage Accounts - Some plan sponsors allow retirement investors to maintain a brokerage account within their retirement plan. If allowed this option, the retirement investor will be responsible for managing and monitoring those assets. We do not manage brokerage account assets; however, if the retirement investor provides us with detailed information on the holdings within the brokerage account, our methodology will consider these holdings in developing an appropriate investment strategy for their retirement account. If the retirement investor does not provide detailed information, our methodology will assume that the balance in the brokerage account is 52% stocks and 48% fixed income. Key Assumptions Social Security - We can incorporate Social Security for both the retirement investor and their spouse. This can be calculated using an estimate based on calculations/formulas from the Social Security Administration or input by the retirement investor. To calculate the estimate, a retirement investor/spouse must have 35 years of contributions. If the retirement investor/spouse has more than 35 years of service remaining, all projections are forward-looking. If the retirement investor/spouse has fewer than 35 years of service remaining, the difference in contributions is back-calculated. Social Security payments are inflated using a simulated cost-of-living allowance designed to replicate the actual Social Security Administration formulas and are applied at the maximum benefit age as defined by the Social Security Administration. Retirement investors can override the estimate by including information from their Social Security statement. In addition to standard payments, we account for reduction in payments while working in retirement, increases in benefits for the spouse 50% rule and increased benefits for the surviving spouse 100% rule. The program assumes the retirement investor/spouse completes all applications required to collect the maximum benefit. We treat Social Security as similar to income from fixed-income investments. We also ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 15 of 22 predict or forecast market fluctuations or other uncertainties that may affect the value of any investment. Asset allocation and diversification are investment strategies which spread assets across various investment types for long-term investing. However, as with all investment strategies, these strategies do not ensure a profit and do not guarantee against losses. in which they Capital market assumptions are forecasts which involve known and unknown risks, uncertainties, and other factors which may cause the actual results to differ materially and/or substantially from any future results, performance, or achievements expressed or implied by those projections for any reason. Past performance does not guarantee future results. Our Advisor Managed Accounts methodology is the same as our Managed Accounts and Advice methodology described above, except that we do not use our Custom Model Portfolios investment process to build the mode) portfolios. The model portfolios are built by our Institutional Client; with the exception of Sub-Advisers, we do not review their portfolios, nor do we have the ability to make any changes to those portfolios. If applicable under Advisor Managed Accounts, the plan sponsor or product provider is responsible for choosing the Sub-Adviser. However, we must agree to engage and are responsible for ongoing monitoring of the Sub-Adviser. In making portfolio recommendations, we are limited to those portfolios created by the Sub-Adviser but have discretion to reject or edit those portfolios if we feel necessary. The model portfolios created by a Sub-Adviser will typically consist of associated receive investment products compensation based on the amount of assets invested. These investment products generally must be added to the retirement plan or product lineup by the plan sponsor or product provider. You should be aware that the use of affiliated investment products gives the Sub-Adviser an incentive to build model portfolios using those investments. Income projections used in our Guidance, Advice, and Managed Account services are based on hypothetical performance data and do not represent actual or guaranteed results. Projections may vary over time and with each use of our service. Our recommendations are made without taking into consideration potential tax consequences and we do not provide tax advice. Potential tax consequences may exist. We encourage you to consult with a tax professional about these and other tax consequences. Enrollment Plan and product providers have the option to make one or more websites available to retirement investors for enrollment in Managed Accounts. You should be aware that the streamlined version of our enrollment process does not consider all information relevant to a retirement investor’s financial situation, including some of the information discussed in this section. (The streamlined process takes into account age, retirement plan or product type, and the balance, investment allocation, and contributions for their retirement account as provided by the retirement plan or product provider.) Retirement investors can access our full enrollment process at any time by logging into the Morningstar Retirement Manager platform through their Plan or product provider’s website. The full enrollment process allows retirement investors to provide us with additional information about their retirement situation and goals so that we can further customize their retirement strategy. If the retirement investor has additional retirement assets outside their retirement account, have a spouse or partner they’d like us to consider, want to restrict certain securities from being used in their retirement account, or want to change suggestions made in the streamlined enrollment process (i.e., savings rate), or if they want to see how changes would impact their retirement strategy, we encourage them to use our full enrollment process instead of the streamlined process. The Morningstar Funds Trust principal risks include multimanager and sub- adviser selection risk, active management risk, asset allocation risk, market risk, investment company/ETF risk, REITS and other real estate companies risk, master limited partnership risk, smaller company risk, sector focus risk, foreign security risk, currency risk, derivative risk, quantitative models risk, cybersecurity risk, European market risk, Asian market risk, China market risk, Japan market risk, emerging-markets risk, geographic concentration risk, cash/cash equivalents risk, private placements risk, interest-rate risk, call risk, credit risk, high-yield risk, convertible securities risk, preferred stock risk, contingent capital securities risk, US government securities risk, sovereign debt securities risk, mortgage-related and other asset-backed securities risk, floating-rate notes risk, loan risk, CDO risk, reverse repurchase agreement risk, dollar rolls risk, portfolio turnover risk, municipal securities risk, municipal focus risk, Latin America issuer risk, absolute return risk strategy, long/short strategy risk, short sales risk, supranational entities risk, indexed and inverse securities risk, and merger arbitrage risk. More information about the Morningstar Funds Trust’s risks can be found in the prospectus at http://connect.rightprospectus.com/Morningstar. Personalized Target-Date Fund Service With the Personalized Target-Date Fund Service, we start with a basic set of retirement investor inputs to generate a personalized asset allocation target. This target is then fulfilled by allocating to target-date funds available within the retirement investor’s retirement plan or product lineup. Our choice of funds is constrained to the universe of the retirement plan or product’s chosen target-date fund series. investment managers are combined with Information Sources Our global resources used in the formulation of our advisory services go down to our roots—the data and analysis from Morningstar that form the base of our investment process. This expansive, in-house network of global data and investment analysis spans asset classes and regions to help drive timely new ideas. Morningstar or its affiliates have more than 800 analysts and make data available on more than 600,000 investment options and 5.2 million privately-held companies. The extensive data, analysis, and methodologies from these resources, along with external research reports, data, and financial interviews with publications, annual reports, prospectuses, press releases, and SEC filings to serve as the basis of our primary sources of information. Risk of Loss and Strategy Risk Investments in securities are subject to market risk, risk of loss, and other risks and will not always be profitable. There is no assurance or guarantee that the intended investment objectives of our recommendations will be received. We do not represent or guarantee that our investment recommendations can or will predict future results, will successfully identify market highs or lows, or will result in a profit or protect clients from loss. Past performance of a security may or may not be sustained in the future and is no indication of future performance. A security’s investment return and an investor’s principal value will fluctuate so that, when redeemed, an investor’s shares may be worth more or less than their original cost. We are unable to For some of our services, we combine this information with other factors— including actuarial data, stock market exposure, probability analysis, and mean-variance optimization—into a proprietary software program to analyze a complex set of market data and variables that results in an advanced model ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 16 of 22 that can provide investment recommendations and a projection of different outcomes. Security Type Risks Mutual Funds and Collective Investment Trusts Investments in mutual funds and collective investment trust (CITs) funds involve risk, including loss of principal as a result of changing market and economic conditions and will not always be profitable. A collective investment trust may also be called a commingled or collective fund. CITs are tax-exempt, pooled investment vehicles maintained by a bank or trust company exclusively for qualified plans, including 401(k)s, and certain types of government plans. CITs are unregistered investment vehicles subject to banking regulations of the Office of the Comptroller of the Currency (OCC), which means they are typically less expensive than other investment options due to lower marketing, overhead, and compliance-related costs. CITs are not available to the general public but are managed only for specific retirement plans. issuing insurance company. Any such guarantee does not affect or apply to the investment return or principal value of the separate account and its subaccount(s). The financial ratings quoted for an insurance company do not apply to the separate account and its subaccount(s). The insurance company offering an annuity will charge several fees to investors, including annual contract charges that compensate the insurance company for the cost of maintaining and administering the annuity contract, mortality and expense risk charges based on a percentage of a subaccount’s assets to cover costs associated with mortality and expense risk, and administration fees that are based on a percentage of a subaccount’s assets to cover the costs involved in offering and administering the subaccount. An annuity investor can also be charged a front-end load by the insurance company on their initial contribution, ongoing fees related to the management of the fund and surrender charges (which can be substantial) if the investor makes a withdrawal prior to a specified time. If the annuity subaccount is invested in a money-market fund, the money market fund is not FDIC-insured, may lose money, and is not guaranteed by a bank or other financial institution. Annuities can be complicated, and an investor should carefully read the insurance company’s offering material to understand how a specific annuity’s return will be determined. Variable Annuities have a rate of return that varies with underlying investment options in the market, and do not include a guarantee from the insurance company that you will earn a return. Money Market Funds A money market fund may impose a fee upon the sale of shares or may temporarily suspend your ability to sell shares if the fund’s liquidity falls below a required minimum because of market conditions or other factors. An investment in a money-market vehicle is not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. For most money market funds, their sponsor has no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to the fund at any time. Although some money market funds seek to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. It is possible to lose money by investing in money market funds. Fixed annuities have a predetermined rate of return an investor earns and a fixed income payout that is guaranteed by the issuing investment company and may be immediate or deferred. Payouts may last for a specific period or for the life of the investor. Investments in a deferred fixed annuity grow tax- deferred with income tax incurred upon withdrawal, and do not depend on the stock market. Fixed annuities typically do not have cost-of-living payment adjustments and are regulated by state insurance commissioners. Stable Value Funds and Guaranteed Investment Contracts (“GICs”) The interest rate on a stable value fund or GIC is typically only guaranteed for a certain amount of time and may vary with changing market conditions. Withdrawal fees or penalties, sometimes substantial, may be charged if you decided to move money out of a stable value fund or GIC. Stable value funds and GICs are less likely to provide long-term protection against inflation, as compared to other options. Fixed indexed annuities, also called equity index annuities, are a combination of the characteristics of both fixed and variable annuities. Fixed indexed annuities offer a predetermined rate of return like a fixed annuity, but they also allow for participation in the stock market, like a variable annuity. Fixed indexed annuities are typically risker and offer the potential for greater return than fixed annuities, but less so than a variable annuity. Investments in a fixed indexed annuity grow tax-deferred with income tax incurred upon withdrawal and are regulated by state insurance commissioners. Target-Date Funds An investment in a target date fund is not guaranteed, and investors may experience losses, including losses near, at, or after the target date. There is no guarantee that a target-date fund will provide adequate income at and through an individual’s retirement. Exchange-traded Funds ETFs, like all investments, carry certain risks that may adversely affect their net asset value, market price, and/or performance. An ETF’s net asset value (NAV) will fluctuate in response to market activity. Because ETFs are traded throughout the day and the price is determined by market forces, the market price you pay for an ETF may be more or less than the NAV. Because ETFs are not actively managed, their value may be affected by a general decline in the U.S. market segments relating to their underlying indexes. Similarly, an imperfect match between an ETF’s holdings and those of its underlying index may cause its performance to not match the performance of its underlying index. Like other concentrated investments, an ETF with concentrated holdings may be more vulnerable to specific economic, political, or regulatory events than an ETF that mirrors the general U.S. market. Annuities An annuity is a tax-deferred investment structured to convert a sum of money into a series of payments over time. Annuity contracts have limitations and are not viewed as short-term liquid investments. An insurance company’s fulfillment of a commitment to pay a death or living benefit, a schedule of payments, a fixed investment amount guaranteed by the insurance company, or another form of guarantee depends on the claims-paying ability of the Methodology Updates Our CMA, asset allocation, and investment committees typically meet on a periodic basis. These committees have oversight for their respective areas of expertise. If any of these committees makes an adjustment, the changes are thoroughly reviewed and tested before being implemented. These changes are manifested in retirement investor portfolios through expected future returns, and asset allocations. CMAs are updated on an annual basis. We also update our methodologies with updated tax limits on an annual basis. Asset allocation and advice methodologies are updated only when there is a regulatory change that requires an update or when research we have completed warrants enhancing our asset allocation process or advice methodology. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 17 of 22 Item 9. Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would influence a potential client to engage us. We do not have any material legal or disciplinary events to disclose. by fellow portfolio managers, which mitigates the conflict of interest by providing checks and balances so that no employee can act unilaterally in making recommendation decisions. Methodology updates which impact investment recommendations or decisions for Morningstar Retirement’s services are peer reviewed by the Morningstar Retirement Investment Policy Committee. This serves to mitigate conflicts of interest by providing checks and balances so that no employee can act unilaterally in making recommendation decisions. Item 10. Other Financial Industry Activities and Affiliations Morningstar Investment Management is a wholly owned subsidiary of Morningstar. Our offerings center on advisory services in our core capabilities of asset allocation, investment selection, and portfolio construction that we offer to individual investors and institutions (including the services described in this brochure.) Morningstar Investment Management is registered as a Commodity Pool Operator with the Commodity Futures Trading Commission. Some of Morningstar Investment Management’s employees are registered with the National Futures Association as principals or associated persons. Our portfolio managers and their team members who are responsible for the day-to-day management of our portfolios are paid a base salary plus a discretionary bonus. The bonus is fully or partially determined by a combination of the employee’s business unit’s overall revenue and profitability, Morningstar’s overall annual revenue and profitability, and the individual’s contribution to the business unit. For most portfolio managers and their team members that work on Morningstar Wealth’s Portfolios, part of their bonus is also based on select portfolio investment performance and risk metrics versus both a corresponding benchmark over specified three-, five-, and/or seven-year periods and appropriate peer groups. Benchmarks are used as a measure of investment performance and are chosen by senior personnel and approved by the Regional Investment Committee, which is chaired by the regional Chief Investment Officer. To mitigate the conflict of interest that could arise from partially basing an employee’s bonus on performance of a select portfolio or portfolios, all investment decisions made within a portfolio by an individual portfolio manager must be peer reviewed by the broader regional team of portfolio managers. In addition, the Regional Investment Committee reviews strategy performance on a quarterly basis. Our investment professionals provide portfolio construction and ongoing monitoring and maintenance for the Morningstar Wealth portfolios within the Morningstar Wealth Platform offered by our subsidiary, Morningstar Investment Services and to third-party financial institutions on Morningstar Investment Services’ behalf. While the same or similar portfolios are offered by us to our Institutional Clients, we do not believe these responsibilities create any material conflicts of interest for our clients. In order to mitigate any perceived conflict of interest, when we offer discretionary services for Morningstar Wealth’s Portfolios, transactions for our clients are placed at the same time as transactions for Morningstar Investment Services’ discretionary clients as part of block trades. We have procedures in place to ensure that trades are allocated in such a manner as to not favor one client over another. When we offer Portfolios on a non-discretionary basis to third-party Institutional Clients, our Institutional Clients receive trade recommendations just after trades are placed for discretionary clients, due to our heightened fiduciary responsibilities to our discretionary clients. In addition, all non- discretionary clients are notified of transaction recommendations after the close of the trading day, so that no one such client has an advantage over another. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. Morningstar Investment Management will become the investment adviser to many of Morningstar Investment Services’ third-party financial institution clients. Trade recommendations will be communicated to non-discretionary clients after the close of the trading day and Morningstar- affiliated accounts in Morningstar Wealth portfolios will be traded the next day so that no one person has an advantage over another.) For many of our advisory services, the universe of investment options from which we make our investment selections is defined by our Institutional Client. In some cases, this universe of investment options includes proprietary investment options of the Institutional Client. To mitigate any actual or potential conflict of interests presented by this situation, we subject all investment options to the same quantitative and qualitative investment selection methodology, based on several factors, including performance, risk, and expense so that the proprietary nature of an investment option does not influence our selection. We invested in the Series D funding round of SMArtX Advisory Solutions, a managed account technology provider and architect of the SMArtX turnkey asset management platform. This investment will assist in the build out of SMArtX’s development capabilities, which could benefit us or our parent company. Daniel Needham, our co-president serves on the board of SMArtX. We may provide consulting or investment management services to Institutional Clients that offer registered or pooled investment products, such as mutual funds, variable annuities, collective investment trusts, or model portfolios. To mitigate the conflict of interest presented by our role in these investment products, we exclude such investment products from the universe of investment options from which we make our recommendations to other clients. When we, along with Morningstar and/or our other affiliates offer services to the same client, we have the option to enter into a bundled agreement with the client that encompasses all or part of those services. Additional fee(s) for such product(s) or service(s), if required, will be set forth in our agreement with the client. In these situations, clients pay a fee directly to us and each such affiliate for its products or services or as part of a joint fee schedule which encompasses all services. Affiliations – Registered Entities Morningstar has various subsidiaries across the globe that are each registered with the applicable regulatory body or bodies in that country to provide investment management or other advisory services. As described earlier in this brochure, we share resources with these various subsidiaries. We receive compensation for our research and analysis activities (e.g., research papers) from a variety of financial institutions including large banks, brokerage firms, insurance companies, and mutual fund companies. In order to mitigate any actual or potential conflicts of interest that may arise from this service, we ensure that our research and analytical activities are non- biased and objective given our business relationships. Employees who provide research and analysis for clients are separate from our sales and relationship manager staff in order to mitigate the conflict of interest that an employee may feel pressure to present results in such a way as to maintain existing or gain new business. In addition, as noted above, all investment decisions for Morningstar Wealth’s Portfolios service must be peer reviewed ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 18 of 22 its investment research reports and/or investment consulting services to clients, including us. Investment Services anticipates the cessation of One subsidiary, Morningstar Investment Services LLC, is our subsidiary and is also an investment adviser registered under the Advisers Act. Morningstar Investment Services is additionally registered with the Securities and Exchange Commissions as a broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA). Morningstar Investment Services offers model portfolios and separately managed accounts through its role as the sponsor of an investment advisory program known as the Wealth Platform and through third-party financial institutions, plan sponsor services, and retirement plan services for institutional and retail clients. (As noted above, Morningstar its discretionary advisory services by the end of the second quarter of 2025.) Morningstar Research Services provides information to the public about various securities, including managed investments like open-end mutual funds and ETFs, which include written analyses of these investment products in some instances. Although we use certain products, services, or databases that contain this information, we do not participate in or have any input in the written analyses that Morningstar Research Services produces. While we consider the analyses of Morningstar Research Services, our investment recommendations are based on our decisions in regard to the investment product. In some cases, our senior management members have management responsibilities to these other affiliated entities. We do not believe that these management responsibilities create any material conflicts of interests for our clients. Morningstar Research Services may issue investment research reports on securities we hold in our portfolios or recommend to our clients, but they do not share any yet-to-be published views and analysis and/or changes in estimates (i.e., their confidential information) with us on these securities. In making investment decisions or recommendations, we use Morningstar Research Services’ publicly available analysis as part of our review process and do not have access to their analysis prior to its public dissemination. We mitigate any actual or potential conflicts of interest that could arise from the access of their analysis prior to publication through measures such as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. Morningstar Research Services prepares qualitative analysis on separately managed accounts and model portfolios. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis on, nor recommend any Morningstar separately managed account or model portfolio we create and manage. Morningstar Wealth and Morningstar Retirement have set up service teams composed of employees of our affiliate and located at our affiliate’s office in Mumbai, India. In addition, Morningstar Retirement has a team composed of employees of our affiliate located at our affiliate’s office in Toronto, Canada. We compensate our affiliates for services rendered via intercompany charges. The services and compensation will be governed by intercompany agreements. This compensation will likely be lower than compensation negotiated with non-affiliated firms for the same or similar services. To mitigate any conflict of interest between us and our affiliates we have established dual reporting lines for employees on these teams so that such employees report up to employees of Morningstar Investment Management. We’ve also established information security boundaries and technology separation to protect our non-public information and Morningstar’s compliance department monitors the personal trading activity of these employees. Some of Morningstar Research Services’ clients are sponsors of funds or associated with other securities that we may recommend to our Institutional Clients. We mitigate any actual or potential conflicts of interests resulting from this fact through such measures as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar Research Services and their clients when analyzing investments or making recommendations. Morningstar Research Services LLC is also a wholly owned subsidiary of Morningstar and an investment adviser registered under the Advisers Act. Morningstar Research Services’ offerings center around the production of investment research reports and investment consulting services to financial institutions/institutional investors who themselves are registered with and governed by a regulatory body. Conflicts of interests between us and Morningstar Research Services are mitigated by such things as the maintenance of separate legal entities and dual reporting/organization lines, and the utilization of physical (i.e., separate office “neighborhoods”) and technological separation. Morningstar Research Services also maintains a committee structure so as to limit any unilateral decisions. Morningstar’s compliance department monitors the personal trading activities of Morningstar Research Services’ employees. Morningstar Investment Management serves as an investment adviser to investment companies registered under the Investment Company Act of 1940, as amended, and to other pooled investment products. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis on nor recommend as part of their investment consulting services any investment company we are an investment adviser or sub- adviser to. investors Affiliations – Morningstar, Inc. Our parent company, Morningstar, Inc., is publicly traded (Ticker Symbol: MORN). We may recommend an investment product that holds a position in publicly traded shares of Morningstar’s stock. Such an investment in Morningstar’s stock is solely the decision of the investment product’s portfolio manager. We have no input into a portfolio manager’s investment decision nor do we require that the investment products we recommend own shares of Morningstar. An investment product’s position in Morningstar has no direct bearing on our investment selection process. We mitigate any actual or potential conflicts of interest by not factoring Morningstar’s publicly traded stock into our qualitative or quantitative analysis nor in our recommendations. In some situations, we engage Morningstar Research Services to perform investment manager due diligence and/or selection services on our behalf as a sub-adviser or consultant. The notification to and authorization by the Institutional Client to our engaging Morningstar Research Services as a sub- adviser is addressed in our agreement with the Institutional Client. On such occasions, we compensate Morningstar Research Services for services rendered via an intercompany charge. The services and compensation will be governed by an intercompany agreement. This compensation will likely be lower financial than compensation negotiated with non-affiliated for the same or similar services. institutions/institutional Morningstar Research Services’ employees who are engaged to provide manager due diligence and/or selection services are prohibited from using non-public/confidential information obtained because of their engagement in ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 19 of 22 Morningstar offers various products and services to the public. Some of Morningstar’s clients are service providers (e.g., portfolio managers, advisers, or distributors) affiliated with a mutual fund or other investment option. We may have a contractual relationship to provide consulting or advisory services to these same service providers or we may recommend the products of these service providers to our advisory clients. To mitigate any actual or potential conflicts of interest, we do not consider the relationship between Morningstar and these service providers when making recommendations. We are not paid to recommend one investment option over another, including products of service providers with which Morningstar has a relationship. strategies are deployed using equity securities. As we have discretion over these accounts, Morningstar’s accounts are traded at the same time as our and Morningstar Investment Services’ other discretionary client accounts in order to ensure that Morningstar’s accounts are not treated more favorably than our client accounts. Some of Morningstar’s accounts are used as the subject of newsletters offered by Morningstar. In order to ensure that Morningstar’s newsletter subscribers are not treated more favorably than our clients, which would result in a breach of our fiduciary duty, we do not report trades in Morningstar’s accounts invested in our strategies to newsletter subscribers until after our client accounts have been traded or our non- discretionary clients have been notified. Morningstar provides information to the public about various investment products, including managed investments like open-end mutual funds and ETFs. In some cases, this information includes written analyses of these investment products. Although we use certain products, services, or databases of Morningstar, we do not have any decision-making input in the written analyses that Morningstar provides its licensees. While we consider the analyses of Morningstar, our investment recommendations are oriented to the mandates of the investment products in question. licenses under Morningstar Investment Services’ As a wholly owned subsidiary, we use the resources, infrastructure, and employees of Morningstar and its affiliates to provide certain support services in such areas as technology, procurement, human resources, accounting, legal, compliance, information security, and marketing. We do not believe this arrangement presents a conflict of interests to us in terms of our advisory services. Employees of Morningstar that provide support services to us have the option to maintain their Financial Industry Regulatory Authority (“FINRA”) limited security broker/dealer registration, if appropriate for their current job responsibilities. We believe no conflict of interest exists due to the maintenance of these security licenses. Morningstar hosts educational events and conferences and, in some instances, provides us with the opportunity to suggest invitees or offer (proactively or upon request) discounted or waived registration fees. We mitigate any actual or potential conflicts of interest this introduces by using pre-defined criteria to select Institutional Clients for these opportunities. We have the option to make our clients aware of various products and services offered by Morningstar or its affiliates. We do not receive compensation for that introduction. Morningstar and its affiliates also have the option to make their clients aware of various products and services offered by us. Morningstar and its affiliates do not receive any compensation from us for that introduction, unless it falls under a solicitation arrangement, as described in Item 14 below. Morningstar Wealth, through Morningstar and its subsidiaries, make available products such as: (i) the Morningstar Wealth Platform; (ii) Morningstar Funds Trust, (iii) Morningstar Office, Morningstar’s RIA portfolio software service; (iv) Morningstar ByAllAccounts, Morningstar’s investment data aggregation service; and (v) Morningstar.com, Morningstar’s individual investor site offering. Daniel Needham, our co-president, has management responsibilities for Morningstar Wealth. We do not believe that these management responsibilities create any material conflicts of interests for our clients, but we mitigate any actual or potential conflicts of interests resulting from that by imposing informational barriers where appropriate and undertaking compliance monitoring. Morningstar offers various products and services to retail and institutional investors. In certain situations, we recommend an investment product that tracks an index created and maintained by Morningstar. In such cases, the investment product sponsor has entered into a licensing agreement with Morningstar to use such index. To mitigate any conflicts of interest arising from our selection of such investment products, we use solely quantitative criteria established by our advisory client to make such selection, or, in the alternative, Morningstar’s compensation from the investment product sponsor will not be based on nor will it include assets that are a result of our recommendation to our advisory client to invest in those investment products. In other cases, some of Morningstar’s clients are sponsors of funds that we recommend to our clients. Morningstar does not and will not have any input into our investment decisions, including what investment products will be recommended for our recommended portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar when analyzing investments or making recommendations. We mitigate any actual or potential conflicts of interests resulting from that by not producing qualitative analysis on any such exchange-traded fund as well as imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines between, and monitoring by the compliance department. Affiliations – Morningstar, Inc. Subsidiaries Equity and manager research analysts based outside the United States are employed by various wholly owned subsidiaries of Morningstar. These analysts follow the same investment methodologies and process as Morningstar Research Services, as well as being held to the same conduct standards. As a result, we do not believe this structure causes actual or a potential for a conflict of interest. In some instances, we create portfolios that track an index created and maintained by Morningstar. Morningstar does not and will not have any input into our investment decisions, including what investment products will be included in our portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. Affiliations – Credit Rating Agency We are affiliated with the Morningstar DBRS group of companies, which include DBRS, Inc., DBRS Limited, DBRS Ratings GmbH, and DBRS Ratings Limited. DBRS, Inc. is registered with the Securities and Exchange Commission as a Nationally Recognized Statistical Rating Organization (NRSRO). Morningstar DBRS’ companies are also registered with and governed by applicable regulatory body or bodies in other countries around the globe. In our analysis of certain securities, we use the publicly available Morningstar has and maintains accounts which they invest in accordance with investment strategies created and maintained by us. Those investment ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 20 of 22 Strategies will be traded the next day so that no one person has an advantage over another.) credit rating and analysis issued by Morningstar DBRS. Because of our use of Morningstar DBRS’ ratings and analysis is limited to that which is publicly available, we do not believe there is an actual or potential conflict of interest that arises from such use. Personal Trading By Access Persons Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities does not interfere with our clients’ interests. While our Access Persons have the option to maintain personal investment accounts, they are subject to certain restrictions. Our Code of Ethics includes policies designed to prevent Access Persons from trading based on material non- public information. Access Persons in possession of material non-public information are prohibited from trading in securities which are the subject of such information and tipping such information to others. In certain instances, we employ information blocking devices such as restricted lists to prevent illegal insider trading. Morningstar’s compliance department monitors the activities in the personal accounts of our Access Persons (and any accounts in which they have beneficial ownership) upon hire and thereafter. Access Persons are required to pre-clear IPO, initial digital coin offerings, and private placement transactions with Morningstar’s compliance department. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code Of Ethics We have in place a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act (“Code of Ethics”). Our Code of Ethics strives to uphold the highest standards of moral and ethical conduct, including placing our clients’ interest ahead of our own. Our Code of Ethics covers all our officers and employees as well as other persons who have access to our non-public information (collectively “Access Persons”). Our Code of Ethics addresses such topics as professional and ethical responsibilities, compliance with securities laws, our fiduciary duty, and personal trading practices. Our Code of Ethics also addresses receipt and/or permissible use of material non-public information and other confidential information our Access Persons may be exposed and/or have access to given their position. The Code of Ethics is provided upon hire and at least annually thereafter and at each time, the Access Person must certify in writing that she or he has received, read, and understands the Code of Ethics and that they agree to or have complied with its contents. A copy of our Code of Ethics is available to existing and prospective clients by sending written request to compliancemail@morningstar.com. Item 12. Brokerage Practices Where we exercise investment discretion, we will generate trade instructions for each portfolio that requires investment, reallocation or rebalancing and forward those instructions to the appropriate institution as designated by the client. As a result, we do not have the ability to make decisions regarding which broker is used to execute the transactions nor the timing of when the trade is executed. This could result in different pricing of client trades. We do not participate in any soft dollar practices. Interest In Client Transactions Our Access Persons have the option to maintain personal investment accounts and purchase or sell investments in those accounts that are the same as or different from the investments we recommend to clients. Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities should not conflict with our advisory activities or the timing of our recommendations and will not interfere with our clients’ interests, while allowing our Access Persons to invest in their own accounts. We do not engage in principal transactions (transactions where we, acting in our own account or in an affiliated account, buy a security from or sell a security to a client’s account) nor do we engage in agency cross transactions (transactions where we or our affiliate executes a transaction while acting as a broker for both our client and the other party in the transaction). To generate additional income or to earn credits that offset expenses, the Morningstar Funds reserves the right to lend its portfolio securities to unaffiliated broker/dealers, financial institutions or other institutional investors pursuant to agreements requiring that the loans be secured continuously by collateral, marked-to-market daily and maintained in an amount at least equal in value to the current market value of the securities loaned. The aggregate market value of securities lent by a Morningstar Fund will not at any time exceed 33 1/3% of the total assets of the Morningstar Fund. All relevant facts and circumstances, including the creditworthiness of the broker-dealer or institution, will be considered in making decisions with respect to the lending of securities subject to review by the Morningstar Funds Trust’s Board of Trustees. Currently, six of the nine Morningstar Funds participate in a securities lending program. The cash collateral received from a borrower as a result of a Morningstar Fund’s securities lending activities will be invested in cash or high quality, short-term debt obligations, such as securities of the U.S. government, its agencies or instrumentalities, irrevocable letters of credit issued by a bank that meets the Morningstar Fund’s investment standards, bank guarantees or money market mutual funds or any combination thereof. receive Securities lending involves two primary risks: “investment risk” and “borrower default risk.” Investment risk is the risk that a fund will lose money from the investment of the cash collateral received from the borrower. Borrower default risk is the risk that a fund will lose money due to the failure of a borrower to return a borrowed security in a timely manner. There also may be risks of delay in receiving additional collateral, in recovering the securities loaned, or a loss of rights in the collateral should the borrower of the securities fail financially. In the event a Morningstar Fund is unsuccessful in seeking to enforce the contractual obligation to deliver additional collateral, then the Morningstar Fund could suffer a loss. Interest In Securities That We May Recommend Morningstar Investment Management has and maintains a number of seed accounts (accounts used to establish a strategy we offer or track), many of which follow strategies we offer to clients. We place block trades for our accounts, therefore trade requests for our seed accounts are placed at the same time as trades are placed for those client accounts invested in the same strategy and for which we have discretion. Block trades are allocated in such a manner as to ensure that our seed accounts do not receive more favorable trades than our clients’ accounts. Client accounts that we manage on a discretionary basis and thus, our seed accounts, are traded before we provide model portfolio trade recommendations to other clients using our model portfolios. However, our model portfolio clients trade recommendation after the close of the trading day, so that no one model portfolio client is favored over another. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. When this occurs, trade recommendations will be communicated to non-discretionary clients after the close of the trading day and seed and Morningstar-affiliated accounts in the ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 21 of 22 Item 13. Review of Accounts If included in our contract with the Institutional Client, we will provide ongoing monitoring of the underlying holdings in investment portfolios and reallocation or rebalancing of investment portfolios. The frequency and nature of our reviews and rebalancing is governed by our contract with each Institutional Client. We enter into agreements with certain Institutional Clients whereby we provide compensation to Institutional Clients in exchange for access to their financial professionals to educate them about our advisory products and services, having our name, products, or services listed or highlighted in Institutional Client materials, attendance or booth space at Institutional Client conferences, and/or similar marketing, distribution, and educational activities. We also provide compensation to Institutional Clients to sponsor meetings and events for their financial professionals and/or clients. In instances where we act as a discretionary investment manager for Morningstar Wealth Portfolios, financial advisors of the Institutional Client or financial advisors using the Institutional Client’s platform are typically responsible for periodically reviewing client accounts. Item 15. Custody We do not serve as a custodian of client assets. However, in cases where we have the ability to debit fees directly from client accounts, we are deemed to have custody of client assets under Rule 206(4)-2 of the Advisers Act, even if we do not act as a custodian. The Institutional Client is responsible for selecting the custodian for assets. We do not provide periodic reviews or ongoing monitoring of retirement accounts where we solely provide our Guidance or Advice services. We recommend such retirement investors return to our site every six months to receive an updated strategy, or sooner if they have had any significant changes in their personal or financial situation. We also recommend they return to our site whenever there has been a chance in the available investment options in their plan lineup. Item 16. Investment Discretion In some cases, we have complete investment discretion in managing investment portfolios, retirement plans, or registered funds for our Institutional Clients and Morningstar Funds Trust. In other cases, we provide information or make investment recommendations to an investment committee, board, plan sponsor, or other person(s) within an institution designed to help them make investment choices, but the institution has the discretion to accept, reject, or modify our recommendations. Retirement accounts enrolled in our Managed Accounts service are typically rebalanced to the asset allocation target or reallocated on a quarterly basis as necessary, and portfolio allocations will be adjusted on an annual or as- needed basis to account for changes in age and any other significant personal or financial changes that we have been informed about. Our methodology has a built-in mechanism to help prevent unnecessary trading and therefore will not propose any changes to investment strategies if the adjustments are relatively small. Retirement investors are responsible for notifying us of changes in their personal and financial information, investment objectives, and investment restrictions so that we can make the necessary adjustments to their investment strategy. As described in our Morningstar Retirement Advisory Services for Individuals firm brochure, we typically have investment discretion in managing retirement accounts through Morningstar Retirement’s Managed Accounts and the Personal Target-Date Fund Service. In other cases, we make investment recommendations to retirement investors through our Advice or Guidance programs, but the retirement investor has the discretion to accept, reject, or modify our recommendations. We may provide periodic reports to our Institutional Clients on the investment portfolios and the underlying holdings or retirement plan or product lineup if included in our contract with the Institutional Client. We do not prepare periodic reports as part of Advice or Guidance. The extent of our investment discretion is set forth in our contract with the Institutional Client or retirement investors using our Managed Account, Advice, or Guidance services. Our model portfolios and valuation models are reviewed on at least an annual basis. Investment-specific model portfolios for a retirement plan or product are reviewed on at least an annual basis. Item 17. Voting Client Securities For the majority of our institutional advisory service arrangements, we do not have the authority to and will not vote proxies. In such situations, proxies or other solicitations will be sent directly to the Institutional Client and we will not provide information or advice in regard to questions an Institutional Client has about a particular solicitation. We do not advise or act for Institutional Clients in legal proceedings, including class actions or bankruptcies, involving recommended securities. The Morningstar Funds have authorized us to vote proxies on their behalf. In turn, in accordance with the sub-advisory agreement entered into between us and each sub-adviser, we have delegated proxy voting authority to the sub-adviser. We have implemented policies and procedures with respect to the portion of the Morningstar Funds that are not managed by a sub-adviser. Item 14. Client Referrals and Other Compensation We may make direct or indirect cash or non-cash payments to our affiliates or to unaffiliated third parties for recommending our services. If such payments occur, they will be done pursuant to Rule 206(4)-1 of the Advisers Act. Clients referred by third party solicitors may in some cases pay a higher fee than clients who contract with us directly. Through disclosures, which are spoken or given in writing to Clients at the time of the solicitation, Clients solicited by an unaffiliated person are made aware of the arrangement between the solicitor and us (and therefore that the solicitor has a financial interest in recommending us to Client), any other material conflicts of interest, and the terms of any compensation paid directly or indirectly to the solicitor as a result of their referral. Proxy Voting Policy and Procedures Rule 206(4)-6 of the Investment Advisers Act of 1940, as amended, places a number of requirements on investment advisers with proxy voting authority. These requirements are: We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. • Adopt and implement written policies and procedures that are reasonably designed to ensure that proxies are voted in the best interest of clients. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 22 of 22 Such procedures must include how to address material conflicts that may arise between our interests and those of our clients; Management LLC at 22 West Washington Street, Chicago, IL 60602 ATTN: Compliance. • Disclose how clients may obtain information about how proxies were voted with respect to their securities; and • Describe to clients our proxy voting policies and procedures and, upon request, furnish a copy of the policies and procedures. Item 18. Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We do not have any financial commitment that impairs our ability to meet our contractual and fiduciary commitments to clients, have we been the subject of any bankruptcy proceeding. Proxy Voting Committee In efforts to mitigate conflicts of interest, we have in place a Proxy Voting Committee (“Committee”). This Committee consists of both non-voting and voting members (collectively, “Committee Members”). Committee Members include members of the investment team serving in a voting role and member(s) of compliance and operations team serving in non-voting roles. The Committee is responsible for tasks such as: • Developing, implementing and updating policy and procedures intended to ensure voting of proxies is conducted in a manner that is in the best interests of Morningstar Funds investors; • Assessing whether proxy voting should be done internally, externally by a third-party vendor, or a combination of the two; • Oversight of a third-party vendor, when applicable; • Making voting decisions (including whether or not to abstain from voting) and ensuring votes are cast on time; • Maintaining documents material to the voting decision; and • Implementing appropriate proxy voting disclosures and maintaining records of communications received from Morningstar Funds investors requesting information on how proxies were voted and our responses. Proxy Voting Process Proxy statement notifications are received by an independent third-party vendor when a proxy statement has been issued on a security that currently underlies a portion of a Morningstar Fund managed by us. This third-party vendor provides additional services such as facilitating vote submissions on our behalf and provides access to e-ballot and meeting information. We identify, on an annual basis, certain categories of proxy votes to be reviewed by our proxy committee. In these instances, the vote will be determined on a case-by-case basis based on the Investment Management group’s global proxy voting principles. Upon receipt of a proxy statement, the investment team member with the primary oversight responsibility for the security will review the proxy statement and any additional soliciting materials it is aware of that the issuer has filed and will communicate their recommendation, support for the recommendation, and other pertinent information to the Committee. The voting Committee Members will review the proxy issue and the recommendation and will cast their vote as to whether they agree or disagree with the recommendation. If the other voting Committee Members agree with the recommendation, the proxy will be voted in that manner. If there is not a super-majority, the Committee will hold a meeting to discuss the proxy and reach a resolution. There may be instances where we will refrain from voting a specific proxy when we believe it is in the best interests of our Morningstar Fund investors. by calling 877-626-3227, sending an e-mail How you can Obtain Proxy Voting Information At any time, you may request information on how we voted proxies and/or request a copy of our proxy voting policies and procedures. Requests can be submitted to compliancemail@morningstar.com, or writing to Morningstar Investment ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc. 

Form ADV Part 2A: Firm Brochure Advisory Services to MetLife ExpertSelect Program Morningstar Investment Management LLC 22 West Washington Street, Chicago, IL 60602 Phone: 312.696.6000 www.corporate.morningstar.com March 27, 2025 This brochure provides information about the qualifications and business practices of Morningstar Investment Management LLC. If you have any questions about the contents of this brochure, please contact us at 312.696.6000 or send an email to compliancemail@morningstar.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Morningstar Investment Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Morningstar Investment Management LLC is registered with the SEC as a registered investment adviser. Registration with the SEC does not imply a certain level of skill or training. All current versions of our firm brochures are available in the Part 2 Brochures section of this record on the SEC’s website. You can request a copy of our current brochure free of charge by contacting our Compliance Department at 312.696.6000, or by email to compliancemail@morningstar.com. In your request, please indicate the name of the company (Morningstar Investment Management) and the service brochure (MetLife Expert Select Program) you are requesting. Item 2. Material Changes The Advisory Services to MetLife ExpertSelect Program Firm Brochure dated March 2025 contains no material changes since our last annual update dated March 25, 2024. Non-material changes since our last annual update include: As applicable throughout the Firm Brochure, we noted that our subsidiary, Morningstar Investment Services, anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. Morningstar Investment Management will become the investment adviser to many of Morningstar Investment Services’ third- party financial institution clients. At the time of this change, trade recommendations for Morningstar Wealth portfolios will be communicated to non-discretionary clients after the close of the trading day and Morningstar- affiliated accounts in Morningstar Wealth strategies will be traded the next day so that no one person has an advantage over another. Item 4. Advisory Business was updated to reflect our assets under management and advisement as of December 31, 2024. Item 5. Fees and Compensation was updated to disclose that we receive compensation from unaffiliated third parties for referring their services to other advisory firms or investors. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss was updated to reflect the current makeup of the Morningstar Retirement Investment Policy Committee. Item 10. Other Financial Activities and Affiliations was updated to disclose an investment in SMArtX. Item 14. Client Referrals and Other Compensation was updated to disclose that we receive compensation from unaffiliated third parties for referring their services to other advisory firms or investors and to note we provide compensation to Institutional Clients to provide marketing or educational support to their financial professionals and to sponsor meetings and events for their clients. 1  We made other edits where necessary to correct grammar or punctuation, to provide clarification or further information, for consistency in terminology or content, or to improve the readability of the brochure. Item 3. Table of Contents 1. Item 2. Material Changes ........................................................................................................... 1 2. Item 3. Table of Contents .......................................................................................................... 2 3. Item 4. Advisory Business ......................................................................................................... 2 4. Investment Management Services to Institutional Clients: $24,038,500,000 ........................................ 4 5. Item 5. Fees and Compensation .................................................................................................. 4 6. Item 6. Performance-Based Fees and Side-by-Side Management ....................................................... 5 7. Item 7. Types of Clients ............................................................................................................ 5 8. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 5 9. Item 9. Disciplinary Information ................................................................................................. 8 10. Item 10. Other Financial Industry Activities and Affiliations ............................................................ 8 11. Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ............. 13 12. Item 12. Brokerage Practices .................................................................................................... 14 13. Item 13. Review of Accounts ................................................................................................... 14 14. Item 14. Client Referrals and Other Compensation ....................................................................... 14 15. Item 15. Custody ................................................................................................................... 14 16. Item 16. Investment Discretion ................................................................................................. 14 17. Item 17. Voting Client Securities .............................................................................................. 15 18. Item 18. Financial Information ................................................................................................. 15 Item 4. Advisory Business Morningstar Investment Management LLC (“Morningstar Investment Management”, “we”, “us” or “our”) is a Delaware limited liability company that was incorporated in 1999. Morningstar Investment Management is a wholly owned subsidiary of Morningstar, Inc. (“Morningstar”). Morningstar is a publicly traded company (Nasdaq Ticker: MORN) with Mr. Joseph Mansueto, Executive Chairman of Morningstar, holding more than 35% of Morningstar’s outstanding shares. Because of that ownership, Mr. Mansueto is an indirect owner of Morningstar Investment Management. Morningstar Investment Management is registered with the SEC under Section 203(c) of the Investment Advisers Act of 1940, as amended (“Advisers Act”). Morningstar Investment Management has filed the appropriate notices to conduct business in all 50 states, the District of Columbia, Guam, the Virgin Islands, and the Commonwealth of Puerto Rico. Morningstar Investment Management is registered with the U.S. Commodity Futures Trading Commission as a Commodity Pool Operator (“CPO”) and is a member of the U.S. National Futures Association. Morningstar Investment Management, along with other Morningstar subsidiaries authorized in appropriate jurisdictions to provide investment management and advisory services, is part of a global investment team composed of investment analysts, portfolio managers, and other professionals. These investment and operations teams span the globe, with primary offices in Chicago, London, and Sydney. We offer a suite of investment advisory services to individuals, plan sponsors, and other institutional clients. This brochure focuses on the products and services we provide to individuals through the MetLife ExpertSelect Program for their retirement plans or retirement accounts. You can obtain a copy of our brochure describing our products and services in our core capabilities of asset allocation, investment selection, and portfolio construction that we offer to individuals and institutions such as asset management firms, insurance companies, investment companies, investment fiduciaries, plan sponsors of retirement plans, plan providers of retirement plan services, and other business entities by following the instructions above. This service is provided by a sub-adviser, Morningstar Research Services LLC, who is affiliated with Morningstar Investment Management. 2  Advisory Services We Offer – MetLife ExpertSelect Program Program Services We selected the menu of investment options available in the MetLife ExpertSelect Program (“Program”) from the universe of investments that MetLife is authorized to offer. We review the universe of investment options using our standard proprietary screening review. The investment options selected for the Program are those that have met our criteria. We do not review the annuity products in connection with the Program or your retirement plan (“Plan.”) On an ongoing basis, we monitor the investment options in the Program lineup using the same process used in the initial selection of the investment options. This monitoring can result in changes to the Program menu due to, for example, one or more investment options no longer meeting our criteria. If we determine that an investment option should be removed from the Program menu, we will identify a replacement from those investment options that MetLife may offer that has similar characteristics (e.g., asset class, risk/return) as the investment option being replaced and that meets our selection criteria. In performing this service, we are acting in an advisory capacity to the Program and we are not acting in an advisory capacity to you with respect to the selection and ongoing monitoring of the investment options within the Program. We only provide advisory services to you on a limited basis as described under Participant Services below. Participant Services The investment options in the Program menu include a broad range of investment options that are diverse and have different risk and return characteristics. The goal of the Program investment option menu is to give you the ability to build a diversified portfolio of investments with risk and return characteristics that you feel are most appropriate for your situation. You are solely responsible for deciding how to allocate your Plan account among available investment options in the Plan and your Program account among the investment options available in the Program lineup. We do not offer any advice or recommendation with respect to the purchase or sale of a particular investment option in your Plan or the investment options in your Program lineup, or with respect to the purchase or sale of annuity products. When a change in the Program menu occurs, we provide MetLife with a written communication to be distributed to you in advance of the change (“Notification”). For purpose of delivering the Notification, MetLife will use your personal mailing information that you have made available to MetLife through the Plan enrollment process or subsequent notification. If your Program account has a balance in the investment option that is intended to be removed from the Program menu, you are to contact MetLife to instruct them as to which remaining investment option or investment options you would like that balance to be reallocated and how you would like future contributions to be allocated. If you do not provide such instructions to MetLife on a timely basis prior to the change, we will provide you with certain limited discretionary advisory services, which only include: • • the reallocation of your entire existing account balance in the investment option that is being removed from the Program lineup to the investment option that has been added to the Program lineup in its place; and the direction of future contributions to the investment option that has been substituted in the Program lineup. You can contact MetLife by calling 1-800-543-2520 or by going to www.mlr.metlife.com for answers to questions about the implementation of an investment option substitution or the Program in general. You are solely responsible for the monitoring of your Program account. You can contact MetLife at any time to change your investment option allocations and/or instructions on how to allocate your future contributions. The Program and Participant Services to you will terminate: • • • if your participation in the Program is terminated, if we cease to provide services in connection with the Program, or if you elect to invest your Plan account assets in a Plan investment option other than the Program menu. Customized Services We provide advice based on the universe of investment options available to your Plan through the Program. These investment options include open-end mutual funds, collective investment trusts (CITs), guaranteed retirement income products like annuities, and other products. The universe of investment options defined by your plan provider or plan 3  sponsor is subject to change without notice. Particular investment options in this universe may not be appropriate for all investors, and there may be other investment options that are more suitable. We may have more favorable opinions of certain investment options which are not included in the universe of investment options made available through your plan provider or plan sponsor. Our selections are based on qualitative factors and quantitative analysis in addition to the judgment of our analysts. Wrap Fee Programs We do not sponsor a wrap fee program, but we do provide portfolio management services to a wrap fee program offered by our subsidiary, Morningstar Investment Services LLC. This wrap fee program is scheduled to be closed around the end of the second quarter of 2025. Assets Under Management As of December 31, 2024, the discretionary regulatory assets under management for Morningstar Investment Management (rounded to the nearest $100,000) were: Retirement Services to Individuals: $29,068,100,000 Investment Management Services to Institutional Clients: $36,267,000,000 Total Regulatory Asset Under Management: $65,335,000,000 The non-discretionary assets under advisement for Morningstar Investment Management (rounded to the nearest $100,000) were $235,870,200,000. Item 5. Fees and Compensation For the above services, only your Program account (and not any other part of your Plan account, including assets in a Fixed Annuity Account) will be charged an annual asset-based fee of 0.05% in payment for the Program and Participant Services (the “Program Service Fee”). The Program Service Fee is included in the fee for the Program. MetLife, acting as a conduit, will remit the Program Service Fee to us. MetLife does not retain any portion of the Program Service Fee and we do not pay MetLife in connection with the Program. We receive a minimum annual fee for our services. If the aggregate amount of annual Program Service Fees does not reach the annual minimum fee owed to us, MetLife has agreed to pay the difference. The amount of compensation we receive does not change based upon any particular investment option in the Program lineup. Payment MetLife will debit the Program Service Fee from your plan account and remit that fee to us. Other Costs in Connection with Our Advisory Services All fees paid by you for the Program and the Participant Services are separate from fees and expenses charged by the investment options or fees that may be charged by a third party, such as your plan provider. The investment options' fees and expenses are described in a prospectus or its equivalent. These fees will generally include a management fee, other investment expenses, and possibly a distribution fee (e.g., 12b-1). In some cases, an investment option will also charge an initial or deferred sales charge. In addition, investment option transactions within your Program account can result in a redemption fee being charged to your Program account by the underlying investment option or investment options. Such redemption fees are separate and distinct and are in addition to the above-mentioned fees paid for the Program and Participant Services. Neither Morningstar Investment Management nor any of our affiliates or employees receive transaction-based compensation for the investment recommendations we make. You may have the option to purchase investment products we recommend or similar services through other investment advisers or financial professionals not affiliated with us. Compensation from Sales of Securities We do not expect, accept or receive compensation for the sales of securities, including asset-based sales charges or service fees from the sale of open-end mutual funds. Revenue Sharing Arrangements We do not have any revenue sharing arrangements with any mutual funds. 4  Third Party Compensation We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. Item 6. Performance-Based Fees and Side-by-Side Management We do not charge any performance-based fees (fees based on a share of capital gains or on capital appreciation of assets in your account). Therefore, we do not manage any performance-based fee accounts side-by-side with non- performance-based fee accounts. Item 7. Types of Clients In addition to the services described in this brochure, we also provide managed accounts and advice services to retirement investors and to individuals who are in retirement and investment advisory services to institutional clients such as asset management firms, banking institutions, consultants, endowments, financial institutions, foundations, insurance companies, investment companies, investment fiduciaries, pension or profit sharing plans, third-party advisory programs, trusts, or other business entities. If you would like a copy of our brochures describing these services, please follow the instructions on Page 1 to access the SEC website or contact us at compliancemail@ morningstar.com. The services described in this brochure are only available to participants of 403(b) plans that enroll in the Program. We do not require a minimum account balance to use our services, and we generally do not impose any other conditions on your use of our services. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Investment Philosophy Our investment philosophy is driven by the investment principles that are promoted throughout our organization. The principles are intended to guide our thinking, behavior and decision making. These principles have been inspired by a number of the most experienced and successful investors in the last century. These principles also reflect and align with the history and foundation of Morningstar. The investment principles are: - We put investors first - We’re independent-minded - We invest for the long term - We’re valuation-driven investors - We take a fundamental approach - We strive to minimize costs - We build portfolios holistically Morningstar Retirement Investment Policy Committee The Morningstar Retirement Investment Policy Committee is responsible for oversight of the investment methodologies across all Morningstar Retirement’s products and services, including those described in this brochure. Members of the Morningstar Retirement Investment Policy Committee includes Morningstar Retirement’s chief investment officer, head of advice and financial planning, head of business development and client success, head of channel strategy, head of research, director of retirement research, director of product management, head of investments for institutional and retirement solutions, and the senior director of portfolio management. An investment team provides the investment advice used in the products and services referenced in this brochure. Investment Selection for Investment Lineups The lineups we build are limited to a universe of mutual funds and other investment vehicles, such as CITs and guaranteed retirement income products such as annuities. This universe is a subset of the entire universe of mutual funds and other products publicly available for purchase by investors available in the Program. We have no ability to choose the mutual funds or other products that are made available under the Program and may have more favorable options of investment options not included. Our analysis includes quantitative analytics and fundamental research on the investment options available, and holdings-based style analysis to determine an investment’s style over time. We draw on Morningstar’s comprehensive database of fund and security analytics. When analyzing investment options or managers for use in a lineup, our goal is to determine their true investment style, identify what we believe to be best-in-class managers, and identify the factors contributing to their 5  performance and risk characteristics with the aim of assessing whether their performance appears to be sustainable over time. We start with a proprietary peer grouping analysis using the available investment options. Once investment options have been placed into their appropriate peer groups, our methodology begins with a quantitative review process. First, we apply a series of screens designed to flag investment options that exhibit characteristics that are apt to hinder long-term performance in order to efficiently filter a large universe of investment options and focus our efforts on a more manageable opportunity set. Second, we use a multitude of statistics to begin to assess the overall quality of an investment option. We gather current and historical data points to evaluate investment style, structure, and performance and consider key factors that include fees, management tenure, style consistency, alpha, volatility, fund size, asset class exposure, and holdings concentration. We conduct further style analyses on managers that pass our initial screens to identify nuances of their strategies. Just as important as selecting qualified managers is determining how well an investment option will fit with other investments in the lineup. We want each investment to fill a distinct stylistic role within a plan lineup, so we carefully assess how it can be expected to complement other options we are recommending in adjacent styles. In general, we want to have a number of strategies investing in a specific space while employing different investment approaches. To accomplish this, we rely largely on a holdings-based style analysis to build a picture of an investment option’s style positioning based on its underlying holdings. This means drilling down to examine the asset class exposure within the investment option. We evaluate overall diversification to ensure that the investment option is not exposed to undue security or sector specific risk. The goal is to provide a selection of investments that are likely to meet their investment mandate, but also to provide options that differ in their pursuit of that objective. After an extensive quantitative review, we review an investment from a qualitative perspective. The purpose here is to allow our investment professionals to gain conviction in their investment thesis by developing a firm fundamental understanding of the strategy. Our professionals draw from their extensive experience in evaluating investment managers to analyze the people and process behind the investment. In doing so, our goal is to anticipate how an investment option is likely to be positioned in the future, which helps us build expectations of performance and capability of consistently playing a specific portfolio role. In our fundamental assessment, we review a number of characteristics of the investment option and its manager that could be relevant to how well it can fill the role for which it is being considered. Those include reviewing the manager’s performance and risk record against his or her peers in the same style—not just at the manager’s current investment option but also any other investment vehicles they’ve managed in the past. We analyze the subtleties of the manager’s investment process to understand what drives performance. We observe in which types of markets the investment option fares best and which types are trouble for its style. We also determine what it is about their style that explains the performance pattern. We assess whether a manager’s investment process leads to a more aggressive or more conservative performance profile relative to its style peers, and how a manager’s process might lead to persistent over- or under-weights in certain sectors. We also assess how performance, both absolute and relative to a peer group, has changed as a manager’s assets have grown. We use many factors to evaluate investment options depending on the specific situation and the questions we are trying to answer, including investment sub-style, manager skill, impact of asset growth on performance, sources of investment ideas, investment decision-making process, actions in previous market environments, manager ownership, process repeatability, and performance attribution. Lineup Design and Construction When constructing a lineup, we consider issues around choice overload, naïve allocations, and loss aversion. We strive to select investments to fill a distinct stylistic role within a lineup and carefully assesses how each investment can be expected to fit with other investments. We strive to choose investment options that are clearly different from one another, rather than similar or redundant. The goal is to establish a specific role for each investment option in the lineup that minimizes holdings overlap and maximizes diversification. 6  Managing Lineups We formally review investment options in our investment lineups quarterly. However, we are always monitoring our approved investment options and if something occurs intra-quarter that we believe merits immediate action, we will take action outside of the normal review schedule. Risk of Loss and Strategy Risk You should remember that all investments involve risk and will not always be profitable. We do not make any guarantee about the future performance or profitability of your Plan account and its underlying investments, nor do we promise that investments in the investment options in the Program lineup will be profitable. The investment options in the Program lineup are subject to a variety of risks, which could include market, currency, and political risks. We cannot guarantee that negative returns can or will be avoided in any of our recommendations. An investment’s future performance can differ substantially from its historical performance and as a result, could incur a loss. Past performance is no guarantee of future results. Asset allocation and diversification are investment strategies which spread assets across various investment types for long-term investing. However, as with all investment strategies, these strategies do not ensure a profit and do not guarantee against losses. You should consider the impact, if any, that an investment in or a distribution from your 403(b) account may have on your tax situation. Potential tax consequences can exist. We do not provide tax advice. We encourage you to consult with a tax professional about these and other tax consequences. Information Sources Our global resources used in the formulation of our advisory services go down to our roots—the data and analysis from Morningstar, Inc. that form the base of our investment process. This expansive, in-house network of global data and investment analysis spans asset classes and regions to help drive timely new ideas. Morningstar or its affiliates have more than 800 analysts and makes data available on more than 600,000 investment options and 5.2 million privately-held companies. The extensive data, analysis, and methodologies from these resources, along with external research reports, data, and interviews with investment managers are combined with financial publications, annual reports, prospectuses, press releases, and SEC filings to serve as the basis of our primary sources of information. For some of our services, we combine this information with other factors—including actuarial data, stock market exposure, probability analysis, and mean-variance optimization—into a proprietary software program to analyze a complex set of market data and variables that results in an advanced model that can provide investment recommendations and a projection of different outcomes. Security Type Risks Mutual Funds Investments in mutual funds involve risk, including loss of principal as a result of changing market and economic conditions and will not always be profitable. Collective Investment Trusts A collective investment trust (CIT) may also be called a commingled or collective fund. CITs are tax-exempt, pooled investment vehicles maintained by a bank or trust company exclusively for qualified plans, including 401(k)s, and certain types of government plans. CITs are unregistered investment vehicles subject to banking regulations of the Office of the Comptroller of the Currency (OCC), which means they are typically less expensive than other investment options due to lower marketing, overhead, and compliance-related costs. CITs are not available to the general public but are managed only for specific retirement plans. Money Market Funds A money market fund may impose a fee upon the sale of shares or may temporarily suspend your ability to sell shares if the fund’s liquidity falls below required minimum because of market conditions or other factors. An investment in a money-market vehicle is not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. For most money market funds, their sponsor has no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to the fund at any time. Although some money market funds seek to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. It is possible to lose money by investing in money market funds. 7  Stable Value Funds and Guaranteed Investment Contracts (“GICs”) The interest rate on a stable value fund or GIC is typically only guaranteed for a certain amount of time and may vary with changing market conditions. Withdrawal fees or penalties, sometimes substantial, may be charged if you decide to move money out of a stable value fund or GIC. Stable value funds and GICs are less likely to provide long-term protection against inflation, as compared to other options. Annuities An annuity is a tax-deferred investment structured to convert a sum of money into a series of payments over time. Annuity contracts have limitations and are not viewed as short-term liquid investments. An insurance company’s fulfillment of a commitment to pay a death or living benefit, a schedule of payments, a fixed investment amount guaranteed by the insurance company, or another form of guarantee depends on the claims-paying ability of the issuing insurance company. Any such guarantee does not affect or apply to the investment return or principal value of the separate account and its subaccount(s). The financial ratings quoted for an insurance company do not apply to the separate account and its subaccount(s). The insurance company offering an annuity will charge several fees to investors, including annual contract charges that compensate the insurance company for the cost of maintaining and administering the annuity contract, mortality and expense risk charges based on a percentage of a subaccount’s assets to cover costs associated with mortality and expense risk, and administration fees that are based on a percentage of a subaccount’s assets to cover the costs involved in offering and administering the subaccount. An annuity investor can also be charged a front-end load by the insurance company on their initial contribution, ongoing fees related to the management of the fund and surrender charges (which can be substantial) if the investor makes a withdrawal prior to a specified time. If the annuity subaccount is invested in a money-market fund, the money market fund is not FDIC- insured, may lose money, and is not guaranteed by a bank or other financial institution. Annuities can be complicated, and an investor should carefully read the insurance company’s offering material to understand how a specific annuity’s return will be determined. Variable Annuities have a rate of return that varies with underlying investment options in the market, and do not include a guarantee from the insurance company that you will earn a return. Fixed annuities have a predetermined rate of return an investor earns and a fixed income payout that is guaranteed by the issuing investment company and may be immediate or deferred. Payouts may last for a specific period or for the life of the investor. Investments in a deferred fixed annuity grow tax-deferred with income tax incurred upon withdrawal, and do not depend on the stock market. Fixed annuities typically do not have cost-of-living payment adjustments and are regulated by state insurance commissioners. Fixed indexed annuities, also called equity index annuities, are a combination of the characteristics of both fixed and variable annuities. Fixed indexed annuities offer a predetermined rate of return like a fixed annuity, but they also allow for participation in the stock market, like a variable annuity. Fixed indexed annuities are typically risker and offer the potential for greater return than fixed annuities, but less so than a variable annuity. Investments in a fixed indexed annuity grow tax-deferred with income tax incurred upon withdrawal and are regulated by state insurance commissioners. Item 9. Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would influence your decision to hire or retain us as your investment advisor. We do not have any material legal or disciplinary events to report. Item 10. Other Financial Industry Activities and Affiliations Morningstar Investment Management is a wholly owned subsidiary of Morningstar. Our offerings center around advisory services in our core capabilities of asset allocation, investment selection, and portfolio construction that we offer to individual investors and institutions. Morningstar Investment Management consists of two groups – Morningstar Wealth and Morningstar Retirement, each of whom offer certain advisory services. Our portfolio managers and their team members who are responsible for the day-to-day management of our portfolios are paid a base salary plus a discretionary bonus. The bonus is fully or partially determined by a combination of the employee’s business unit’s overall revenue and profitability, Morningstar’s overall annual revenue and profitability, and the individual’s contribution to the business unit. 8  For many of our advisory services, the universe of investment options from which we make our investment selections is defined by our Institutional Client. In some cases, this universe of investment options includes proprietary investment options of the Institutional Client. To mitigate any actual or potential conflict of interests presented by this situation, we subject all investment options to the same quantitative and qualitative investment selection methodology, based on several factors, including performance, risk, and expense so that the proprietary nature of an investment option does not influence our selection. We provide consulting or investment management services to institutional clients that offer registered or pooled investment products, such as mutual funds, variable annuities, collective investment trusts, or model portfolios. To mitigate the conflict of interest presented by our role in these investment products, we exclude such investment products from the universe of investment options from which we make our recommendations to other clients. please request a of our Institutional Advisory Services brochure and Morningstar Funds Trust is registered with the SEC as an open-end management investment company under the Investment Company Act of 1940, as amended, and has retained us as its investment adviser. The funds within the Morningstar Funds Trust will be used as the underlying holdings for certain Morningstar Wealth portfolios, most notably the mutual fund model portfolios series. The funds within the Morningstar Funds Trust can only be utilized in connection with the model portfolios and separately managed accounts offered by Morningstar’s Investment Management group. To mitigate the conflict of interest presented by our role in these investment products, we exclude such investment products from the universe of investment options from which we make our recommendations to other clients, including participants in MetLife’s ExpertSelect program. For more information about the Morningstar Funds Trust, visit copy http://connect.rightprospectus.com/Morningstar to view the prospectus. Morningstar Investment Management is registered as a Commodity Pool Operator with the Commodity Futures Trading Commission. Some of Morningstar Investment Management’s employees are registered with the National Futures Association as principals or associated persons. We receive compensation for our research and analysis activities (e.g., research papers) from a variety of financial institutions including large banks, brokerage firms, insurance companies, and mutual fund companies. In order to mitigate any actual or potential conflicts of interest that arise from this service, we ensure that our research and analytical activities are non-biased and objective given our business relationships. Employees who provide research and analysis for clients are separate from our sales and relationship manager staff in order to mitigate the conflict of interest that an employee may feel pressure to present results in such a way as to maintain existing or gain new business. In addition, methodology updates that impact investment recommendations or decisions are peer reviewed by the Morningstar Retirement Investment Policy Committee, which mitigates the conflict of interest by providing checks and balances so that no employee can act unilaterally in making recommendation decisions. Our investment professionals provide portfolio construction and ongoing monitoring and maintenance for the Morningstar Wealth portfolios offered by our subsidiary, Morningstar Investment Services and to third-party financial institutions on Morningstar Investment Services’ behalf. While the same or similar portfolios are offered by us to our institutional clients, we do not believe these responsibilities create any material conflicts of interest for our clients. In order to mitigate any perceived conflict of interest, when we offer discretionary services for Morningstar Wealth’s portfolios, transactions for our clients are placed at the same time as transactions for Morningstar Investment Services’ discretionary clients as part of block trades. We have procedures in place to ensure that trades are allocated in such a manner as to not favor one client over another. When we offer portfolios on a non-discretionary basis to third-party institutional clients, our institutional clients receive trade recommendations just after trades are placed for discretionary clients, due to our heightened fiduciary responsibilities to our discretionary clients. In addition, all non- discretionary clients are notified of transaction recommendations after the close of the trading day, so that no one such client has an advantage over another. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. Morningstar Investment Management will become the investment adviser to many of Morningstar Investment Services’ third-party financial institution clients. Once this occurs, trade recommendations will be communicated to non-discretionary clients after the close of the trading day and Morningstar-affiliated accounts in Morningstar Wealth portfolios will be traded the next day so that no one person has an advantage over another.) 9  We invested in the Series D funding round of SMArtX Advisory Solutions, a managed account technology provider and architect of the SMArtX turnkey asset management platform. This investment will assist in the build out of SMArtX’s development capabilities, which could benefit us or our parent company. Daniel Needham, our co-president serves on the board of SMArtX. When we, along with Morningstar and/or our other affiliates offer services to the same client, we have the option to enter into a bundled agreement with the client that encompasses all or part of those services. Additional fee(s) for such product(s) or service(s), if required, will be set forth in our agreement with the client. In these situations, clients pay a fee directly to us and each such affiliate for its products or services, or as part of a joint fee schedule which encompasses all services. Affiliations –Registered Entities Morningstar has various subsidiaries across the globe that are each registered with the applicable regulatory body or bodies in that country to provide investment management or other advisory services. We share resources with these various subsidiaries. One subsidiary, Morningstar Investment Services LLC, is our subsidiary and is also an investment adviser registered under the Advisers Act. Morningstar Investment Services is additionally registered with the Securities and Exchange Commissions as a broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA). Morningstar Investment Services offers model portfolios and separately managed accounts through its role as the sponsor of an investment advisory program known as the Wealth Platform and through third- party financial institutions, plan sponsor services, and retirement plan services for institutional and retail clients. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025.) In some cases, our senior management members have management responsibilities to these other affiliated entities. We do not believe that these management responsibilities create any material conflicts of interests for our clients. Morningstar Wealth and Morningstar Retirement have set up shared services teams composed of employees of our affiliate and located at our affiliate’s office in Mumbai, India. Morningstar Retirement also has a team composed of employees of our affiliate located at our affiliate’s office in Toronto, Canada. We compensate our affiliates for services rendered via intercompany charges. The services and compensation will be governed by intercompany agreements. This compensation will likely be lower than compensation negotiated with non-affiliated firms for the same or similar services. To mitigate any conflict of interest between us and our affiliates we have established dual reporting lines for employees on these teams so that such employees report up to employees of Morningstar Investment Management. We’ve also established information security boundaries and technology separation to protect our non- public information and Morningstar’s compliance department monitors the personal trading activity of these employees. Morningstar Research Services LLC is also a wholly owned subsidiary of Morningstar and an investment adviser registered under the Advisers Act. Morningstar Research Services’ offerings center around the production of investment research reports and investment consulting services to financial institutions/institutional investors who themselves are registered with a regulatory body. Conflicts of interests between us and Morningstar Research Services are mitigated by such things as the maintenance of separate legal entities and dual reporting/organization lines, and the utilization of physical (i.e., separate office “neighborhoods”) and technological separation. Morningstar Research Services also maintains a committee structure so as to limit any unilateral decisions. Morningstar’s compliance department monitors the personal trading activities of Morningstar Research Services’ employees. We have the option to engage Morningstar Research Services to perform investment manager due diligence and/or selection services on our behalf as a sub-adviser or consultant. The notification to and authorization by the Institutional Client to our engaging Morningstar Research Services as a sub-adviser is addressed in our agreement with the Institutional Client. On such occasions, we compensate Morningstar Research Services for services rendered via an intercompany charge. The services and compensation will be governed by an intercompany agreement. This compensation will likely be lower than compensation negotiated with non-affiliated financial institutions/institutional investors for same or similar services. Morningstar Research Services’ employees who are engaged to provide manager due diligence and/or selection service are prohibited from using non-public/confidential information obtained because of their engagement in its investment research reports and/or investment consulting services to clients, including us. 10  Morningstar Research Services provides information to the public about various securities, including managed investments like open-end mutual funds and ETFs, which include written analyses of these investment products in some situations. Although we use certain products, services, or databases that contain this information, we do not participate in or have any input in the written analyses that Morningstar Research Services produces. While we consider the analyses of Morningstar Research Services, our investment recommendations are based on our decisions in regard to the investment product. Morningstar Research Services issues investment research reports on securities we hold in our portfolios or recommend to our clients, but they do not share any yet-to-be published views and analysis and/or changes in estimates (i.e., their confidential information) with us on these securities. In making investment decisions or recommendations, we use Morningstar Research Services’ publicly available analysis as part of our review process, and do not have access to their analysis prior to its public dissemination. We mitigate any actual or potential conflicts of interest that could arise from the access of their analysis prior to publication through measures such as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. Morningstar Research Services prepares qualitative analysis on separately managed accounts and model portfolios. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis nor recommend any Morningstar separately managed account or model portfolio we create and manage. Some of Morningstar Research Services’ clients are sponsors of funds or associated with other securities that we recommend to our institutional clients. We mitigate any actual or potential conflicts of interests resulting from this fact through such measures as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar Research Services and their clients when analyzing investments or making recommendations. Morningstar Investment Management serves as an investment adviser to investment companies registered under the Investment Company Act of 1940, as amended, and to other pooled investment products. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis on nor recommend as part of their investment consulting services any investment company we are an investment adviser or sub-adviser to. Affiliations – Morningstar, Inc. Our parent company, Morningstar, Inc., is publicly traded (Ticker Symbol: MORN). We may recommend an investment product that holds a position in publicly traded shares of Morningstar’s stock. Such an investment in Morningstar’s stock is solely the decision of the investment product’s portfolio manager. We have no input into a portfolio manager’s investment decision nor do we require that the investment products we recommend own shares of Morningstar. An investment product’s position in Morningstar has no direct bearing on our investment selection process. We mitigate any actual or potential conflicts of interest by not factoring Morningstar’s publicly traded stock into our qualitative or quantitative analysis nor in our recommendations. Morningstar offers various products and services to the public. Some of Morningstar’s clients are service providers (e.g., portfolio managers, advisers, or distributors) affiliated with a mutual fund or other investment option. We may have a contractual relationship to provide consulting or advisory services to these same service providers or we may recommend the products of these service providers to our advisory clients. To mitigate any actual or potential conflicts of interest, we do not consider the relationship between Morningstar and these service providers when making recommendations. We are not paid to recommend one investment option over another, including products of service providers with which Morningstar has a relationship. Morningstar provides information to the public about various investment products, including managed investments like open-end mutual funds and ETFs. In some cases, this information includes written analyses of these investment products. Although we use certain products, services, or databases of Morningstar, we do not or have any decision- making input in the written analyses that Morningstar provides its licensees. While we consider the analyses of Morningstar, our investment recommendations are oriented to the mandates of the investment products in question. 11  Morningstar hosts educational events and conferences and on occasion provides us with the opportunity to suggest invitees or offer (proactively or upon request) discounted or waived registration fees. We mitigate any actual or potential conflicts of interest this introduces by using pre-defined criteria to select Clients for these opportunities. Morningstar offers various products and services to retail and institutional investors. In certain situations, we recommend an investment product that tracks an index created and maintained by Morningstar. In such cases, the investment product sponsor has entered into a licensing agreement with Morningstar to use such index. To mitigate any conflicts of interest arising from our selection of such investment products, we use solely quantitative criteria established by our advisory client to make such selection, or, in the alternative, Morningstar’s compensation from the investment product sponsor will not be based on nor will it include assets that are a result of our recommendation to our advisory client to invest in those investment products. In other cases, some of Morningstar’s clients are sponsors of funds that we recommend to our clients. Morningstar does not and will not have any input into our investment decisions, including what investment products will be recommended for our recommended portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar when analyzing investments or making recommendations. We mitigate any actual or potential conflicts of interests resulting from that by not producing qualitative analysis on any such exchange-traded fund as well as imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines between, and monitoring by the compliance department. In some instances, we create portfolios that track an index created and maintained by Morningstar. Morningstar does not and will not have any input into our investment decisions, including what investment products will be included in our portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. Morningstar has and maintains accounts which they invest in accordance with investment strategies created and maintained by us. Those investment strategies are deployed using equity securities. As we have discretion over these accounts, Morningstar’s accounts are traded at the same time as our and Morningstar Investment Services’ other discretionary client accounts in order to ensure that Morningstar’s accounts are not treated more favorably than our client accounts. Some of Morningstar’s accounts are used as the subject of newsletters offered by Morningstar. In order to ensure that Morningstar’s newsletter subscribers are not treated more favorably than our clients, which would result in a breach of our fiduciary duty, we do not report trades in Morningstar’s accounts invested in our strategies to newsletter subscribers until after our client accounts have been traded or our non-discretionary clients have been notified. As a wholly owned subsidiary, we use the resources, infrastructure, and employees of Morningstar and its affiliates to provide certain support services in such areas as technology, procurement, human resources, account, legal, compliance, information security, and marketing. We do not believe this arrangement presents a conflict of interests to us in terms of our advisory services. Employees of Morningstar that provide support services to us have the option to maintain their Financial Industry Regulatory Authority (“FINRA”) security licenses under Morningstar Investment Services’ limited broker/dealer registration, if appropriate for their current job responsibilities. We believe no conflict of interest exists due to the maintenance of these security licenses. In certain situations, we make our clients aware of various products and services offered by Morningstar or its affiliates. We do not receive compensation for that introduction. Morningstar and its affiliates also have the option to make their clients aware of various products and services offered by us. Morningstar and its affiliates do not receive any compensation from us for that introduction, unless it falls under a solicitation arrangement, as described in Item 14 below. Morningstar Wealth, through Morningstar and its subsidiaries, make available products such as: (i) the Morningstar Wealth Platform; (ii) Morningstar Funds Trust, (iii) Morningstar Office, Morningstar’s RIA portfolio software service; (iv) Morningstar ByAllAccounts, Morningstar’s investment data aggregation service; and (v) Morningstar.com, Morningstar’s individual investor site offering. Daniel Needham, our co-president, has management responsibilities for Morningstar Wealth. We do not believe that these management responsibilities create any material conflicts of interests for our clients, but we mitigate any actual or potential conflicts of interests resulting from that by imposing the Investment Management group. 12  Affiliations – Morningstar, Inc.’s Subsidiaries Equity and manager research analysts based outside the United States are employed by various wholly owned subsidiaries of Morningstar. These analysts follow the same investment methodologies and process as Morningstar Research Services, as well as being held to the same conduct standards. As a result, we do not believe this structure causes actual or a potential for a conflict of interest. Affiliations – Credit Rating Agency We are affiliated with the Morningstar DBRS group of companies, which include DBRS, Inc., DBRS Limited, DBRS Ratings GmbH, and DBRS Ratings Limited. DBRS, Inc. is registered with the Securities and Exchange Commission as a Nationally Recognized Statistical Rating Organization (NRSRO). Morningstar DBRS’ companies are also registered with and governed by applicable regulatory body or bodies in other countries around the globe. In our analysis of certain securities, we use the publicly available credit rating and analysis issued by Morningstar DBRS. Because of our use of Morningstar DBRS’ ratings and analysis is limited to that which is publicly available, we do not believe there is an actual or potential conflict of interest that arises from such use. Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Code Of Ethics We have in place a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act (“Code of Ethics”). Our Code of Ethics strives to uphold the highest standards of moral and ethical conduct, including placing our clients’ interest ahead of our own. Our Code of Ethics covers all our officers and employees as well as other persons who have access to our non-public information (collectively “Access Persons”). Our Code of Ethics addresses such topics as professional and ethical responsibilities, compliance with securities laws, our fiduciary duty, and personal trading practices. Our Code of Ethics also addresses receipt and/or permissible use of material non-public information and other confidential information our Access Persons may be exposed and/or have access to given their position. The Code of Ethics is provided upon hire and at least annually thereafter and at each time, the Access Person must certify in writing that she or he has received, read, and understands the Code of Ethics and that they agree to or have complied with its contents. A copy of our Code of Ethics is available to existing and prospective clients by sending written request to compliancemail@morningstar.com. Interest In Client Transactions Our Access Persons have the option to maintain personal investment accounts and purchase or sell investments in those accounts that are the same as or different from the investments we recommend to clients. Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities should not conflict with our advisory activities or the timing of our recommendations and interfere with our clients’ interests, while allowing our Access Persons to invest in their own accounts. We do not engage in principal transactions (transactions where we, acting in our own account or in an affiliated account, buy a security from or sell a security to a client’s account) nor do we engage in agency cross transactions (transactions where we or our affiliate executes a transaction while acting as a broker for both our client and the other party in the transaction). Interest In Securities That We May Recommend Morningstar Investment Management has and maintains a number of seed accounts (accounts used to establish a strategy we offer or are tracking), many of which follow strategies we offer to clients. We place block trades for our accounts, therefore trade requests for our seed accounts are placed at the same time as trades are placed for those client accounts invested in the same strategy and for which we have discretion. Block trades are allocated in such a manner as to ensure that our seed accounts do not receive more favorable trades than our clients’ accounts. Client accounts that we manage on a discretionary basis and thus, our seed accounts, are traded before we provide model portfolio trade recommendations to other clients using our model portfolios. However, our model portfolio clients receive trade recommendation after the close of the trading day, so that no one model portfolio client is favored over another. Upon the cessation of Morningstar Investment Service’ discretionary advisory services, anticipated by the end of the second quarter of 2025, trade recommendations will be communicated to non-discretionary clients after the close of 13  the trading day and Morningstar-affiliated accounts in Morningstar Wealth portfolios will be traded the next day so that no one person has an advantage over another. Personal Trading By Access Persons Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities does not interfere with our clients’ interests. While our Access Persons have the option to maintain personal investment accounts, they are subject to certain restrictions. Our Code of Ethics includes policies designed to prevent Access Persons from trading based on material non-public information. Access Persons in possession of material non-public information are prohibited from trading in securities which are the subject of such information and from tipping such information to others. In certain instances, we employ information blocking devices such as restricted lists to prevent illegal insider trading. Morningstar’s compliance department monitors the activities in the personal accounts of our Access Persons (and any accounts in which they have beneficial ownership) upon hire and thereafter. Access Persons are required to pre-clear IPO, initial digital coin offerings, and private placement transactions with Morningstar’s compliance department. Item 12. Brokerage Practices Where we exercise investment discretion, we will generate trade instructions for each individual account that requires rebalancing and forward those instructions to the appropriate institution as designated by the plan provider. As a result, we do not have the ability to make decisions regarding which broker is used to execute the transactions in your account. We do not participate in any soft dollar practices. Item 13. Review of Accounts We provide ongoing monitoring of the investment options in the Program and, when necessary, remove and replace investment options included in the Program. However, we do not provide periodic review or ongoing monitoring of individual participant accounts. Item 14. Client Referrals and Other Compensation We make direct or indirect cash or non-cash payments to our affiliates or to unaffiliated third parties for recommending our services as described in Item 4 above. If such payments occur, they will be done pursuant to Rule 206(4)-1 of the Advisers Act. Clients referred by third party solicitors may in some cases pay a higher fee than clients who contract with us directly. Through disclosures, which are spoken or given in writing to clients at the time of the solicitation, solicited clients solicited by an unaffiliated person are made aware of the arrangement between the solicitor and us (and therefore that the solicitor has a financial interest in recommending us to client), any other material conflicts of interest, and the terms of any compensation paid directly or indirectly to the solicitor as a result of their referral. We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. We enter into agreements with certain Institutional Clients whereby we provide compensation to Institutional Clients in exchange for access to their financial professionals to educate them about our advisory products and services, having our name, products, or services listed or highlighted in Institutional Client materials, attendance or booth space at Institutional Client conferences, and/or similar marketing, distribution, and educational activities. We also provide compensation to Institutional Clients to sponsor meetings and events for their financial professionals and/or clients. Item 15. Custody We do not serve as a custodian of client assets. However, in cases where we have the ability to debit fees directly from client accounts, we are deemed to have custody of client assets under Rule 206(4)-2 of the Advisers Act, even if we do not act as a custodian. The plan sponsor is responsible for selecting the custodian for plan assets. The selection of custodians may be limited by your plan provider. Item 16. Investment Discretion You retain the investment discretion over the assets in your Plan account. We only have investment discretion under the limited circumstances more specifically described under Participant Services in the Advisory Business section above, in the event you fail to provide MetLife with instructions on how to reallocate investments in your account in an investment option that has been removed from the Program lineup, and how to allocate future investments in your account. 14  Item 17. Voting Client Securities You are responsible for receiving and voting proxies for all investments held in your account. We do not have the authority to and will not vote proxies. You may receive proxies or other solicitations directly from your plan account’s custodian. We cannot provide information or advice in regard to questions you have about a particular solicitation. We do not advise or act for clients in legal proceedings, including class actions or bankruptcies, involving recommended securities. Item 18. Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We do not have any financial commitment that impairs our ability to meet our contractual and fiduciary commitments to clients, nor have we been the subject of any bankruptcy proceeding. 15 

Morningstar Investment Management LLC Form ADV Part 2A: Firm Brochure Morningstar Wealth Advisory Services 22 West Washington Street, Chicago, IL 60602 Phone: 312.696.6000 www.corporate.morningstar.com March 27, 2025 Select Lists. Information on the Investment Analytics, Monitoring and Comparative Analysis Reports service has been removed. us at 312.696.6000 or send an email Item 5. Fees and Compensation was also updated to include information about marketing, distribution, and educational support and third-party compensation arrangements we have with institutional clients. This brochure provides information about the qualifications and business practices of Morningstar Investment Management LLC. If you have any questions about the contents of this brochure, please to contact compliancemail@morningstar.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Morningstar Investment Management LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss was also updated to provide information about valuation, sub-advisers, and the prospectus risks for the Morningstar Funds Trust and to remove risks for securities that are not applicable to the services being offered. Item 10. Other Financial Activities and Affiliations was updated to disclose an investment in SMArtX. Morningstar Investment Management LLC is registered with the SEC as a registered investment adviser. Registration with the SEC does not imply a certain level of skill or training. Please retain this brochure for future reference. Item 14. Client Referrals and Other Compensation was updated to disclose that we receive compensation from unaffiliated third parties for referring their services to other advisory firms or investors and note we provide compensation to institutional clients to provide marketing or educational support to their financial professionals and to sponsor meetings and events for their clients. We made other edits where necessary to correct grammar or punctuation, to provide clarification or further information, for consistency in terminology or content, or to improve the readability of the brochure. All current versions of our firm brochures are available in the Part 2 Brochures section of this record on the SEC’s website. You can also request a copy of our current brochure free of charge by contacting our Compliance Department at 312.696.6000, or by email to compliancemail@morningstar.com. In your request, please indicate the name of the company (Morningstar Investment Management) and the service brochure(s) (Morningstar Wealth Advisory Services, Morningstar Retirement Advisory Services for Individuals, or Morningstar Retirement Institutional Advisory Services) you are requesting. Item 2. Material Changes The Morningstar Wealth Advisory Services Firm Brochure dated March 2025 contains no material changes since this brochure was first created in November 2024. Non-material changes since our last annual update include: Investment Services, anticipates the cessation of Item 3. Table of Contents Advisory Business ....................................................................................... 1 Fees and Compensation .............................................................................. 4 Performance Based Fees and Side-by-Side Management ........................... 5 Types of Clients ........................................................................................... 5 Methods of Analysis, Investment Strategies, and Risk of Loss ................... 5 Disciplinary Information ............................................................................. 12 Other Financial Industry Activities and Affiliations ..................................... 12 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................ 15 Brokerage Practices ................................................................................... 15 Review of Accounts .................................................................................. 16 Client Referrals and Other Compensation .................................................. 16 Custody ..................................................................................................... 16 Investment Discretion ................................................................................ 16 Voting Client Securities ............................................................................. 17 Financial Information .................................................................................. 17 As applicable throughout the Firm Brochure, we noted that our subsidiary, Morningstar its discretionary advisory services by the end of the second quarter of 2025. Morningstar Investment Management will become the investment adviser to many of Morningstar Investment Services’ third-party financial institution clients. At the time of this change, trade recommendations for Morningstar Wealth portfolios will be communicated to non-discretionary clients after the close of the trading day and Morningstar-affiliated accounts in Morningstar Wealth strategies will be traded the next day so that no one person has an advantage over another. Item 4. Advisory Business was updated to reflect our assets under management and advisement as of December 31, 2024. that was incorporated in 1999. Morningstar is a wholly owned subsidiary of Morningstar, Iten 4. Advisory Business, Item 5. Fees and Compensation, and Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss were updated to add information about a previously offered service we are bringing back, Item 4. Advisory Business Firm Information Morningstar Investment Management LLC is a Delaware limited liability Investment company Management Inc. (“Morningstar”). Morningstar is a publicly traded company (Nasdaq Ticker: MORN) with Mr. Joseph Mansueto, Executive Chairman of Morningstar, ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 2 of 17 • Asset allocation, capital market assumptions, and other advisory services to institutional clients. holding more than 35% of Morningstar’s outstanding shares. Because of that ownership, Mr. Mansueto is an indirect owner of Morningstar Investment Management. Morningstar Investment Management is registered with the SEC under Section 203(c) of the Investment Advisers Act of 1940, as amended (“Advisers Act”). Morningstar Investment Management has filed the appropriate notices to conduct business in all 50 states, the District of Columbia, Guam, the Virgin Islands, and the Commonwealth of Puerto Rico. Morningstar Investment Management is registered with the U.S. Commodity Futures Trading Commission as a Commodity Pool Operator (“CPO”) and is a member of the U.S. National Futures Association. Institutional Asset Management For Institutional Clients who sponsor registered or pooled investment products, we serve as a portfolio manager, portfolio construction adviser, or sub-adviser. We provide recommendations for asset class allocation targets and/or selection of underlying holdings to fulfill each asset class allocation target. Underlying holdings may include, but are not limited to, open-end mutual funds, exchange-traded funds (“ETFs”), and collective investment trusts. The universe of underlying holdings is generally defined by the Institutional Client and can include investment products that are affiliated with that Institutional Client. This service typically includes ongoing responsibilities such as monitoring the underlying holdings and reviewing and updating asset allocation percentages and/or underlying holdings as necessary. Morningstar Investment Management, along with other Morningstar subsidiaries authorized in appropriate jurisdictions to provide investment management and advisory services, is part of a global investment team composed of investment analysts, portfolio managers, and other investment professionals. These investment and operations teams span the globe, with primary offices in Chicago, London, and Sydney. Morningstar Investment Management is composed of two units that are organizationally and functionally segregated from each other – Morningstar Wealth and Morningstar Retirement. Each unit retains discretion over the assets it manages, has a separate and distinct investment process, and is held out to the public as separate from the other. about the Funds is We are an investment adviser to Morningstar Funds Trust, registered with the SEC as an open-end management investment company under the Investment Company Act of 1940, as amended. We have overall supervisory responsibility for the general management and investment of the fund portfolios within the Morningstar Funds Trust (“Morningstar Funds”), which are managed in a multimanager structure. Subject to the review and approval by the Morningstar Funds Trust’s board, we set each Morningstar Fund’s overall investment strategy. We are also responsible for the oversight and evaluation of each Morningstar Fund’s sub-advisers. The Morningstar Funds will be used as the underlying holdings for certain model portfolios, most notably mutual fund model portfolios, offered by Morningstar Investment Management and our subsidiary, Morningstar Investment Services LLC The Morningstar Funds include the Morningstar Alternatives Fund, Morningstar Defensive Bond Fund, Morningstar Global Income Fund, Morningstar International Equity Fund, Morningstar Multisector Bond Fund, Morningstar Municipal Bond Fund, Morningstar Total Return Bond Fund, Morningstar U.S. Equity Fund, and the Morningstar Global Opportunistic Equity Fund. More at Morningstar information http://connect.rightprospectus.com/Morningstar. insurance companies, investment advisers, This brochure focuses on the products and services we provide to retail and institutional Morningstar Wealth clients. You can obtain a copy of our Morningstar Retirement brochure describing our products and services for individuals (managed accounts, advice, and personal target-date fund services for retirement investors, “Morningstar Retirement Advisory Services for Individuals”) or products and services in our core capabilities of asset allocation, investment selection, and portfolio construction that we offer to institutions such as asset management firms, banks, broker/dealers, consultants, investment fiduciaries, plan sponsors of retirement plans, plan providers of retirement plan services, trusts, and other business entities (“Morningstar Retirement Institutional Advisory Services”) by following the instructions above. investment strategies Model Investment Strategies and Seed Accounts For institutional clients who offer a proprietary advisory program, or a platform that makes investment strategies available for use by other financial institutions, we create model (collectively, “Strategies”) for use through such programs or platforms. The Strategies are typically designed for use by a financial professional with their retail investor clients, and can include risk- or target date-based asset allocation portfolios, portfolios designed to address a certain financial planning need or goal, or relatively focused stock or bond portfolios. We generally provide sales and marketing support on behalf of the institutional client by educating financial professionals who use the program or platform about the strategies we provide. Advisory Services We Offer – Overview Morningstar Wealth and Morningstar Retirement are groups within Morningstar Investment Management that independently offer certain advisory products and services. These investment advisory services focus on our core capabilities in asset allocation, investment selection, and portfolio construction to retail or institutional clients. Institutional clients include, but are not limited to, asset management firms, banks, broker/dealers, consultants, endowments, foundations, insurance companies, investment advisers, investment fiduciaries, plan sponsors of retirement plans, providers of retirement plan services, trusts, and other business entities. investment strategies to third-party The Morningstar Wealth unit within Morningstar Investment Management offers: • • Institutional asset management, Proprietary model institutional clients on a non-discretionary basis as a strategist, • In providing this service, we act as a non-discretionary model manager. We select and monitor the asset allocation and underlying holdings of each Strategy based on a universe of investments typically defined by the institutional client. In general, we provide ongoing monitoring of the Strategies, along with rebalancing and reallocating recommendations. The investor’s financial professional or the investor is responsible for suitability, choice of custodian, and other services related to investing in a Strategy. The institutional client or the financial professional using the advisory program or platform has the full and sole discretion over their client accounts invested in a Strategy and has the ability to deviate from our Strategy by including all or • Maintains seed accounts that it manages on a discretionary basis in accordance with its proprietary model investment strategies, Recommendations of other investment advisers or platforms that offer our model investment strategies to retail investors, and ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 3 of 17 a portion of our recommendations and/or supplement or modify our investment recommendations. Profile responses and assist the investor in selecting a Strategy that is appropriate for and aligned with the investor’s Profile as well as identifying any available features or options the investor would like to utilize and any reasonable restrictions and/or available customizations the investor wish to place on the management of their account and/or account assets. We also maintain seed and other Morningstar-affiliated accounts of our Strategies in which we act as a discretionary investment manager. The seed accounts are maintained to provide an indication of the performance of each Strategy while the Morningstar-affiliated accounts are used with the Morningstar Newsletters product. If features, options, reasonable restrictions and/or customizations are available to an account, the financial advisor will assist the investor in completing necessary information based on the investor’s preferences (“Specifications”). This information varies by account and/or Strategy and may include indicating exclusions, subject to limitations, for items such as specific securities, sectors, industries, themes, master limited partnerships, foreign companies, or fixed-income securities subject to the Alternative Minimum Tax, or other requestable portfolio customizations. If applicable, the financial advisor will also assist the investor with the choice of a qualified custodian for their account from those available through the institutional client. We offer a broad array of multi-asset and equity Strategies designed to play varying roles for investors. Our multi-asset Strategies range from conservative to aggressive, and are comprised of mutual funds, ETFs, or a combination of the two. In addition to broad, widely diversified Strategies that can function as the “core” portion of an investor’s financial strategy, we also manage more targeted Strategy options. Our equity Strategies are generally concentrated portfolios of stocks chosen based upon their valuation and fundamental characteristics. We also have a lineup of index-based portfolios which can incorporate individual needs and preferences. The Strategies, most notably those utilizing mutual funds, may have underlying holdings that include one or more of the Morningstar Funds. The Morningstar Funds became accessible through certain Strategies in November 2018. Each Morningstar Funds’ summary prospectus, prospectus, statement of additional information (‘SAI”), and other regulatory filings are available at http://connect.rightprospectus.com/Morningstar. Account Set-Up: Once an appropriate Strategy, custodian, and any other account features have been determined, the financial advisor will review the disclosure documents and help the investor complete applicable account documents. Account documents will typically include an Investment Management Agreement with the institutional client and a brokerage account application for the selected custodian. Please note, the custodian can charge additional fees (“Clearing Fees”) for transactions made in accounts as a result of investment decisions made for a Strategy and/or other account administrative fees that are in addition to the institutional client’s fees described in their account opening documents. Clearing Fee details can be requested from the client’s Custodian. Select Lists We work with institutional clients to analyze an investment universe they define and create a subset or “select list” of investments that meet specific criteria, including the institutional client’s proprietary requirements. A select list is typically used by the institutional client’s financial professionals when working with their clients to put together an investment strategy. Each select list is derived through a combination of quantitative screens and qualitative analysis, resulting in a menu of investments under various asset categories. Typically, we provide ongoing monitoring of those investments within the select list to help ensure that the investment options initially selected for the select list continue to satisfy the criteria that led to their initial selection. This service may be provided by a sub-adviser, Morningstar Research Services LLC, who is affiliated with us. Asset Allocation Services We provide Institutional Clients and their financial representatives tools for identifying their clients’ investment goals and risk tolerance (such as risk tolerance questionnaires), and a mechanism to match those goals and risks with an appropriate asset allocation strategy. Asset allocation services are typically used by our Institutional Clients in their investment products, wrap programs, variable annuity asset allocation programs, or similar programs. If included in an agreement with an Institutional Client, asset allocation models are periodically reviewed and adjusted as needed. We may provide Institutional Clients with rebalancing triggers and recommendations on when the allocations for asset classes should be revisited or adjusted. Customized Services Upon request, we will take under consideration the provision of a customized version of the above services or a different type of advisory services that would utilize our core capabilities in asset allocation, investment selection, or portfolio construction. Given the customized nature, the client can impose constraints/restrictions on such things as security types, asset classes, or proprietary security requirements and/or wish to collaborate with us on such things as investment methodology and screening criteria. Recommendations of Other Investment Advisers or Platforms As noted above, we provide our Strategies to institutional clients who offer a proprietary advisory program or a platform that makes investment strategies available for use by other financial institutions. For institutional clients who have entered into a promoter agreement with us, we will recommend to certain retail investors or financial advisors that they access our Strategies through these institutional clients. We assist the investor in determining the suitability of a Strategy, choice of custodian, and other services related to investing in a Strategy. The institutional client has discretion over client accounts invested in a Strategy and has the ability to deviate from our Strategy. We are incentivized to recommend institutional clients that offer our Strategies as the institutional client pays us a licensing fee for use of our Strategies based on assets invested in the Strategies. Wrap Fee Programs We do not sponsor a wrap fee program, but we do provide portfolio management services to a wrap fee program offered by our subsidiary, Morningstar Investment Services LLC, through the Morningstar Wealth program. This wrap fee program is scheduled to be closed around the end of the second quarter of 2025. Pre-Account Opening: For investors we recommend access our Strategies through one of our institutional clients, a financial advisor will assist the investor in completing a client profile (“Profile”). This Profile helps the investor and the investor’s financial adviser determine such things as the investor’s risk tolerance, investment objectives, time horizon, financial goals, and personal and financial situation. The financial adviser will review the investor’s ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 4 of 17 Assets Under Management As of December 31, 2024, the discretionary regulatory assets under management for Morningstar Investment Management (rounded to the nearest $100,000) were: Retirement Services to Individuals: $29,068,100,000 Investment Management Services to Institutional Clients: $36,267,000,000 Total Regulatory Asset Under Management: $65,335,000,000 Strategies, and any other services we provide to the institutional client. Some institutional clients charge a fee for including our Strategies on their program or platform. Clients of those programs and platforms will be charged a higher fee than that noted above. Strategy fees are typically charged quarterly and may be charged in advance based on the prior period’s ending balance or arrears based on the average daily balance for the applicable period. If, in accordance with the contractual terms, the institutional client terminates the agreement they have with us prior to the end of the billing period, we will refund any unearned fees on a pro rata basis after the termination of the contract. The non-discretionary assets under advisement for Morningstar Investment Management (rounded to the nearest $100,000) were $235,870,200,000. For any Strategy in which one or more of the underlying holdings is a Morningstar Fund, no investment management fee is charged with respect to the Morningstar Funds. As disclosed above, in accordance with the Investment Management Agreement between us and Morningstar Funds Trust, we receive compensation from Morningstar Funds Trust based on the assets invested in the Morningstar Funds for the investment management activities we perform for the Morningstar Funds. Since we receive compensation for this activity, we don’t charge a separate investment management fee with respect to the Morningstar Funds in a Strategy. Item 5. Fees and Compensation Fees and Compensation – Overview We typically negotiate our fees, payment terms, and payment schedules on an individual basis with each institutional client. We utilize a standard fee schedule for recommendations of other investment advisers or platforms. The services we provide, the specific fees for such services, and the contract term are governed by the contractual agreement between us and our client. Clients may not receive all of the services listed above. Our fees vary depending on the services selected and could include a fixed fee, a basis-point fee, and/or a technology licensing fee. Fees for some services take into consideration such factors as the number of services being provided and service specific variables such as the universe of investments, variables in monitoring frequency, delivery type, investment types, and frequency of written analysis. Select Lists Select list fees are negotiable but generally range from $50,000 to $400,000 annually. The actual amount charged depends on a range of variables including the intended use of the select list, the number of type of securities included, the type of reporting the institutional client wishes to receive from us, the degree of customizations or constraints placed on us, and whether the service includes on-going monitoring of the select list. The fee is typically charged quarterly in advance. If, in accordance with the contractual terms, the institutional client terminates the agreement they have with us prior to the end of the billing period, we may refund any unearned fees on a pro rata basis after the termination of the contract. In addition to the fee, payment terms and payment schedules are negotiable. Institutional Asset Management Our Institutional Asset Management fees are negotiable but generally include an asset-based fee and can include a minimum annual fee. The asset-based fee typically ranges from 2 to 15 basis points of the assets being managed or consulted upon while the minimum annual fee is $100,000 - $200,000. The actual fee depends on a range of variables including our role in providing the services, the type of security we are providing services for, and the amount of assets involved. The fee is typically charged monthly in arrears. Recommendations of Other Investment Advisers or Platforms When recommending another institutional client who offers our Strategies, we receive a portion of the fees the institutional client charges the investor. We negotiate this fee with each institutional client, but they generally are paid to us for the period of time the investor remains invested in one or more of our Strategies through the institutional client. The fee may be paid in advance or in arrears. As the investment adviser to the Morningstar Funds Trust (“Trust”), we are compensated by the Trust based on assets within the Morningstar Funds for our investment management activities in accordance with the Investment Management Agreement between the Trust and us. We are entitled to receive an annual management fee calculated daily and payable monthly equal to the following percentage of a Morningstar Fund’s average daily net assets: Investors can find the institutional client’s fees applicable to their account in their proposal and/or account opening documents. Morningstar Fund Morningstar U.S. Equity Fund Morningstar International Equity Fund Morningstar Global Income Fund Morningstar Total Return Bond Fund Morningstar Municipal Bond Fund Morningstar Defensive Bond Fund Morningstar Multisector Bond Fund Morningstar Global Opportunistic Equity Fund Morningstar Alternatives Fund Management Fee 0.67% 0.83% 0.35% 0.44% 0.44% 0.36% 0.61% 0.47% 0.85% Asset Allocation Services Our Asset Allocation Services fees are negotiable but generally range from $50,000 to $500,000 annually. The actual amount charged depends on a range of variables including the terms of distribution, number of sets, type and scope of the models requested (including the number of asset classes used in the asset allocation models), and whether the client receives other advisory services from us. The fee is typically charged annually in arrears. In addition to the fee, payment terms and schedules are negotiable. More information about the Morningstar Funds’ fees and expenses can be found in the prospectus at http://connect.rightprospectus.com/Morningstar. Payment Payments, payment terms and payment schedules are negotiated and governed by the contractual agreement we enter into with each client. For institutional clients, we typically send an invoice on a periodic basis (e.g., monthly or quarterly), although in some instances, we bill annually. Fixed and Model Investment Strategies and Seed Accounts Strategy fees are typically negotiable and range from 0 – 40 basis points. The actual fee depends on our role in offering the service including asset size, the complexity involved, whether Morningstar Funds are included in the ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 5 of 17 We do not have any revenue sharing arrangements with any mutual funds. licensing fees are typically paid in advance of services being provided, and basis-point fees are typically charged in arrears. Third-Party Compensation We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. Other Costs in Connection with Our Advisory Services Our fees are separate from fees and expenses charged by the investment products (including redemption fees or asset- or transaction-based trading fees), fees and expenses charged by the institutional client or platform for their products (including any revenue sharing arrangements that they have with the investment option’s investment adviser and/or distributor), or fees that are charged by a third party, such as a proprietary advisory program, financial advisor, platform, custodian, transfer agent, plan provider, or recordkeeper. Marketing, Distribution, and Educational Support Arrangements We enter into agreements with certain institutional clients whereby we provide compensation to the institutional client in exchange for access to their financial advisers to educate them about our Strategies, having our Strategies listed or highlighted in the marketing materials, attendance or booth space at conferences, and/or similar marketing, distribution, and educational activities. We also provide compensation to institutional client or advisory firms to sponsor financial adviser or retail client meetings and events. are described prospectus Item 6. Performance Based Fees and Side-by-Side Management We do not have performance-based fee arrangements with any qualified client pursuant to Rule 205-3 under the Advisers Act. For funds, the fees and expenses are described in the prospectus or an equivalent document. These fees will generally include a management fee, other investment expenses, and possibly a distribution fee (e.g., 12b-1). In some cases, an investment option may also charge an initial or deferred sales charge. Neither Morningstar Investment Management nor any of our employees receive transaction-based compensation for the investment recommendations we make. The fees and expenses charged by Morningstar Funds at the in http://connect.rightprospectus.com/Morningstar. Exchange-traded funds have their own internal fees and expenses such as investment advisory, administration, and other fund-level expenses; by investing in them, the investor incurs a proportionate share of those fees and expenses. ADRs are typically created, organized and administered by a U.S. bank. Generally, these banks charge a fee for their services (e.g., custody) and typically deduct these fees from the dividends and other distributions generated from the ADR shares. In addition, banks incur expenses, such as converting foreign currency into U.S. dollars, and as a result can choose to pass those expenses on to the ADR shareholder. Item 7. Types of Clients Our clients include advisory programs or platforms of third-party advisory or platform providers, entities such as financial institutions, third-party investment advisers, broker/dealers, investment companies (including the Morningstar Funds Trust), and other business entities, consultants, plan providers, product providers, and sponsors who offer investment advice programs to individual retirement investors in defined contribution plans such as 401(k), 457, and 403(b) retirement plans, individual retirement plan participants, health savings accounts, individuals who are in retirement, and other investors. Please see our Morningstar Retirement Advisory Services for Individuals and Morningstar Retirement Institutional Advisory Services brochures, available on the SEC website, for further information about the advisory services offered through Morningstar Retirement. We do not require a minimum account size for our institutional investment advisory services, and we generally do not impose other conditions for using our institutional advisory services. Fees Charged in Advance Our services can be terminated as outlined in the contractual agreement between Morningstar Investment Management and the client. Termination of services and refunds of fees, if any, are governed by the contractual agreement between the parties, which is negotiated on an individual basis. Upon termination, any earned, unpaid fees by the client are due and payable. If, in accordance with contractual terms, the client terminates their contract prior to the end of the billing period, we will refund any unearned fees on a pro rata basis after the termination of the contract. The minimum funding size for our Strategies is dependent on the selected Strategy and/or the institutional client making the Strategies available. Investors should review their account opening documents to determine the minimum, if there is one, applicable to their Strategy. Compensation from Sales of Securities We do not expect, accept or receive compensation for the sales of securities, including asset-based sales charges or service fees from the sale of open- end mutual funds. investment advisers or Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss Investment Philosophy Our investment philosophy is driven by the investment principles that are promoted throughout our organization. The principles are intended to guide our thinking, behavior and decision making. These principles have been inspired by a number of the most experienced and successful investors in the last century. These principles also reflect and align with the history and foundation of Morningstar. The investment principles are: - We put investors first - We’re independent-minded - We invest for the long term - We’re valuation-driven investors You may have the option to purchase investment products we recommend or similar services through other financial professionals not affiliated with us. Because our services are not exclusive, the fee for our services may be higher than fees charged by other financial firms who provide services similar to ours or if you paid separately for investment advice and other services. In addition, because the underlying holdings of our portfolios are not exclusive to the services described herein, you may buy securities (e.g., mutual funds, exchange-traded funds, equity securities, etc.) outside of this service without incurring our fees. Revenue Sharing Arrangements ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 6 of 17 the market consensus because one needs to be different to be able to outperform. - We take a fundamental approach - We strive to minimize costs - We build portfolios holistically We also look closely at each asset class’s risk, which can be complex, multifaceted, and vary over time. We believe that one of the best ways to control for risk is to buy fundamentally strong assets that seem underpriced. Building upon our investment principles, our investment philosophy is built on the belief that portfolios should maintain a risk profile commensurate with the desired long-term asset allocation guidelines we provide to the client. We focus extensively on the portfolio structure to maintain a careful balance between being allocated similarly to the portfolio benchmarks and one that reflects our assessment of the value available in the current market environment. We select managers that we believe manage fund assets with a consistent and disciplined process that can provide for sustainable long- term results. We prefer managers with a prudent, logical, and repeatable process and remain keenly focused on the consistency of the implementation of their investment disciplines. Our in-depth valuation analysis and contrarian indicators, when brought together, are the key ways we generate investment ideas. These ideas might be names to include in a stock portfolio or our best thinking on reward for risk at the asset class-level. In addition, our valuation-driven asset allocation process paired with our in-house investment selection skill allows us to holistically build portfolios for our clients for the long term. The Investment Management group, as a global team, works to understand markets and opportunities, monitor risk in existing portfolios, and vet ideas to make investment changes. We use this ongoing investment process to manage a variety of equity and multi-asset portfolios for our Institutional Clients. To align with our business structure, we have two Investment Policy Committees. The investment advice used in the products and services referenced in this brochure from Morningstar Investment Management is provided by investment teams. Information on key members of these investment teams is included in our Form ADV Part 2B Brochure Supplement for Morningstar Wealth Advisory Services. Investment Selection Finding investment opportunities isn’t just about great ideas; it’s also about selecting great investments for our clients. Investments may be individual stocks, or active managers and/or passive exchange-traded products in a multi-asset portfolio. Our research-driven approach to selecting investments is designed to help investors reach their goals and objectives. When building multi-asset portfolios, we need to evaluate the active investment managers and/or passive funds we use to implement our investment strategies. Our investment selection process begins with analysis from Morningstar and its affiliates, which covers hundreds of thousands of investment offerings globally, including mutual funds, closed-end funds, separate accounts, exchange-traded products, individual stocks, and hedge funds. We then build upon that analysis with reviews by our internal investment team, which includes not only quantitative screens and assessments, but also one-on-one conversations with portfolio managers as part of our fundamental due diligence. for different In our due diligence, we assess whether their investment team is qualified, experienced, and talented; that they follow a consistent and disciplined investment process; that their organization is strong and stable; and that they operate professionally and ethically. Global Investment Committee Morningstar Wealth’s Global Investment Committee and its regional governance bodies, in addition to the Americas Investment Product Committee, are responsible for oversight of the investment methodologies across some of our Institutional Asset Management, Model Investment Strategies and Seed Accounts, Select Lists, and Asset Allocation Services. Members of the Global Investment Committee may include officers, chief investment officers, managing directors, or managers of Morningstar Investment Management or its affiliates. The regional governance bodies meet quarterly to review guideline changes and performance across portfolios. Formal and informal global best practice working groups also exist with the goal of sharing methodologies and research across regions. These groups focus on specific investment areas such as valuation models driven by our capital markets research and methodologies used for asset allocation, investment selection, portfolio construction investment strategies and advice. In addition to governance bodies, the investment team has regional research and portfolio construction workflows that surface best thinking across investment opportunities and guide portfolio construction. We study managers’ holdings using our proprietary tools and analytics to assess how well their strategy may work in combination with those of other managers. And we consider managers’ ability to outperform in different market environments. Rather than following simple style analytics or style neutrality blends, we seek process diversification and try to avoid the pitfalls of over-diversification often found in fund-of-fund investment strategies. Once we have selected active managers, we tend to keep them in place for the long haul. We believe hiring independent managers to run high-conviction strategies is a far better approach to multimanager portfolios. Institutional Asset Management, Model Investment Strategies, Seed Accounts, and Asset Allocation Services Investment Process Our investment process starts with scouring the globe for opportunities. Instead of hewing closely to an index-defined universe, we look broadly, investigating asset classes, sub-asset classes, sectors, and securities in markets around the world. Our capital markets research extends to more than 200 equity and 150 fixed-income asset classes. We also track around 30 world currencies. We apply deep valuation analysis supported by in-depth fundamental research to find opportunities around the globe. Alongside this analysis, which looks at both absolute and relative valuation, we also consider investor sentiment and positioning, which adds contrarian elements to our process and tells us how the market consensus views an investment idea we’re considering. We prefer to invest in ideas contrary to As for passive vehicles, our selection process begins with the thousands of exchange-traded products in the Morningstar database and includes the work of Morningstar and its affiliates’ ETF analyst team. Our own analysts perform qualitative work that can’t be found in an automated service. ETFs are often less expensive than their open-end mutual fund counterparts but assessing them has to go beyond this fact. We closely examine the risk characteristics that define ETFs—including tracking to the index, trading volume, bid/ask spread, and premium/discount—to help ensure the goals are realistic and the ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 7 of 17 liquidity is what we expect. As with other funds, we assess ETFs within a portfolio context to achieve access to a particular market segment or sub- asset class. Individual stock selection relies heavily on our asset class research to identify attractive segments of the market (sectors, countries, or factors like quality) and a review of the valuations and fundamentals of the underlying stocks. We rely heavily upon Morningstar’s Equity Research group in addition to our own proprietary insights. Managing Portfolios Once we’ve holistically built portfolios, we manage them. This part of the process is simply continuing to find opportunities, thinking through ways those opportunities might be included in our portfolios, and watching markets closely for any signs that would call for adjustments within the portfolio. Portfolio management is not a stop/start process. We constantly review our positions, seeking to maximize reward for risk. Each strategy we manage has a set of investment guidelines that outline the investment objectives, risk levels, and investment constraints. These are monitored to stay within the defined ranges. As valuation-driven investors, we primarily focus on price changes relative to fair value through time. Given that markets are dynamic, we reassess the portfolio given the changes in investment ideas, aggregate risks, and portfolio exposures. This iterative process reconsiders the opportunity set, with a constant eye on fundamental diversification and portfolio allocations. Specific to our Institutional Asset Management and Asset Allocation Model Portfolio services, the portfolios we build for an Institutional Client are typically constrained to a universe of investment options defined by our client, which include their affiliated investment products in some instances. Our analysis will still include quantitative analytics and fundamental research on the investment options available. We draw on Morningstar’s comprehensive database of fund and security analytics as well as utilizing portfolios information provided by our Institutional Client, if applicable. In some instances, we work closely with our Institutional Client to identify and evaluate manager candidates for possible addition to or removal from the available investment universe. Turnover and trading reduce returns for investors and therefore any changes should be expected to add value by a comfortable margin. Investment decisions happen in the real world rather than on paper—transaction costs and taxes are real. This means being biased toward inaction and long-term holdings, keeping turnover and transaction costs as low as possible. Our global investment team works around the clock to understand markets and opportunities, monitor risk in existing portfolios, and vet ideas to make investment changes. This ongoing investment process powers every portfolio managed by the entities within Morningstar’s Investment Management group. Building Portfolios Armed with investment ideas, our global team works together to holistically build portfolios suited to each strategy we offer or the objectives of our clients. Portfolio construction is about ranking and risk management. We seek to gain the largest exposure to our best ideas, while building robust portfolios designed to stand up to challenging investment environments or investment errors. This judgment-driven approach also allows us to evaluate the complexity and multifaceted nature of investment risk. We view risk as the permanent loss of capital. Our valuation-based approach (that is, seeking underpriced assets and avoiding overpriced assets), fundamental diversification, and forward- looking approach to viewing asset class co-movements (that is, those that buffer gains and losses), all help mitigate risk in the portfolios we build. We have processes and risk controls in place at multiple levels of the investment process to ensure that our portfolios are created in a manner consistent with their risk and return objectives. We evaluate risk at both the asset class model level and the portfolio level. At the asset class level, we monitor easily observable metrics such as standard deviation, skew, kurtosis, historical beta and overall tracking error relative to our stated benchmark. Our standard deviation and covariance matrix figures are estimated by a proprietary factor analysis system that ensures consistency across multiple asset classes and time periods. We delve deeper by examining conditional value-at-risk and conducting scenario analysis testing under different market conditions. To prepare investors for the future, we seek to construct robust portfolios designed to perform well in different environments rather than being considered “optimal” based on expected results or a specific environment. We avoid forecasts and building strategies based on our ability to predict specific environments. Instead, we aim to prepare for different environments through constructing portfolios that will hold up under many possible environments—even ones that we haven’t seen before. In effect, this involves trade-offs of aggregate reward for risk and a calibration of the probability and impact of negative outcomes. At the portfolio level, we conduct a detailed style analysis of our underlying funds using holdings information, quantitative regressions, and manager meetings. The underlying styles allow us to determine the effective rolled up portfolio asset class exposures and compare them to our asset allocation targets. Further, we analyze each manager’s style consistency to make sure we monitor and adjust for huge swings in our effective asset class exposures. This analysis ensures that we are aware of, and comfortable with, our effective asset class exposures. Additional analysis is done routinely to measure our fund portfolio duration, tracking error, sector exposures and betas. While actively managed portfolios will exhibit certain biases in terms of asset class weightings or security characteristics relative to their blended benchmarks at times (based our intended investment decisions and the actions of the underlying managers), they are constrained by setting minimum and maximum allocations to different asset classes, as stated in our investment policy guidelines. Establishing allowable ranges for asset classes helps enable the strategy to take advantage of opportunities and avoid risks Asset allocation guidelines for multi-asset portfolios are developed by our Asset Allocation Committee, which comprises most of the investment professionals in Morningstar’s Investment Management group. Our investment professionals serve in different asset-class specialties on the committee. The committee jointly decides on organization-wide portfolio positioning policy, and strategy teams and portfolio managers adapt the positioning decision, as applicable, to their particular strategies and client portfolios. Teams of our portfolio managers are supported by the broad array of investment professionals within the Investment Management group, who contribute to manager research, asset-class research, investment-process enhancement, and the development and maintenance of portfolio management tools used in providing this service. All portfolios are reviewed by a team of peers before we deliver them to our Institutional Client. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 8 of 17 Harris Associates L.P. at the asset class level, but also keeps the portfolios tethered to their blended benchmarks. Lazard Asset Management LLC T. Rowe Price Associates, Inc. Morningstar International Equity Fund Morningstar International Equity Fund Morningstar International Equity Fund Morningstar Global Income Fund Morningstar Global Income Fund Ongoing monitoring of the underlying position weights is critical to keeping the portfolio exposures as intended. Each fund is assigned a target position and a “deviation threshold,” which governs the degree to which a fund may sway from its target. Each fund has a different degree of latitude, based on both its weight in the portfolio and the volatility of the assets in which it typically invests. If a fund deviates from its target weight, we evaluate whether the accounts that contain the fund need to be adjusted (i.e., rebalanced) to bring the alignment back in order. Cullen Capital Management, LLC Western Asset Management Company, LLC BlackRock Financial Management, Inc. Allspring Global Investments, LLC T. Rowe Price Associates, Inc. First Pacific Advisors, LP Loomis, Sayles & Company, L.P. For registered or collective investment products we manage on behalf of an Institutional Client, we review and revise portfolio allocation targets on a continuous basis to ensure that asset class targets outlined in the prospectus are maintained. Reviews are implemented to ensure that the underlying investments in the portfolio don’t exceed allocations noted in the product’s prospectus or breach other restrictions. TCW Investment Management Company LLC Voya Investment Management Company, LLC Lazard Asset Management LLC Morningstar Funds Trust Valuation The Morningstar Funds Trust’s Board of Directors has oversight responsibility for the Morningstar Funds Trust’ portfolio valuation and pricing practices but has the discretion to delegate authority to the adviser or sub-adviser of the funds. Fair valuation matters are also addressed within the Morningstar Funds Trust’s valuation policies and procedures. Morningstar Total Return Bond Fund Morningstar Municipal Bond Fund Morningstar Municipal Bond Fund Morningstar Defensive Bond Fund Morningstar Multisector Bond Fund Morningstar Multisector Bond Fund Morningstar Multisector Bond Fund Morningstar Global Opportunistic Equity Fund Morningstar Alternatives Fund Morningstar Alternatives Fund Morningstar Alternatives Fund SSI Investment Management LLC Water Island Capital, LLC BlackRock Financial Management, Inc. Morningstar Funds Trust Subadvisor Oversight and Multi-Style Management We are responsible for hiring, terminating, and replacing sub-advisers to the Morningstar Funds, subject to board approval. Before hiring a sub-adviser, we perform due diligence on them including, but not limited to, quantitative and qualitative analysis of their investment process, risk management, and historical performance. We are responsible for the general supervision of the sub-advisers as well as allocating each Morningstar Fund’s assets among the sub-advisers and rebalancing the portfolio as necessary, the timing and degree of which will be determined by us. At times, allocation adjustments among sub-advisers may be considered tactical with over- or under-allocations to certain sub-advisers based on our assessment of the risk and return potential of each sub-adviser’s strategy. Sub-adviser allocations are also influenced by each sub-adviser’s historical returns and volatility, which are assessed by examining the performance of strategies managed by the sub-advisers in other accounts that we believe to be similar to those that will be used for a Morningstar Fund. Sub-advisers have discretionary authority to determine, subject to each portfolio’s investment policies and restrictions, the securities in which the portfolios advised by them will invest, which may include domestic and foreign equity securities, warrants, derivatives, delayed settlement securities, commercial paper, certificates of deposit, investment company securities, United States government securities, and options, futures, and forward contracts. The sub-advisers employ proprietary methods of securities analysis in making investment decisions for the portfolios and may rely upon a variety of sources for information, including internally generated research. In making investments on behalf of the portfolios, the sub-advisers may employ investment strategies and techniques which include long and short-term purchases, short-term trading, short sales, derivatives, and options writing. Potential investors in the Morningstar Funds Trust should carefully read the prospectus, statement of additional information and/or portfolio’s offering documents for additional information on each portfolio’s investment objectives, risks and restrictions. We have retained the following investment advisers to act as a sub-adviser for the listed Morningstar Fund Trust fund pursuant to a sub-advisory agreement: Sub-adviser Portfolio Sub-advised Morningstar U.S. Equity Fund Morningstar U.S. Equity Fund Asset Allocation Services – Capital Market Assumptions and Risk Tolerance Questionnaires As part of our Asset Allocation Services, we typically offer a combination of Asset Class Model Portfolio(s), Risk Tolerance Questionnaire(s) (“RTQ”), and our Capital Market Assumptions (“CMAs”). Our construction method for Asset Class Model Portfolios is described above. This section will focus on our CMA and RTQ methods. Morningstar U.S. Equity Fund Morningstar U.S. Equity Fund ClearBridge Investments, LLC Diamond Hill Capital Management, Inc. Massachusetts Financial Services Company, d/b/a MFS Investment Management Wasatch Advisors, LP d/b/a Wasatch Global Investors Westwood Management Corp. Harding Loevner LP Capital Market Assumptions We provide forward-looking CMAs for both taxable and tax-deferred account types. Our CMAs consist of expected return, standard deviation and correlation among asset classes based on our proprietary equity, fixed income, currency and risk models. In our CMAs, we use valuation-implied returns, which are based on the idea that asset class returns can be decomposed into underlying corporate and economic fundamentals and the Morningstar U.S. Equity Fund Morningstar International Equity Fund ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 9 of 17 valuations impact near-term returns. Our research team develops and enhances our capital market models on an ongoing basis to reflect the latest best practices and innovations. We analyze the available opportunity set of asset classes and constructs long-term expected returns, standard deviations, and correlation coefficients for each. For equity valuation-implied returns, we use a supply-side approach to forecast equity returns. The supply-side model is based on the idea that equity returns can be decomposed into underlying economic and corporate fundamentals. Our approach separates the expected return of each equity asset class into four key return drivers: 1) Inflation: Our long-term inflation expectations are based on several consensus and professional long-term inflation forecasts, as well as central banks’ medium- to long-term inflation targets where inflation targeting is part of the monetary policy mandate. currency return. The currency valuation-implied return has two main components: 1) the inflation differential between the local currency and the reference currency, and 2) the reversion of real exchange rate to its fair value. The inflation differential is the difference between the expected inflation rate of the local and reference currencies, where the inflation forecast is based on the same methodology as the one discussed in the equity section above. In the very long run (i.e., at the unconditional horizon), we expect the inflation differential to be the sole driver of changes in the spot rate. The change in the real exchange rate is estimated based on multiple deflators (including CPI and PPI) to account for potential differences in the importance of the tradable versus non-tradable sector in a given economy. These price-based measures of real exchange rates are adjusted for differences in export quality and productivity differentials, accounting for potential differences in the value of goods not reflected in the price indexes. The expected change in the real exchange rate is generally based on the assumption that the real exchange rate will revert to a long-run average. 2) Total Yield: We base our estimates of future total yield on an analysis of the historical payout rates and total payout yields for a given asset class. We estimate total yield for each equity asset class at both the country and sector level. 3) Growth: The growth term measures the change in corporate cash flows per share excluding the impact of repurchases. Our long-run growth expectations are based on expected growth of the asset class based on underlying fundamentals. 4) Change in Valuation: We use several valuation models to estimate the fair value of equity asset classes and assumes reversion to fair value over a 10-year period. Specifically, our valuation models rely on several forward-looking measures of normalized earnings such as profit margin, return on book-equity, and inflation-adjusted average earnings over the business cycle. Risk Tolerance Questionnaire A risk tolerance questionnaire is a tool designed to measure an investor’s self- reported perceptions of their general willingness and ability to withstand the volatility inherent in investing in capital markets. Our measure is based on three self-reported factors: (1) time horizon, (2) feelings about the trade-offs between expected returns and expected volatility, and (3) beliefs about the investor’s anticipated emotional reactions to changes in their portfolio’s value, in particular drawdowns. Using a unit weighted sum of the responses to the questions within this questionnaire, two overall scores are generated. The first is a score in regard to the investor’s time horizon, which serves as a proxy for the investor’s ability or capacity to take on risk. The second score reflects an investor’s overall risk preferences. These two scores can be used independently, and/or they can be systematically mapped to a spectrum of risk tolerance profiles ranging from conservative to aggressive. The spectrum of risk tolerance profiles and scores can be represented as distinct profiles, such as Very Conservative, Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Very Aggressive. For fixed-income valuation-implied returns, we use a building-block approach to forecast returns of fixed-income asset classes. The key inputs into our fixed-income model are: 1) Inflation: The inflation forecast is the same as the one used in our equity model. 2) Real Rate: The real rate of return is the expected return of cash after inflation. We forecast real rates based on an examination of long-run historical real-rate data and consideration of the macroeconomic environment for each fixed-income asset class. 3) Ultimately, the investor and/or their financial professional has the final decision in determining the investor’s portfolio, which may differ from the risk tolerance profile or scores and be based on additional information not captured by the risk tolerance questionnaire. Our risk tolerance questionnaire is a measurement tool for helping a financial professional discover information about the investor’s time horizon, risk and return preferences, and their anticipated responses to volatility. This information can—and should—help initiate and facilitate conversations that assist the financial professional in gaining a broader understanding of the investor’s financial situation, including additional information about an investor’s assets, anticipated cash-flows, needs, goals, and other relevant information. Based on this more complete understanding of the investor, financial professional should be able to develop a suitable investment strategy. Risk tolerance questionnaire scores alone should not be the predominant indicator used to match an investor to a portfolio or investment products. Term Spread: We base our forecast of the term spread on the long-run shape of the yield curve, current market data, and surveys. The expected shape of the yield curve also determines our forecast of the roll return of a fixed-income asset class. 4) Credit Spread: We forecast default and recovery rates across credit ratings and industries. Our model takes into account the impact of rating upgrades and downgrades (credit migration) on credit bond prices. Although the risk tolerance questionnaire scoring process is objective, subjectivity cannot be completely eliminated when using such measurement tools. For example, some investors may struggle to understand the questions or may not have clearly defined risk preferences. There is no guarantee that this risk tolerance assessment tool or its scoring method perfectly assesses a person’s tolerance to risk or attitudes about gains and losses. In addition, although the financial professional may have directly or indirectly used the results of a risk tolerance questionnaire to inform a suggested asset For currency valuation-implied returns, the currency return is our forecast of the change in the spot exchange rate. In general, for any asset not denominated in the reference currency, the valuation-implied return of the asset is based on the expected return in local currency plus the expected ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 10 of 17 allocation, there is no guarantee that the resulting asset mix appropriately reflects an investor’s ability to withstand investment risk. periods. We favor managers that have added value over an appropriate benchmark or peer group in a consistent manager. Price – Research indicates that expenses are one of the most important factors in predicting mutual fund performance. While a lower expense ratio is always better, we put expenses into the proper context and consider factors such as the size of the fund, trend in expenses, and investment strategy. Our access to fund managers allows us to conduct constant research, and meetings with those managers are an important part of our process. This deepens our understanding of the processes these managers use and gives us valuable perspective on the state of the economy and capital markets. Select Lists For our Select List service, our analysis is typically constrained to a universe of investment options defined by our institutional client, which may include their affiliated investment products. Our analysis will still include quantitative analytics and fundamental research on the investment options available. We draw on Morningstar’s comprehensive database of fund and security analytics as well as utilizing portfolio information provided by our institutional client, if applicable. Select Lists are fully customized around a firm’s asset allocation, portfolio construction, and investment objective needs. We work with our institutional client to determine the universe of investment options from which we are to choose from, the asset classes to be addressed, the number of investment selections per asset class, the intended users of the list, and the intended account type (e.g., taxable or tax-deferred). We typically update select lists quarterly, or on another basis as defined by our client. After creating a new Select List, we will conduct monitoring, typically on a quarterly basis, following the same process used for the initial selection. We also maintain a watch list, which includes investment options that have undergone changes we believe may negatively affect its long-term prospects. The intent of the watch process is to ensure that the investments initially selected continue to satisfy the criteria that led to their initial selection. Generally, an investment option’s watch period is two to four quarters, at which point, we will make a recommendation to remove the option from the Select List or take it off watch. In addition, if any investments experience significant change prior to the quarterly update, such as a manager change, we will notify the client as the case arises. To build the select list, we employ a disciplined process incorporating quantitative screens (e.g., manager tenure, portfolio exposure, and risk and return characteristics) to the available investment universe to narrow the list. Investment options passing those initial quantitative screens are then subject to a qualitative analysis. During that analysis, we are assessing each security on its own merits. During the qualitative analysis phases, we are also assessing how the investment options compares to others in its asset class as well among all the asset classes, paying attention to diversification of investment approach within each asset class and overall. The investment selection process is guided by a proprietary due diligence process, which combines quantitative analysis with qualitative assessment of an investment’s management team and investment process. The assessment we make represents our overall level of conviction in an investment based on various factors that we believe are important in determining which investments have the best chance of delivering above- average risk-adjusted performance in the future. These factors include the following: Risk of Loss and Strategy Risk Investments in securities are subject to market risk, risk of loss, and other risks and will not always be profitable. There is no assurance or guarantee that the intended investment objectives of our recommendations will be received. We do not represent or guarantee that our investment recommendations can or will predict future results, will successfully identify market highs or lows, or will result in a profit or protect clients from loss. Past performance of a security may or may not be sustained in the future and is no indication of future performance. A security’s investment return and an investor’s principal value will fluctuate so that, when redeemed, an investor’s shares may be worth more or less than their original cost. We are unable to predict or forecast market fluctuations or other uncertainties that may affect the value of any investment. Process – We strive to identify managers who employ a disciplined and prudent investment process that has been executed in a consistent fashion. We favor attributes such as insightful security analysis, a robust valuation discipline, and sound risk management and portfolio construction. Asset allocation and diversification are investment strategies which spread assets across various investment types for long-term investing. However, as with all investment strategies, these strategies do not ensure a profit and do not guarantee against losses. Capital market assumptions are forecasts which involve known and unknown risks, uncertainties, and other factors which may cause the actual results to differ materially and/or substantially from any future results, performance, or achievements expressed or implied by those projections for any reason. Past performance does not guarantee future results. Parent – The culture and structure of a firm can have a significant impact on its ability to attract and retain talent and its penchant for serving in the best interests of shareholders. We look at ownership structure of the firm, its organizational stability and financial strength. We also place considerable emphasis on stewardship by favoring investments where the firm has shown a tendency to act in the best interests of shareholders and where the portfolio managers eat their own cooking, so to speak, and have their incentives aligned with shareholders. Our recommendations are made without taking into consideration potential tax consequences and we do not provide tax advice. Potential tax consequences may exist. We encourage you to consult with a tax professional about these and other tax consequences. People – We judge the depth and capabilities of members of the investment team and the stability of the organization. We look beyond the lead portfolio manager to assess the quality of research analysts. Performance – We strive to identify investments that have shown the ability to deliver solid risk-adjusted performance over time. We evaluate performance from several angles and over various time The Morningstar Funds Trust principal risks include multimanager and sub- adviser selection risk, active management risk, asset allocation risk, market risk, investment company/ETF risk, REITS and other real estate companies risk, master limited partnership risk, smaller company risk, sector focus risk, foreign security risk, currency risk, derivative risk, quantitative models risk, ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 11 of 17 the risk of adverse political, economic and social developments taking place within the underlying issuer’s home country. In addition, the underlying issuers of certain ADRs are under no obligation to distribute shareholder communications to ADR holders, or to pass through to them any voting rights with respect to the deposited securities. cybersecurity risk, European market risk, Asian market risk, China market risk, Japan market risk, emerging-markets risk, geographic concentration risk, cash/cash equivalents risk, private placements risk, interest-rate risk, call risk, credit risk, high-yield risk, convertible securities risk, preferred stock risk, contingent capital securities risk, US government securities risk, sovereign debt securities risk, mortgage-related and other asset-backed securities risk, floating-rate notes risk, loan risk, CDO risk, reverse repurchase agreement risk, dollar rolls risk, portfolio turnover risk, municipal securities risk, municipal focus risk, Latin America issuer risk, absolute return risk strategy, long/short strategy risk, short sales risk, supranational entities risk, indexed and inverse securities risk, and merger arbitrage risk. More information about the Morningstar Funds Trust’s risks can be found in the prospectus at http://connect.rightprospectus.com/Morningstar. Exchange-Traded Funds Portfolios may be invested in exchange-traded funds whose investment objective is to track that sector. ETFs are traded on national exchanges and therefore are subject to similar investment risks as common stocks. ETFs, like all investments, carry certain risks that may adversely affect their net asset value, market price, and/or performance. An ETF’s net asset value (NAV) will fluctuate in response to market activity. Because ETFs are traded throughout the day and the price is determined by market forces, the market price you pay for an ETF may be more or less than the net asset value. Because ETFs are not actively managed, their value may be affected by a general decline in the U.S. market segments relating to their underlying indexes. Similarly, an imperfect match between an ETF’s holdings and those of its underlying index may cause its performance to not match the performance of its underlying index. Like other concentrated investments, an ETF with concentrated holdings may be more vulnerable to specific economic, political, or regulatory events than an ETF that mirrors the general U.S. market. investment managers are combined with Information Sources Our global resources used in the formulation of our advisory services go down to our roots—the data and analysis from Morningstar that form the base of our investment process. This expansive, in-house network of global data and investment analysis spans asset classes and regions to help drive timely new ideas. Morningstar or its affiliates have more than 800 analysts and make data available on more than 600,000 investment options and 5.2 million privately-held companies. The extensive data, analysis, and methodologies from these resources, along with external research reports, data, and interviews with financial publications, annual reports, prospectuses, press releases, and SEC filings to serve as the basis of our primary sources of information. For some of our services, we combine this information with other factors— including actuarial data, stock market exposure, probability analysis, and mean-variance optimization—into a proprietary software program to analyze a complex set of market data and variables that results in an advanced model that can provide investment recommendations and a projection of different outcomes. Money Market Funds A money market fund may impose a fee upon the sale of shares or may temporarily suspend your ability to sell shares if the fund’s liquidity falls below a required minimum because of market conditions or other factors. An investment in a money-market vehicle is not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. For most money market funds, their sponsor has no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to the fund at any time. Although some money market funds seek to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. It is possible to lose money by investing in money market funds. Mutual Funds and Collective Investment Trusts Investments in mutual funds and collective investment trust (CITs) funds involve risk, including loss of principal as a result of changing market and economic conditions and will not always be profitable. Security Type Risks Commons Stocks Certain Portfolios are invested primarily in common stocks listed on U.S. stock exchanges, which are a type of equity security that represents an ownership interest in a corporation. Please be aware that common stocks are typically subject to greater fluctuations in market value than other asset classes as a result of such factors as a company’s business performance, investor perceptions, stock market trends and general economic conditions. Stocks of small-cap and mid-cap companies tend to be more volatile and less liquid than stocks of large companies. Small-cap and mid-cap companies, as compared to larger companies, may have a shorter history of operations, may not have as great an ability to raise additional capital, may have a less diversified product line making them susceptible to market pressure, and may have a smaller public market for their shares. A collective investment trust may also be called a commingled or collective fund. CITs are tax-exempt, pooled investment vehicles maintained by a bank or trust company exclusively for qualified plans, including 401(k)s, and certain types of government plans. CITs are unregistered investment vehicles subject to banking regulations of the Office of the Comptroller of the Currency (OCC), which means they are typically less expensive than other investment options due to lower marketing, overhead, and compliance-related costs. CITs are not available to the general public but are managed only for specific retirement plans. risk, mortgage risk, diversification Real Estate Investment Trusts Publicly-traded Real Estate Investment Trusts (REITs) may be included in certain Portfolios. REITs are traded like common stocks and invest in real estate either through properties or mortgages. REITs are focused securities and may exhibit higher volatility than securities with broader investment objectives. Principal risks associated with REITs include market risk, issuer risk, economic risk, and rate sector/concentration risk. ADRs and Foreign Stocks Certain Portfolios are invested in ADRs or foreign stocks listed on an U.S. exchange. An ADR is typically created by a U.S. bank and allows U.S. investors to have a position in the foreign company in the form of an ADR. Each ADR represents one or more shares of a foreign stock or a fraction of a share (often referred as the ‘ratio’). The certificate, transfer, and settlement practices for ADRs are identical to those for U.S. securities. Generally, the price of the ADR corresponds to the price of the foreign stock in its home market, adjusted for the ratio of ADRs to foreign company shares. There are investment risks associated with ADRs and foreign stocks including, but not limited to, currency exchange-rate, inflationary, and liquidity risks as well as ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 12 of 17 performance of a select Strategy or Strategies, all investment decisions made within a Strategy by an individual portfolio manager must be peer reviewed by the broader regional team of portfolio managers. In addition, the Regional Investment Committee reviews strategy performance on a quarterly basis. Exchange-traded Funds ETFs, like all investments, carry certain risks that may adversely affect their net asset value, market price, and/or performance. An ETF’s net asset value (NAV) will fluctuate in response to market activity. Because ETFs are traded throughout the day and the price is determined by market forces, the market price you pay for an ETF may be more or less than the NAV. Because ETFs are not actively managed, their value may be affected by a general decline in the U.S. market segments relating to their underlying indexes. Similarly, an imperfect match between an ETF’s holdings and those of its underlying index may cause its performance to not match the performance of its underlying index. Like other concentrated investments, an ETF with concentrated holdings may be more vulnerable to specific economic, political, or regulatory events than an ETF that mirrors the general U.S. market. For many of our institutional advisory services, the universe of investment options from which we make our investment selections is defined by our client. In some cases, this universe of investment options includes proprietary investment options of that client. To mitigate any actual or potential conflict of interests presented by this situation, we subject all investment options to the same quantitative and qualitative investment selection methodology, based on several factors, including performance, risk, and expense so that the proprietary nature of an investment option does not influence our selection. Target-Date Funds An investment in a target date fund is not guaranteed, and investors may experience losses, including losses near, at, or after the target date. There is no guarantee that a target-date fund will provide adequate income at and through an individual’s retirement. We may provide consulting or investment management services to institutional clients that offer registered or pooled investment products, such as mutual funds, variable annuities, collective investment trusts, or model portfolios. To mitigate the conflict of interest presented by our role in these investment products, we exclude such investment products from the universe of investment options from which we make our recommendations to other clients. Methodology Updates Our CMA, asset allocation, and investment committees typically meet on a periodic basis. These committees have oversight for their respective areas of expertise. If any of these committees makes an adjustment, the changes are thoroughly reviewed and tested before being implemented. These changes are manifested in retirement investor portfolios through expected future returns, and asset allocations. CMAs are updated on an annual basis. We also update our methodologies with updated tax limits on an annual basis. Asset allocation and advice methodologies are updated only when there is a regulatory change that requires an update or when research we have completed warrants enhancing our asset allocation process or advice methodology. We receive compensation for our research and analysis activities (e.g., research papers) from a variety of financial institutions including large banks, brokerage firms, insurance companies, and mutual fund companies. In order to mitigate any actual or potential conflicts of interest that may arise from this service, we ensure that our research and analytical activities are non- biased and objective given our business relationships. Employees who provide research and analysis for clients are separate from our sales and relationship manager staff in order to mitigate the conflict of interest that an employee may feel pressure to present results in such a way as to maintain existing or gain new business. In addition, as noted above, all investment decisions for Morningstar Wealth’s Strategies must be peer reviewed by fellow portfolio managers, which mitigates the conflict of interest by providing checks and balances so that no employee can act unilaterally in making recommendation decisions. Item 9. Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would influence a potential client to engage us. We do not have any material legal or disciplinary events to disclose. Morningstar Investment Management is registered as a Commodity Pool Operator with the Commodity Futures Trading Commission. Some of Morningstar Investment Management’s employees are registered with the National Futures Association as principals or associated persons. Item 10. Other Financial Industry Activities and Affiliations Morningstar Investment Management is a wholly owned subsidiary of Morningstar. Our offerings center on advisory services in our core capabilities of asset allocation, investment selection, and portfolio construction that we offer to individual investors and institutions (including the services described in this brochure.) Our portfolio managers and their team members who are responsible for the day-to-day management of our strategies are paid a base salary plus a discretionary bonus. The bonus is fully or partially determined by a combination of the employee’s business unit’s overall revenue and profitability, Morningstar’s overall annual revenue and profitability, and the individual’s contribution to the business unit. For most portfolio managers and their team members that work on Morningstar Wealth’s Strategies, part of their bonus is also based on select Strategy investment performance and risk metrics versus both a corresponding benchmark over specified three-, five-, and/or seven-year periods and appropriate peer groups. Benchmarks are used as a measure of investment performance and are chosen by senior personnel and approved by the Regional Investment Committee, which is chaired by the regional Chief Investment Officer. To mitigate the conflict of interest that could arise from partially basing an employee’s bonus on Our investment professionals provide portfolio construction and ongoing monitoring and maintenance for the Morningstar Wealth Strategies within the Morningstar Wealth Platform offered by our subsidiary, Morningstar Investment Services, and to third-party financial institutions on Morningstar Investment Services’ behalf. We maintain seed accounts for our Morningstar Wealth Strategies in order to provide an indication of each Strategy’s performance. While the same or similar Strategies are offered by us to our institutional clients, we do not believe this creates any material conflicts of interest for our clients. In order to mitigate any perceived conflict of interest, transactions for our seed and Morningstar-affiliated accounts are placed at the same time Strategy rebalance or reallocation instructions are provided to institutional clients that license our Strategies. Our institutional clients receive rebalance or reallocation instructions just after trades are placed for discretionary clients, due to our heightened fiduciary responsibilities to our discretionary clients. In addition, all non-discretionary clients are notified of transaction recommendations after the close of the trading day, so that no one such client has an advantage over another. (We anticipate the cessation ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 13 of 17 of our subsidiary’s discretionary advisory services by the end of the second quarter of 2025. We will become the investment adviser to many of Morningstar Investment Services’ third-party financial institution clients. When this occurs, trade recommendations will be communicated to non- discretionary clients after the close of the trading day and seed and Morningstar-affiliated accounts in the Strategies will be traded the next day so that no one person has an advantage over another.) investment research reports and investment consulting services to financial institutions/institutional investors who themselves are registered with and governed by a regulatory body. Conflicts of interests between us and Morningstar Research Services are mitigated by such things as the maintenance of separate legal entities and dual reporting/organization lines, and the utilization of physical (i.e., separate office “neighborhoods”) and technological separation. Morningstar Research Services also maintains a committee structure so as to limit any unilateral decisions. Morningstar’s compliance department monitors the personal trading activities of Morningstar Research Services’ employees. We invested in the Series D funding round of SMArtX Advisory Solutions, a managed account technology provider and architect of the SMArtX turnkey asset management platform. This investment will assist in the build out of SMArtX’s development capabilities, which could benefit us or our parent company. Daniel Needham, our co-president serves on the board of SMArtX. When we, along with Morningstar and/or our other affiliates offer services to the same client, we have the option to enter into a bundled agreement with the client that encompasses all or part of those services. Additional fee(s) for such product(s) or service(s), if required, will be set forth in our agreement with the client. In these situations, clients pay a fee directly to us and each such affiliate for its products or services or as part of a joint fee schedule which encompasses all services. investors In some situations, we engage Morningstar Research Services to perform investment manager due diligence and/or selection services on our behalf as a sub-adviser or consultant. The notification to and authorization by the institutional client to our engaging Morningstar Research Services as a sub- adviser is addressed in our agreement with the institutional client. On such occasions, we compensate Morningstar Research Services for services rendered via an intercompany charge. The services and compensation will be governed by an intercompany agreement. This compensation will likely be financial than compensation negotiated with non-affiliated lower institutions/institutional for the same or similar services. Morningstar Research Services’ employees who are engaged to provide manager due diligence and/or selection services are prohibited from using non-public/confidential information obtained because of their engagement in its investment research reports and/or investment consulting services to clients, including us. Morningstar Research Services provides information to the public about various securities, including managed investments like open-end mutual funds and ETFs, which include written analyses of these investment products in some instances. Although we use certain products, services, or databases that contain this information, we do not participate in or have any input in the written analyses that Morningstar Research Services produces. While we consider the analyses of Morningstar Research Services, our investment recommendations are based on our decisions in regard to the investment product. Affiliations – Registered Entities Morningstar has various subsidiaries across the globe that are each registered with the applicable regulatory body or bodies in that country to provide investment management or other advisory services. As described earlier in this brochure, we share resources with these various subsidiaries. One subsidiary, Morningstar Investment Services LLC, is our subsidiary and is also an investment adviser registered under the Advisers Act. Morningstar Investment Services is additionally registered with the Securities and Exchange Commissions as a broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA). Morningstar Investment Services offers model investment strategies through its role as the sponsor of an investment advisory program known as the Wealth Platform and through third-party financial institutions, plan sponsor services, and retirement plan services for institutional and retail clients. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025.) In some cases, our senior management members have management responsibilities to these other affiliated entities. We do not believe that these management responsibilities create any material conflicts of interests for our clients. Morningstar Research Services may issue investment research reports on securities we hold in our portfolios or recommend to our clients, but they do not share any yet-to-be published views and analysis and/or changes in estimates (i.e., their confidential information) with us on these securities. In making investment decisions or recommendations, we use Morningstar Research Services’ publicly available analysis as part of our review process and do not have access to their analysis prior to its public dissemination. We mitigate any actual or potential conflicts of interest that could arise from the access of their analysis prior to publication through measures such as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. Morningstar Research Services prepares qualitative analysis on separately managed accounts and model portfolios. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis on, nor recommend any Morningstar separately managed account or model portfolio we create and manage. Morningstar Wealth has set up service teams composed of employees of our affiliate and located at our affiliate’s office in Mumbai, India. We compensate our affiliates for services rendered via intercompany charges. The services and compensation will be governed by intercompany agreements. This compensation will likely be lower than compensation negotiated with non- affiliated firms for the same or similar services. To mitigate any conflict of interest between us and our affiliates we have established dual reporting lines for employees on these teams so that such employees report up to employees of Morningstar Investment Management. We’ve also established information security boundaries and technology separation to protect our non- public information and Morningstar’s compliance department monitors the personal trading activity of these employees. Morningstar Research Services LLC is also a wholly owned subsidiary of Morningstar and an investment adviser registered under the Advisers Act. Morningstar Research Services’ offerings center around the production of Some of Morningstar Research Services’ clients are sponsors of funds or associated with other securities that we may recommend to our Institutional Clients. We mitigate any actual or potential conflicts of interests resulting from this fact through such measures as informational barriers (both physical ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 14 of 17 and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar Research Services and their clients when analyzing investments or making recommendations. Morningstar Investment Management serves as an investment adviser to investment companies registered under the Investment Company Act of 1940, as amended, and to other pooled investment products. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis on nor recommend as part of their investment consulting services any investment company we are an investment adviser or sub- adviser to. recommendation to our advisory client to invest in those investment products. In other cases, some of Morningstar’s clients are sponsors of funds that we recommend to our clients. Morningstar does not and will not have any input into our investment decisions, including what investment products will be recommended for our recommended portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar when analyzing investments or making recommendations. We mitigate any actual or potential conflicts of interests resulting from that by not producing qualitative analysis on any such exchange-traded fund as well as imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines between, and monitoring by the compliance department. In some instances, we create portfolios that track an index created and maintained by Morningstar. Morningstar does not and will not have any input into our investment decisions, including what investment products will be included in our portfolios. We mitigate any actual or potential conflicts of interest by imposing informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. Affiliations – Morningstar, Inc. Our parent company, Morningstar, Inc., is publicly traded (Ticker Symbol: MORN). We may recommend an investment product that holds a position in publicly traded shares of Morningstar’s stock. Such an investment in Morningstar’s stock is solely the decision of the investment product’s portfolio manager. We have no input into a portfolio manager’s investment decision nor do we require that the investment products we recommend own shares of Morningstar. An investment product’s position in Morningstar has no direct bearing on our investment selection process. We mitigate any actual or potential conflicts of interest by not factoring Morningstar’s publicly traded stock into our qualitative or quantitative analysis nor in our recommendations. Morningstar offers various products and services to the public. Some of Morningstar’s clients are service providers (e.g., portfolio managers, advisers, or distributors) affiliated with a mutual fund or other investment option. We may have a contractual relationship to provide consulting or advisory services to these same service providers or we may recommend the products of these service providers to our advisory clients. To mitigate any actual or potential conflicts of interest, we do not consider the relationship between Morningstar and these service providers when making recommendations. We are not paid to recommend one investment option over another, including products of service providers with which Morningstar has a relationship. Morningstar has and maintains accounts which they invest in accordance with investment strategies created and maintained by us. Those investment strategies are deployed using equity securities. As we have discretion over these accounts, Morningstar’s accounts are traded at the same time as our and Morningstar Investment Services’ other discretionary client accounts in order to ensure that Morningstar’s accounts are not treated more favorably than our client accounts. Some of Morningstar’s accounts are used as the subject of newsletters offered by Morningstar. In order to ensure that Morningstar’s newsletter subscribers are not treated more favorably than our clients, which would result in a breach of our fiduciary duty, we do not report trades in Morningstar’s accounts invested in our strategies to newsletter subscribers until after our client accounts have been traded or our non- discretionary clients have been notified.(As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. When this occurs, trade recommendations will be communicated to non-discretionary clients after the close of the trading day and seed and Morningstar-affiliated accounts in the Strategies will be traded the next day so that no one person has an advantage over another.) Morningstar provides information to the public about various investment products, including managed investments like open-end mutual funds and ETFs. In some cases, this information includes written analyses of these investment products. Although we use certain products, services, or databases of Morningstar, we do not have any decision-making input in the written analyses that Morningstar provides its licensees. While we consider the analyses of Morningstar, our investment recommendations are oriented to the mandates of the investment products in question. Morningstar hosts educational events and conferences and, in some instances, provides us with the opportunity to suggest invitees or offer (proactively or upon request) discounted or waived registration fees. We mitigate any actual or potential conflicts of interest this introduces by using pre-defined criteria to select Institutional Clients for these opportunities. licenses under Morningstar Investment Services’ As a wholly owned subsidiary, we use the resources, infrastructure, and employees of Morningstar and its affiliates to provide certain support services in such areas as technology, procurement, human resources, accounting, legal, compliance, information security, and marketing. We do not believe this arrangement presents a conflict of interests to us in terms of our advisory services. Employees of Morningstar that provide support services to us have the option to maintain their Financial Industry Regulatory Authority (“FINRA”) security limited broker/dealer registration, if appropriate for their current job responsibilities. We believe no conflict of interest exists due to the maintenance of these security licenses. Morningstar offers various products and services to retail and institutional investors. In certain situations, we recommend an investment product that tracks an index created and maintained by Morningstar. In such cases, the investment product sponsor has entered into a licensing agreement with Morningstar to use such index. To mitigate any conflicts of interest arising from our selection of such investment products, we use solely quantitative criteria established by our advisory client to make such selection, or, in the alternative, Morningstar’s compensation from the investment product sponsor will not be based on nor will it include assets that are a result of our We have the option to make our clients aware of various products and services offered by Morningstar or its affiliates. We do not receive compensation for that introduction. Morningstar and its affiliates also have the option to make their clients aware of various products and services offered by us. Morningstar and its affiliates do not receive any compensation ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 15 of 17 from us for that introduction, unless it falls under a solicitation arrangement, as described in Item 14 below. Interest In Client Transactions Our Access Persons have the option to maintain personal investment accounts and purchase or sell investments in those accounts that are the same as or different from the investments we recommend to clients. Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities should not conflict with our advisory activities or the timing of our recommendations and will not interfere with our clients’ interests, while allowing our Access Persons to invest in their own accounts. Morningstar Wealth, through Morningstar and its subsidiaries, make available products such as: (i) the Morningstar Wealth Strategies; (ii) Morningstar Funds Trust, (iii) Morningstar Office, Morningstar’s RIA portfolio software service; (iv) Morningstar ByAllAccounts, Morningstar’s investment data aggregation service; and (v) Morningstar.com, Morningstar’s individual investor site offering. Daniel Needham, our co-president, has management responsibilities for Morningstar Wealth. We do not believe that these management responsibilities create any material conflicts of interests for our clients, but we mitigate any actual or potential conflicts of interests resulting from that by imposing informational barriers where appropriate and undertaking compliance monitoring. We do not engage in principal transactions (transactions where we, acting in our own account or in an affiliated account, buy a security from or sell a security to a client’s account) nor do we engage in agency cross transactions (transactions where we or our affiliate executes a transaction while acting as a broker for both our client and the other party in the transaction). Affiliations – Morningstar, Inc. Subsidiaries Equity and manager research analysts based outside the United States are employed by various wholly owned subsidiaries of Morningstar. These analysts follow the same investment methodologies and process as Morningstar Research Services, as well as being held to the same conduct standards. As a result, we do not believe this structure causes actual or a potential for a conflict of interest. receive Affiliations – Credit Rating Agency We are affiliated with the Morningstar DBRS group of companies, which include DBRS, Inc., DBRS Limited, DBRS Ratings GmbH, and DBRS Ratings Limited. DBRS, Inc. is registered with the Securities and Exchange Commission as a Nationally Recognized Statistical Rating Organization (NRSRO). Morningstar DBRS’ companies are also registered with and governed by applicable regulatory body or bodies in other countries around the globe. In our analysis of certain securities, we use the publicly available credit rating and analysis issued by Morningstar DBRS. Because of our use of Morningstar DBRS’ ratings and analysis is limited to that which is publicly available, we do not believe there is an actual or potential conflict of interest that arises from such use. Interest In Securities That We May Recommend Morningstar Investment Management has and maintains a number of seed accounts (accounts used to establish a strategy we offer or track), many of which follow strategies we offer to clients. We place block trades for our accounts, therefore trade requests for our seed accounts are placed at the same time as trades are placed for those client accounts invested in the same strategy and for which we have discretion. Block trades are allocated in such a manner as to ensure that our seed accounts do not receive more favorable trades than our clients’ accounts. Client accounts that we manage on a discretionary basis and thus, our seed accounts, are traded before we provide model portfolio trade recommendations to other clients using our model portfolios. However, our model portfolio clients trade recommendation after the close of the trading day, so that no one model portfolio client is favored over another. (As noted above, Morningstar Investment Services anticipates the cessation of its discretionary advisory services by the end of the second quarter of 2025. When this occurs, trade recommendations will be communicated to non-discretionary clients after the close of the trading day and seed and Morningstar-affiliated accounts in the Strategies will be traded the next day so that no one person has an advantage over another.) Personal Trading By Access Persons Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities does not interfere with our clients’ interests. While our Access Persons have the option to maintain personal investment accounts, they are subject to certain restrictions. Our Code of Ethics includes policies designed to prevent Access Persons from trading based on material non- public information. Access Persons in possession of material non-public information are prohibited from trading in securities which are the subject of such information and tipping such information to others. In certain instances, we employ information blocking devices such as restricted lists to prevent illegal insider trading. Morningstar’s compliance department monitors the activities in the personal accounts of our Access Persons (and any accounts in which they have beneficial ownership) upon hire and thereafter. Access Persons are required to pre-clear IPO, initial digital coin offerings, and private placement transactions with Morningstar’s compliance department. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code Of Ethics We have in place a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act (“Code of Ethics”). Our Code of Ethics strives to uphold the highest standards of moral and ethical conduct, including placing our clients’ interest ahead of our own. Our Code of Ethics covers all our officers and employees as well as other persons who have access to our non-public information (collectively “Access Persons”). Our Code of Ethics addresses such topics as professional and ethical responsibilities, compliance with securities laws, our fiduciary duty, and personal trading practices. Our Code of Ethics also addresses receipt and/or permissible use of material non-public information and other confidential information our Access Persons may be exposed and/or have access to given their position. The Code of Ethics is provided upon hire and at least annually thereafter and at each time, the Access Person must certify in writing that she or he has received, read, and understands the Code of Ethics and that they agree to or have complied with its contents. A copy of our Code of Ethics is available to existing and prospective clients by sending written request to compliancemail@morningstar.com. Item 12. Brokerage Practices Where we exercise investment discretion, we will generate trade instructions for each portfolio that requires investment, reallocation or rebalancing and forward those instructions to the appropriate institution as designated by the client. As a result, we do not have the ability to make decisions regarding which broker is used to execute the transactions nor the timing of when the trade is executed. This could result in different pricing of client trades. We do not participate in any soft dollar practices. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 16 of 17 To generate additional income or to earn credits that offset expenses, the Morningstar Funds reserves the right to lend its portfolio securities to unaffiliated broker/dealers, financial institutions or other institutional investors pursuant to agreements requiring that the loans be secured continuously by collateral, marked-to-market daily and maintained in an amount at least equal in value to the current market value of the securities loaned. The aggregate market value of securities lent by a Morningstar Fund will not at any time exceed 33 1/3% of the total assets of the Morningstar Fund. All relevant facts and circumstances, including the creditworthiness of the broker-dealer or institution, will be considered in making decisions with respect to the lending of securities subject to review by the Morningstar Funds Trust’s Board of Trustees. Currently, six of the nine Morningstar Funds participate in a securities lending program. Item 14. Client Referrals and Other Compensation We may make direct or indirect cash or non-cash payments to our affiliates or to unaffiliated third parties for recommending our services. We may also receive direct or indirect cash or non-cash payments from an institutional client if we recommend investors use their services. If such payments occur, they will be done pursuant to Rule 206(4)-1 of the Advisers Act. Those referred by third party solicitors may in some cases pay a higher fee than those who contract with a firm directly. Through disclosures, which are spoken or given in writing to clients at the time of the solicitation, clients or investors solicited by an unaffiliated person or recommended to use our institutional client are made aware of the arrangement between the us and solicitor or us and our institutional client (and therefore that the solicitor has a financial interest in making the recommendation), any other material conflicts of interest, and the terms of any compensation paid directly or indirectly to the solicitor as a result of their referral. The cash collateral received from a borrower as a result of a Morningstar Fund’s securities lending activities will be invested in cash or high quality, short-term debt obligations, such as securities of the U.S. government, its agencies or instrumentalities, irrevocable letters of credit issued by a bank that meets the Morningstar Fund’s investment standards, bank guarantees or money market mutual funds or any combination thereof. Referral fees are typically paid quarterly for so long as the client or investor maintains an applicable agreement for advisory services and the solicitor’s agreement between us and the other firm remains in-force. If at any time either agreement is terminated, the referral fee payments to the solicitor will cease. We receive direct or indirect cash payments from unaffiliated third parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third parties in order to receive the cash payment. Securities lending involves two primary risks: “investment risk” and “borrower default risk.” Investment risk is the risk that a fund will lose money from the investment of the cash collateral received from the borrower. Borrower default risk is the risk that a fund will lose money due to the failure of a borrower to return a borrowed security in a timely manner. There also may be risks of delay in receiving additional collateral, in recovering the securities loaned, or a loss of rights in the collateral should the borrower of the securities fail financially. In the event a Morningstar Fund is unsuccessful in seeking to enforce the contractual obligation to deliver additional collateral, then the Morningstar Fund could suffer a loss. We enter into agreements with certain Institutional Clients whereby we provide compensation to Institutional Clients in exchange for access to their financial professionals to educate them about our advisory products and services, having our name, products, or services listed or highlighted in Institutional Client materials, attendance or booth space at Institutional Client conferences, and/or similar marketing, distribution, and educational activities. We also provide compensation to Institutional Clients to sponsor meetings and events for their financial professionals and/or clients. Item 13. Review of Accounts If included in our contract with an institutional client, we will provide ongoing monitoring of the underlying holdings in investment portfolios and reallocation or rebalancing of investment portfolios. The frequency and nature of our reviews and rebalancing is governed by our contract with each such client. Item 15. Custody We do not serve as a custodian of client assets. However, in cases where we have the ability to debit fees directly from client accounts, we are deemed to have custody of client assets under Rule 206(4)-2 of the Advisers Act, even if we do not act as a custodian. The client is typically responsible for selecting the custodian for its assets. In instances where we recommend an institutional client that offers our Strategies, our financial advisor is responsible for periodically reviewing those client accounts. In most cases, the investor’s financial advisor will review the investor’s responses to a risk tolerance questionnaire or similar information and assist the investor in determining if a Strategy is appropriate for the investor. If it is, the financial advisor will assist the investor in making a final determination as to the most appropriate Strategy for the investor from those available through the institutional client. The investor’s financial advisor will contact the investor at least annually to discuss and review any changes in their financial situation. Item 16. Investment Discretion In some cases, we have complete investment discretion in managing investment portfolios or registered funds for our institutional clients and Morningstar Funds Trust. In other cases, we provide information or make investment recommendations to an investment adviser, broker/dealer, investment committee, board, plan sponsor, financial professional, or other person(s) within an institution designed to help them make investment choices, but the institution or person has the discretion to accept, reject, or modify our recommendations. The extent of our investment discretion is set forth in our contract with our institutional client. We provide ongoing monitoring of the Strategies we offer to seek to ensure each Strategy remains aligned with factors such as its objective, guidelines, and restrictions. Our model portfolios and valuation models are reviewed on at least an annual basis. Investment-specific model portfolios for a retirement plan or product are reviewed on at least an annual basis. When recommending investors to an institutional client that offers our Strategies, we do not have discretion over the investor’s account. We may provide periodic reports to our institutional clients on the investment portfolios and the underlying holdings or retirement plan or product lineup if included in our contract with such client. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 17 of 17 Item 17. Voting Client Securities For the majority of our institutional advisory service arrangements, we do not have the authority to and will not vote proxies. In such situations, proxies or other solicitations will be sent directly to the client and we will not provide information or advice in regard to questions a client has about a particular solicitation. We identify, on an annual basis, certain categories of proxy votes to be reviewed by our proxy committee. In these instances, the vote will be determined on a case-by-case basis based on the Investment Management group’s global proxy voting principles. Upon receipt of a proxy statement, the investment team member with the primary oversight responsibility for the security will review the proxy statement and any additional soliciting materials it is aware of that the issuer has filed and will communicate their recommendation, support for the recommendation, and other pertinent information to the Committee. We do not vote proxies in instances where we provide our Strategies to institutional clients. We do not advise or act for clients in legal proceedings, including class actions or bankruptcies, involving recommended securities. The voting Committee Members will review the proxy issue and the recommendation and will cast their vote as to whether they agree or disagree with the recommendation. If the other voting Committee Members agree with the recommendation, the proxy will be voted in that manner. If there is not a super-majority, the Committee will hold a meeting to discuss the proxy and reach a resolution. The Morningstar Funds have authorized us to vote proxies on their behalf. In turn, in accordance with the sub-advisory agreement entered into between us and each sub-adviser, we have delegated proxy voting authority to the sub-adviser. We have implemented policies and procedures with respect to the portion of the Morningstar Funds that are not managed by a sub-adviser. There may be instances where we will refrain from voting a specific proxy when we believe it is in the best interests of our Morningstar Fund investors. Proxy Voting Policy and Procedures Rule 206(4)-6 of the Investment Advisers Act of 1940, as amended, places a number of requirements on investment advisers with proxy voting authority. These requirements are: by calling 877-626-3227, sending an e-mail How you can Obtain Proxy Voting Information At any time, you may request information on how we voted proxies and/or request a copy of our proxy voting policies and procedures. Requests can be submitted to compliancemail@morningstar.com, or writing to Morningstar Investment Management LLC at 22 West Washington Street, Chicago, IL 60602 ATTN: Compliance. • Adopt and implement written policies and procedures that are reasonably designed to ensure that proxies are voted in the best interest of clients. Such procedures must include how to address material conflicts that may arise between our interests and those of our clients; • Disclose how clients may obtain information about how proxies were voted with respect to their securities; and • Describe to clients our proxy voting policies and procedures and, upon request, furnish a copy of the policies and procedures. Item 18. Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We do not have any financial commitment that impairs our ability to meet our contractual and fiduciary commitments to clients, have we been the subject of any bankruptcy proceeding. Proxy Voting Committee In efforts to mitigate conflicts of interest, we have in place a Proxy Voting Committee (“Committee”). This Committee consists of both non-voting and voting members (collectively, “Committee Members”). Committee Members include members of the investment team serving in a voting role and member(s) of compliance and operations team serving in non-voting roles. The Committee is responsible for tasks such as: • Developing, implementing and updating policy and procedures intended to ensure voting of proxies is conducted in a manner that is in the best interests of Morningstar Funds investors; • Assessing whether proxy voting should be done internally, externally by a third-party vendor, or a combination of the two; • Oversight of a third-party vendor, when applicable; • Making voting decisions (including whether or not to abstain from voting) and ensuring votes are cast on time; • Maintaining documents material to the voting decision; and • Implementing appropriate proxy voting disclosures and maintaining records of communications received from Morningstar Funds investors requesting information on how proxies were voted and our responses. Proxy Voting Process Proxy statement notifications are received by an independent third-party vendor when a proxy statement has been issued on a security that currently underlies a portion of a Morningstar Fund managed by us. This third-party vendor provides additional services such as facilitating vote submissions on our behalf and provides access to e-ballot and meeting information. ©2025 Morningstar Investment Management LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.