A. Description of the Advisory Firm Brite Investments USA, LLC (“BIUSA”) (formerly known as Touchstone Advisory, LLC) is a Limited Liability Company organized in the State of Delaware. BIUSA primarily offers investment advisory services focused on portfolio management to retail clients residing in the United States (“U.S.”), including United Kingdom (“U.K.”) expatriates who have pension assets located overseas. BIUSA also provides investment advisory services to BIUSA assets custodied in the U.S. The firm operated as Touchstone Advisory, LLC in the U.S. since October 2017. On May 5, 2020, BAH 2021 Ltd (formerly known as Brite Advisory Holdings, Ltd) (“BAH”) acquired Touchstone Advisory, LLC, and during 2021 the legal name of the firm was changed to Brite Investments USA, LLC. BAH also owns Brite Advisors USA, Inc. (“Brite”), which, like BIUSA, is a Registered Investment Adviser. See Item 10 Section C for further discussion. B. Types of Advisory Services Portfolio Management Services Clients engage BIUSA to manage all or a portion of their assets on a non-discretionary basis only. The BIUSA does not act on a discretionary basis for clients. BIUSA’s investment advisory services primarily focus on the use of international pension (including both SIPP and QROPS) schemes, described below, and the allocation of client assets among mutual funds, Exchange-Traded Funds (“ETFs”), individual debt and equity securities, Undertakings for Collective Investment in Transferable Securities (“UCITS”), and currency, consistent with the investment objectives of each client. Clients may elect to allocate their assets according to model portfolios utilized by the BIUSA. Portfolios of clients on the Brite Platform (described in Section F below) are periodically rebalanced to their starting allocations. For clients invested in a Brite Platform model portfolio, investments will be automatically rebalanced by the platform entities in order to maintain recommended asset allocations. On average, model portfolios are rebalanced annually, but rebalancing may occur more or less depending on the circumstances. There may be substitutions of different underlying securities over time within an asset class, but there will be no change in asset allocations without prior notice and written consent obtained from client. BIUSA tailors its investment advisory services to the individual needs of clients. BIUSA consults with clients initially and on an ongoing basis to evaluate their financial situation, risk profile and recent developments that may impact their investment goals. BIUSA utilizes a number of technologies to assist with the process of providing advisory services to its clients. It seeks investments that it believes are in the best interest of each of its clients. Clients are advised to promptly notify BIUSA if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon BIUSA’s investment advisory services. BIUSA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of BIUSA’s economic, investment or other financial interests. To meet its fiduciary obligations, BIUSA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios. Pension Consulting Services BIUSA provides pension consulting services for United Kingdom (U.K) pensions. This service is segmented into two distinct product types: Self-Invested Personal Pension (SIPP) and Recognised Overseas Pension Scheme (ROPS) A Self-Invested Personal Pension (SIPP) is the name given to the type of UK government approved personal pension scheme, which allows individuals to make their own investment decisions from the full range of investments approved by HM Revenue and Customs (HMRC). BIUSA advises on SIPP transfers and provides ongoing portfolio management services for SIPP assets. A ROPS (formally QROPS) is considered a recognised overseas pension if it satisfies certain HMRC requirements. The ROPS manager must have correctly notified HMRC that the ROPS is a recognised overseas pension and provided evidence to HMRC where required. BIUSA provides ongoing portfolio management services for ROPS assets. BIUSA does not advise on ROPS transfers. The custodians previously utilized for ROPS assets are RL 360 in the Isle of Man and Utmost Worldwide Limited in Guernsey. BIUSA’s affiliate company, Brite Advisors, Ltd. (f/k/a Touchstone Advisory Ltd.), had terms of business with RL 360 and Utmost Worldwide Limited. This allowed BIUSA to provide portfolio management services for ROPS assets. BIUSA does not maintain pension assets. All QROPS and SIPP assets are administered by an overseas third-party pension trustee (regulated by the relevant financial services regulator where the pension plan is held) and subject to the terms and conditions of a separate agreement between the client and the pension trustee. The QROPS pension trustees with which clients currently have agreements include STM Malta Trust and Company Management Ltd (“STM Malta”) and Trireme Pension Services (“Trireme”), each an overseas financial services company. The pension trustees for the SIPPs that BIUSA recommends currently include London and Colonial Services Limited (“L&C”), and The Pension Solutions Group SIPP Limited (“PSG”). L&C and PSG are each companies authorized and regulated by the U.K. Financial Conduct Authority (“FCA”). L&C is wholly owned by STM Group Plc, which also owns STM Malta. PSG is indirectly wholly owned by Brite Advisory Group Limited, a Hong Kong company (“BAG”) via its controlling interest in Basi & Basi Financial Planning Limited (“B&B”), a financial

advisory firm based in the United Kingdom. See “F. The Brite Platform,” below. Services Limited to Specific Types of Investments BIUSA generally limits its investment advice to ETFs (including ETFs invested in equity securities, debt securities, and the gold and precious metal sectors), mutual funds, equities, fixed income securities, insurance products including annuities, treasury inflation protected/inflation linked bonds, and non-U.S. securities. For overseas accounts (ROPS & SIPP) and international clients, BIUSA generally limits investment advice to offshore mutual funds and exchange traded funds. BIUSA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions BIUSA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by BIUSA on behalf of the client. BIUSA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BIUSA from properly servicing the client account, or if the restrictions would require BIUSA to deviate from its standard suite of services, BIUSA reserves the right to end the relationship. Clients may elect to allocate their assets according to model portfolios developed or approved by BIUSA. Portfolios of clients on the Brite Platform (described in Section F below) are automatically rebalanced to their starting allocations approximately annually. Brite’s model portfolios consist primarily of Exchange Traded Funds (“ETFs”). D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. BIUSA does not participate in any wrap fee programs. E. Assets Under Management BIUSA has the following assets under management (“AUM”). Discretionary AUM Non-Discretionary AUM Date Calculated $0 $36,472,282 December 31, 2022 F. The Brite Platform BIUSA has entered into a platform agreement with Brite Advisory Group Limited, a Hong Kong company (“BAG”) pursuant to which BAG (the “Platform Provider”), through one or more of its direct and indirect wholly owned companies, has agreed to make available to BIUSA’s clients an end-to-end retirement solution that is tailored for U.K. expatriates residing in the U.S. who desire to transfer their U.K. pension assets out of the U.K. (“Brite Platform”). The Brite Platform also is available to clients with existing QROPS or SIPP accounts. The Brite Platform integrates the U.K. pension asset transfer process with overseas pension trusteeship, asset management, trading, custody, and reporting, as follows: Service Provider
• Pension Transfer Analysis Onvestor Reporting (“Onvestor”), a trading style of Basi & Basi Financial Planning Limited.
• Pension Trustees SIPPs: The Pension Solutions Group SIPP Limited (“PSG”), and London and Colonial Services Limited (“L&C”) QROPS: MC Trustees (Malta) Ltd. (“MC Trustees Malta”), Trireme Pension Services, and STM Malta
• Investment Adviser Brite Investments USA, LLC
• Trading and Custody Interactive Brokers (Australia) Pty. Ltd (“IB”)
• Custody and Reporting Brite Advisors Pty Ltd (Australia) (“PTY”) Onvestor is a trading style of Basi & Basi Financial Planning Limited (B&B), an “Appointed Representative” (“B&B”) per regulations of the FCA. Michael Basi, managing director of B&B, currently owns a non-controlling interest in Onvestor. B&B is authorized and regulated by the FCA, and directly wholly owned by BAG. PTY is directly wholly owned by BAG. BAG indirectly owns a non-controlling interest in MC Trustees Malta, and PSG. BIUSA’s ultimate individual owner currently serves as Chief Marketing Officer of BAG, but BAG does not own any direct or indirect interest in BIUSA. As consideration to BAG for making the Brite Platform available to BIUSA’s clients, BIUSA has agreed to pay BAG a quarterly fee at the annual rate of 0.10% of the clients’ pension assets on the Platform (“Platform Fee”). BIUSA pays the Platform Fee out of the advisory fee it charges clients, as discussed in “Item 5. Fees and Compensation” below. It is not a separate or additional charge. For performing the Pension Transfer Analysis required by FCA regulation, Onvestor charges a fee that is described in “U.K. Suitability Report Fee” under “Item 5 – Fees and Compensation – Additional Compensation” below. For existing clients who are currently utilizing a QROPS or a SIPP from one of the pension trustees discussed above in “Item 4B – Types of Advisory Services” under “Recognised Overseas Pension Scheme (ROPS)” the Brite Platform is expected to offer cost savings. Accordingly, it may be in the best interest of clients to transfer their pension assets to the Brite Platform. To help determine whether a transfer to the Brite Platform is in a client’s best interest, BIUSA’s IARs will provide the client with a comparative analysis of the fees and costs, available investment alternatives, and other features of the client’s current QROPS or SIPP arrangement as compared to those available under the Brite Platform (“Comparative Analysis”). All securities transactions on the Brite Platform are executed through omnibus accounts that Brite Australia Pty Limited ("PTY") maintains in its name, as account holder, with Interactive Brokers Australia Pty Limited ("IBAU"), the broker for the Brite Platform.