Description of Firm Mill Creek Capital Advisors, LLC (“MCCA”) provides investment supervisory services to high net-worth individuals, pooled investment vehicles, pension plans, endowments, 401(k), 403b and similar institutions, among other types of clients. MCCA has been registered as an investment adviser with the SEC since September 2006. MCCA is primarily owned by SG Management, LLC, an employee owned holding company. Joshua Gross, Chief Executive Officer and Richard Lunsford, President are the principal owners of MCCA. Assets Under Management As of December 31, 2023, we manage approximately $8.2 billion in regulatory assets. Of this total, nearly $8.1 billion is managed on a discretionary basis, while approximately $$113 million is managed on a non-discretionary basis. In addition, we provide advisory or non-continuous management services for approximately $1.3 billion in client assets. Advisory Services Acting as your investment adviser, we build custom investment programs. We collaborate with you to develop objectives within suitable risk/reward parameters relative to your financial circumstances, and then develop an appropriate asset allocation strategy. Prudent risk-taking is at the core of how Mill Creek stewards clients’ investment capital. We marry financial market insights with investment programs designed best to meet each client’s particular risk and return goals. We create and implement a customized investment portfolio or an investment policy statement for each client taking into account its individual needs, including client requested restrictions, cash needs, tax considerations, and other items.. There may be an opportunity to employ client requested restrictions on a case-by-case basis; any proposed client requested restrictions should be provided to MCCA in writing in advance for its consideration. MCCA will also consider allowing clients to impose restrictions on investing in certain securities or types of securities. We practice manager/strategy due diligence and create investment policy statements to inform our discretionary investment management. Along the way, our clients can expect: ― Research and market commentary ― Tactical rebalancing ― Ongoing liquidity and risk management MCCA offers several investment allocation strategies that include equity and fixed income allocations, using both active and passive strategies, in varying percentages; some of these strategies include hedging and/or private equity components. MCCA selects third party investment advisory organizations (“Specialist Managers”) to handle the selection of specific investments consistent with the overall asset allocation strategy developed. Specialist Managers are selected based on our overall evaluation of the investment advisory organization involved, including that organization’s performance against selected benchmarks, investment style within a particular asset class and related factors. MCCA receives a fee for providing the overall asset allocation strategy in addition to other services. We will also negotiate the fees payable to the Specialist Managers on your behalf and communicate client restrictions, if any, applicable to portfolio investments and/or expense management to Specialist Managers. Access to Specialist Managers will be provided by establishing a separate account with a Specialist Manager or through the use of pooled vehicles, including mutual funds and exchange traded funds. Our ability to negotiate fees with Specialist Managers and communicate client restrictions is limited with respect to mutual funds and exchange traded funds. MCCA monitors the performance of Specialist Managers, including their adherence to investment style and continuing suitability with respect to your overall asset allocation strategy, as well as overall expense levels. As part of this monitoring process, we employ the services of various outside consulting and research providers to obtain performance measurement, including index and peer group comparisons, and/or other services. We continuously monitor the capital markets and various asset classes. Periodically, we may recommend

that you make tactical changes to your strategic asset allocation in seeking to avoid risk or attract returns associated with investment opportunities. MCCA utilizes various custodians and back-office service providers to obtain detailed transaction statements on a monthly basis, as well as quarterly and annual performance reports. These custodians and back-office service providers also provide access to your account information through secure, access-controlled websites. MCCA will also work with custodians and service providers that you select. Overall, our services to high net worth families and individuals may include:
• Dedicated Investment Officer team,
• Creation and implementation of a customized investment portfolio,
• Evaluation of tax issues,
• Financial and retirement planning,
• Cash flow analysis,
• Philanthropic planning,
• Estate planning,
• Financial concierge services,
• Comprehensive reporting and online access,
• Family governance and education,
• Coordination with attorneys and accountants, and
• Public and private market access. All in the name of providing our clients with well-informed guidance and peace of mind. We also work with foundations, endowments, non-profits and defined benefit pension plans to understand the organizations’ values and needs over a long-term investment horizon. Our services offered to foundations, endowments, non-profits and defined benefit pension plans may include:
• Dedicated Investment Officer team,
• Creation and implementation of customized investment policy statement if needed and portfolio,
• Special projects and ad hoc analysis,
• Ongoing education of, and communication with, board/committee members,
• Evaluation of long-term spending requirements,
• Comprehensive reporting and online access,
• Cash flow budget and projections,
• Ongoing liquidity and risk management, and
• Public and private market access. All in the name of meeting institutional portfolio goals and helping sustain an institutional financial memory. MCCA manages a series of custom-built private equity investment funds, committing across various vintage years, strategies, managers, and geographies. In 2022, MCCA partnered with Wilshire Advisors LLC to offer an expanded set of capabilities while maintaining MCCA’s discretion on the design of the private equity program. As Special Limited Partner, MCCA retains the right to approve or veto any new primary commitments to private equity fund managers. While MCCA may consider any and all recommendations from Wilshire, the program’s designed in terms of strategy, geography, duration, and vintage diversification was pre-determined by MCCA. MCCA also manages privately offered funds that operate as a “fund of funds” to provide an opportunity for qualified individuals and institutional investors to invest in a diversified portfolio of private hedge funds. MCCA serves as investment manager of the “fund of funds”. MCCA provides advisory, administrative and financial services to the “fund of funds”, including advisory services with respect to the “fund of funds” investment activities. MCCA’s investment committee (the “Investment Committee”) to make all investment decisions on behalf of the “fund of funds” in accordance with the investment management process described in “fund of funds” offering documents. IRA Rollover Recommendations We may recommend the rollover of assets from retirement plans to individual retirement accounts (IRAs). This creates an inherent conflict of interest, as the rollover can result in increased fees and expenses for clients, which may result in higher compensation for our firm. We acknowledge and understand these conflicts of interest and strive to always act in the best interest of our clients. We adhere to a fiduciary standard of care, which means that we are legally and ethically obligated to put our clients' interests ahead of our own. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.