Firm Description Affinity Investment Advisors, LLC (“Affinity” or “Firm) is a registered investment advisor providing investment supervisory services to institutional and retail clients since November 1, 2010. Affinity, originally founded in 1992, sold a majority of its assets to Morgan Stanley Investment Management (“MSIM”) in May 2007 with the Firm’s business and investment professionals, along with the client track records, moving to MSIM. In May of 2010 MSIM entered into a bulk sale of selected assets to Invesco including those accounts managed by the Affinity team. Shortly after the close of the transaction, Affinity entered into a purchase transaction with Invesco whereby Affinity purchased the client accounts and the associated track records that were managed by the Affinity team. All the business and investment professionals associated with these accounts moved to Affinity effective November 1, 2010. Principal Owners The principal owner is Mr. Gregory Lai. Types of Advisory Services Affinity provides investment advisory services directly to clients and through sub-advisory relationships for both domestic, international, and various investments portfolios including multi- asset models on a discretionary and non-discretionary basis. The primary elements of this service are the following: (a) Formulation with the client of appropriate investment objectives and restrictions; (b) Implementation of the investment strategy by execution of portfolio transactions as needed; (c) Multi-asset models typically consist of mutual funds, separately managed accounts, ETF's, government securities, limited partnerships, and/or private placements. Affinity will allocate the client's assets among various investments taking into consideration the overall asset allocation and management style selected by the client. Portfolio weighting between funds and managers will be determined by each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. Clients will retain individual ownership of all securities. (d) The continual monitoring of the account for purposes of reviewing its performance and controlling its adherence to strategy and objectives; (e) Furnishing reports to the client concerning account activity, strategy, and performance; and (f) The continual education of both Affinity and client in modern techniques of portfolio management. This is accomplished by constant monitoring of trade journals, academic research, and

attendance of trade seminars. Affinity also participates in programs with third party advisors and sponsors of Unified Managed Account (“UMA”) programs whereby Affinity submits a model portfolio to these parties. Services and fees for these arrangements will be negotiated. Affinity also acts as sub-advisor to the Affinity World Leaders Equity ETF (“ETF,” WLDR). Tailored Relationships Separately managed accounts are tailored to the client’s needs including the ability to manage client restrictions on investing in certain securities or certain types of securities. Any restrictions imposed by the client must be in writing. Wrap Fee Programs The firm participates in a number of wrap fee programs. A wrap fee program is any program under which a client is charged a specified fee or fees not based directly upon transactions in the client’s account for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisors) and execution of client transactions. Sponsors of wrap fee programs are usually broker/dealers who are compensated under these programs for organizing or administering the programs or for selecting or providing advice to clients regarding the selection of professional portfolio managers under the program. A wrap program may not be suitable for all investment needs and any decision to participate in a wrap program should be based on the client’s own financial circumstances and investment goals. The benefits under a wrap program are a function of the size of the client’s account and the number of transactions likely to be generated in the account i.e., wrap accounts may not be suitable for accounts with little activity or accounts comprised principally of fixed income securities. Participating in a wrap program may cost more or less than the cost of purchasing such services separately from the broker or dealer. Affinity receives compensation as a result of the client’s participation in a wrap program. Affinity may have a financial incentive to recommend wrap programs over other programs and services. Affinity utilizes the same investment process and portfolio management disciplines for all accounts managed by the Firm whether in a separate account, UMA, or wrap program format. Client Assets Total Firm Assets as of 12/31/2023 was approximately $938 million. Of the total assets, $935 million was held in discretionary accounts and $3 million in non-discretionary accounts. Additionally, Affinity manages $67 million in assets under advisement, through model programs.