A. Description of Advisory Firm F.L.Putnam Investment Management Company (F.L.Putnam) provides discretionary and non-discretionary investment management, investment advisory, investment consulting, and financial planning services. We have a diverse clientele that includes individuals and their families as well as foundations, endowments, secondary schools, educational institutions, religious organizations, corporations, and other investment advisers. Many of our client relationships span decades and generations. We were founded in 1983 and have been registered as an investment adviser with the Securities and Exchange Commission since 1984. Registration as an investment adviser does not imply a certain level of skill or training. F.L.Putnam is majority-owned by F.L. Putnam Securities Company, Inc., a domestic corporation incorporated under the laws of the Commonwealth of Massachusetts. Certain key employees of F.L.Putnam are also shareholders. F.L.Putnam has established stock ownership plans in order to distribute ownership to employees of F.L.Putnam. Our offices are located in Lynnfield, Needham, and Boston, Massachusetts; Portland, Maine; Wolfeboro, New Hampshire; Providence, Rhode Island; and New York, New York. F.L.Putnam acknowledges that it is a “fiduciary,” with respect to its clients, within the meaning of that term under ERISA. B. Types of Advisory Services Our primary business activity is to provide investment advisory and investment management services to individual and institutional clients on a discretionary basis and financial planning services to individuals and their families. We provide investment management services to some clients on a non-discretionary basis. Additionally, we assist clients with a wide range of investment consulting services. The services that we provide are specifically tailored to each client’s needs and more fully described in their individual contract. We do not sell financial products such as mutual funds, annuities, or insurance. We do not provide brokerage services. C. Tailored Investment Management and Advisory Services  Investment Management and Advisory Services Each institutional client is assigned a team consisting of a primary portfolio manager, a supporting investment advisor, and an account administrator. Each individual or family client is assigned a team consisting of a client advisor and/or an investment advisor, and an account administrator. Each client portfolio is tailored to meet the requirements of each client based on information that a client has provided to us. Our first step in working with our clients is to gather information that will help clients define realistic investment goals, determine income needs, and provide an understanding about the level of investment risk and loss a client is willing and/or able to assume. We then develop a written investment policy statement that is reviewed with each client. The written investment policy statement serves as a guide for the management of a client’s account by the assigned investment advisor(s). Clients may impose investment restrictions on investing in certain securities or types of securities or may direct F.L.Putnam to hold certain securities. F.L.Putnam incorporates environmental, social, and governance (ESG) into its investment and research process. ESG serves as a risk mitigation tool that accompanies our analysis of public company financial statements. We conduct primary and secondary ESG analysis on companies to discern where other risks stemming from environmental policies, social behaviors, and internal governance may exist and factor these findings into our investment selection process. Clients may impose their own ESG investment restrictions. F.L.PUTNAM INVESTMENT MANAGEMENT COMPANY | 5 F.L.Putnam has a long-standing practice in socially responsible investing. Many clients are concerned with the religious, ethical, social justice, environmental, and other non-financial aspects of their investments. These concerns differ from client to client. Clients can exclude (or include) particular activities from their investment portfolios. Within portfolios applying a socially responsible investing approach, we select investments that we believe will provide the potential for a favorable return but are also consistent with those beliefs and ethical preferences that clients have made known to us. F.L.Putnam provides clients with periodic reports describing the applicable non-financial aspects of each company in their portfolios. Clients must opt into these services. We continuously communicate with our clients, but clients must notify us about any changes in their financial circumstances and needs so that we can take these changes into consideration when managing their portfolio(s). Our minimum account size for platform discretionary investment advisory accounts is $250,000. Our minimum relationship size for non-platform discretionary investment advisory accounts combined with financial planning services is $500,000. Our minimum relationship size for Institutional Advisory Services is $10,000,000. Schwab Institutional Intelligent Portfolios In addition to our standard investment approaches, our firm also provides portfolio management services through Institutional Intelligent Portfolios™, an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Program” and “SWIA,” respectively). Through the Program, we offer clients a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at SWIA’s affiliate, Charles Schwab & Co., Inc. (“CS&Co”). F.L.Putnam is independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, CS&Co or their affiliates (together, “Schwab”). The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios™ Disclosure Brochure (the “Program Disclosure Brochure”), which is delivered to clients by SWIA during the online enrollment process. F.L.Putnam, and not Schwab, is the client’s investment advisor and primary point of contact with respect to the Program. Our firm is solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. SWIA’s role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. F.L.Putnam has contracted with SWIA to provide it with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of the F.L.Putnam investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that F.L.Putnam will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but our firm then makes the final decision and selects a portfolio based on all the information F.L.Putnam has about the client. The System also includes an automated investment engine through which our firm manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). F.L.Putnam does not receive a portion of a wrap fee for our services to clients through the Program. Clients do not pay fees to SWIA in connection with the Program, but F.L.Putnam does charge clients a fee for its services as described below under Item

5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to Schwab as part of the Program. Schwab does receive other revenues in connection with the Program, as described in the Program Disclosure Brochure. F.L.Putnam does not pay SWIA fees for its services in the Program so long as we maintain $100 million in client assets in accounts at Schwab that are not enrolled in the Program. If F.L.Putnam does not meet this condition, then we must pay SWIA an annual fee of 0.10% (10 basis points) on the value of F.L.Putnam clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with Schwab. F.L.PUTNAM INVESTMENT MANAGEMENT COMPANY | 6 The Program Disclosure Brochure includes a discussion of various risks associated with the Program, including the risks of investing in ETFs, as well as risks related to the underlying securities in which ETFs invest. In addition, the Program Disclosure Brochure also discusses market/systemic risks, asset allocation/strategy/diversification risks, investment strategy risks, trading/liquidity risks, and large investment risks.  Financial Planning F.L.Putnam offers financial planning services to our individual and family clients, which may cover investment analysis, income tax planning, insurance analysis, retirement planning, education funding, estate planning, cash flow analysis, assistance with budgeting, and preparation of personal balance sheets as well as numerous other items related to a client’s financial profile. Financial planning services can be provided in conjunction with our investment management and advisory services or can be provided on a standalone basis. Based upon a review of information and data provided by the client, a written plan or another agreed-upon deliverable will be prepared that includes our analysis of each client’s current financial conditions, proposed changes, or recommendations. We recommend that clients review their financial plan at least annually or following any significant change to their personal or financial circumstances. We do not provide any accounting, tax, or legal advice and we do not prepare any financial statements, tax returns, or legal documents in connection with the implementation of any financial plan. Standalone financial planning services are rendered only after a written agreement has been executed. The written agreement specifies the parties to the agreement, the date of the agreement, its duration, how and on what terms the agreement may be terminated, and the scope of the services to be provided. After delivery of a written plan or other financial planning product each standalone financial planning client is responsible for the implementation, acceptance, or rejection of the recommendations included in the written plan or other financial planning product. Clients are encouraged to carefully review the financial planning agreement and a copy of this Form ADV Part 2A and to ask any questions they may have, prior to signing the financial planning agreement. F.L.Putnam does not have a duty to update the financial planning services, plans, or recommendations, unless such duty is specifically addressed in our client agreements. If there are any material changes in the client’s financial circumstances and needs during the course of a project, clients must update F.L.Putnam so that we can take these changes into consideration prior to providing the financial planning services.  Separately Managed Accounts F.L.Putnam provides separately managed account (“SMA”) services on a fully discretionary basis. Clients using its SMA services do not receive additional investment advisory services. After gaining an understanding of a client’s particular investment objectives, assets are invested in accordance with one of F.L.Putnam’s SMA strategies. Each client portfolio can be tailored to meet the requirements of each client based on information that a client has provided to us. We work with clients to develop a written set of investment objectives that are reviewed with each client. The objectives serve as a guide for the management of a client's account. Clients may impose investment restrictions on investing in certain securities or types of securities or may direct F.L.Putnam to hold certain securities. F.L.Putnam incorporates environmental, social, and governance (ESG) into its investment and research process. ESG serves as a risk mitigation tool that accompanies our analysis of public company financial statements. We conduct primary and secondary ESG analysis on companies to discern where other risks stemming from environmental policies, social behaviors, and internal governance may exist and factor these findings into our investment selection process. Clients may impose their own ESG investment restrictions. Our minimum account size for Equity SMA strategies is $250,000. Our minimum account size for taxable Fixed Income SMA strategies is $300,000 and $500,000 for tax-exempt Fixed Income SMA strategies. There is also a $1,000,000 minimum account size for the Short Duration Fixed Income SMA strategy. F.L.PUTNAM INVESTMENT MANAGEMENT COMPANY | 7  Investment Consulting F.L.Putnam provides various financial consulting services including, but not limited to, third-party manager due diligence, evaluation, selection and monitoring, advisor oversight, asset allocation advice, client reporting, investment policy design, and portfolio review services.  Atrato Consulting Solution Via its Atrato Consulting Solution, F.L.Putnam offers customized services to clients, including investment advisory, due diligence, portfolio construction, risk analysis, and monitoring of new or existing portfolios. F.L.Putnam assists its clients in identifying and investing in various private investment funds by performing manager due diligence and by constructing and monitoring customized portfolio solutions. In addition, F.L.Putnam works with independent wealth managers and advisors to augment their capabilities in providing alternative investment advisory solutions to their underlying clients. After consultation with F.L.Putnam, the client, when investing in any fund, will invest directly in such fund and will enter into a direct contractual relationship with such fund or its managing partner.  Retirement Participant Account Management F.L.Putnam uses a third-party platform to facilitate discretionary management of assets held in client accounts that are part of defined contribution plans (including, for example, 401k and HSA participant accounts). F.L.Putnam is not considered to have custody of these assets. Through the third-party platform, F.L.Putnam does not have direct access to any client log-in credentials to affect trades. F.L.Putnam is not affiliated with the platform and receives no compensation from the platform. F.L.Putnam does pay a fee to the platform provider. For clients that hire F.L.Putnam to manage their defined contribution plans, a link is provided to the client that allows them to connect their account(s) to the platform. Once a client account(s) is connected to the platform, F.L.Putnam will have access to review the current account allocations and investment options, and to rebalance or reallocate the account based upon the client’s investment goals and risk tolerance. F.L.Putnam will review the account on an ongoing basis and will make any changes to the account to meet the requirements of each client based on information that the client has provided to us. D. Participation in Wrap Fee Programs We do not participate in any wrap fee programs. E. Amount of Client Assets Managed on a Discretionary Basis The amount of assets under our discretionary management as of December 31, 2023: $6,118,000,000 The amount of assets under our non-discretionary management as of December 31, 2023: $50,200,000 The amount of assets under our advisement as of December 31, 2023: $2,137,000,000 F.L.PUTNAM INVESTMENT MANAGEMENT COMPANY | 8